ETLS Gap Analysis – Ghana ––December 2010
GHANA: A GAP ANALYSIS OF ECOWAS
MARKET INTEGRATION
West Africa Trade Hub Technical Report No. 36
Acknowledgements
The authors wish to express their gratitude to the numerous individuals in the countries that
participated in this analysis who donated hours of their time to answer questions. This report could not
have been produced without the able assistance and devotion of the teams that conducted interviews
across the region: Mashood Ilupeju, Ometere Omoluabi, Jane Owiredu-Yeboah, Jeremy Streatfeild
and David Tanenbaum and the research assistance of Kwasi Osei-Kusi. Thanks also to the technical
writing and editing team including Fred Levitan, John O’Connell, Denise Awoonor-Renner and Ryan
Yingling.
DISCLAIMER
The authors’ views expressed in this publication do not necessarily reflect the views of the United
States Agency for International Development or the United States Government.
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ETLS Gap Analysis – Ghana ––December 2010
Table of Contents
Table of Contents .................................................................................................................................... 3
List of Figures .......................................................................................................................................... 4
List of Tables ........................................................................................................................................... 4
Abbreviations & Acronyms ...................................................................................................................... 5
Executive Summary ................................................................................................................................ 6
1
2
Introduction and Background .......................................................................................................... 9
1.1
Objectives and Methodology .................................................................................................... 9
1.2
Legislative actions of the Ghanaian Government ................................................................... 10
1.3
Ghana Trade Background ...................................................................................................... 11
1.4
How to Use This Study ........................................................................................................... 11
Overall Findings ............................................................................................................................ 13
2.1
Specific Findings Regarding Implementation of ETLS in Ghana ........................................... 13
Private and Public Sector Responses to ETLS Protocol Implementation......................................... 15
2.2
3
4
5
Key recommendations for Ghana ........................................................................................... 16
Transport ....................................................................................................................................... 17
3.1
Rules and Procedures on Transport ....................................................................................... 17
3.2
Private and Public Sector Responses to Survey on ETLS Protocols ..................................... 19
3.3
Implementation of ETLS Transport Protocols......................................................................... 25
3.4
Recommendations for Transport ............................................................................................ 26
Movement of Goods ...................................................................................................................... 28
4.1
Rules and Procedures on Movement of Goods...................................................................... 28
4.2
Private and Public Sector Responses to Survey on ETLS Protocols ..................................... 29
4.3
Secondary Findings and Anecdotal Reports .......................................................................... 33
4.4
Implementation of Free Movement of Goods ......................................................................... 35
4.5
Recommendations on Movement of Goods ........................................................................... 37
Movement of Persons ................................................................................................................... 39
5.1
Rules and Procedures on Movement of Persons ................................................................... 39
5.2
Private and Public Sector Responses to Survey on ETLS Protocols ..................................... 40
5.3
Secondary Findings and Anecdotal Reports .......................................................................... 42
5.4
Implementation of Free Movement of Persons....................................................................... 43
5.5
Recommendations for Movement of Persons ........................................................................ 43
6
Conclusions ................................................................................................................................... 44
7
Annexes ........................................................................................................................................ 45
Annex A:
Documents for Import and Export in Ghana ..................................................................... 45
Annex B:
Ghana Trade Regulations Catalog ................................................................................... 56
ANNEX C: ECOWAS Templates versus National Templates ............................................................ 64
Annex D:
Private Sector Survey Compilations ................................................................................. 79
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ETLS Gap Analysis – Ghana ––December 2010
Annex E:
Public Sector Survey Compilations ................................................................................ 84
ANNEX F:
Immigration Pamphlet .................................................................................................... 90
ANNEX G:
List of Possible Cross-Border Documentation Requirements for Ghana as produced
by GCNet ....................................................................................................................... 91
ANNEX H:
Ghana Institute of Freight Forwarders List of Fees ....................................................... 92
ANNEX I:
Ghana Axle-Load Diagrams........................................................................................... 94
List of Figures
Figure 1: Ghana: Public and Private Sector Reporting of Non-Implementation of ETLS Protocols on
Transport, Movement of Goods and Persons. ...................................................................... 15
Figure 2: Transport: Public and Private Sector Reporting of Non-Implementation of ETLS Protocols 20
Figure 3: Movement of Goods: Public and Private Sector Reporting of Non-Implementation of ETLS
Protocols ................................................................................................................................ 30
List of Tables
Table 1: Key Recommendations for Ghana .......................................................................................... 16
Table 2: Legislation on Transportation .................................................................................................. 17
Table 3: Implementation of ETLS Transport Protocols ......................................................................... 25
Table 4: Priority Recommendations on Transport ................................................................................ 26
Table 5: Chart of ECOWAS Text and Ghanaian Trade Regulations on Free Movement of Goods ..... 28
Table 6: Implementation of Free Movement of Goods ......................................................................... 35
Table 7: Priority Recommendations for Free Movement of Goods....................................................... 37
Table 8: Legislation on Free Movement of Persons ............................................................................. 39
Table 9: Implementation of Free Movement of Persons ....................................................................... 43
Table 10: Priority Recommendations for Free Movement of Persons .................................................. 43
4
ETLS Gap Analysis – Ghana ––December 2010
Abbreviations & Acronyms
CEPS
Customs Excise and Preventive Service
CET
Common External Tariff
CIF
Cost, insurance and freight
COO
Certificate of Origin
Gap Analysis The gap analysis undertaken by USAID’s West Africa Trade Hub in relation to
the ETLS
GDP
Gross Domestic Produce
ECOWAS
Economic Community of West African States
ETLS
ECOWAS Trade Liberalization Scheme
FCVR
Final Classification and Valuation Report
IDF
Import Declaration Form
ISRT
Inter-State Road Transit Scheme
MOF
Ministry of Finance
MOFA
Ministry of Foreign Affairs
MS
Member State(s) of ECOWAS
NTB
Non-tariff barrier
SAD
Single Administrative Document
UEMOA
Union Economique et Monétaire Ouest Africaine (also known as WAEMU)
USAID
United States Agency for International Development
VAT
Value Added Tax
WAEMU
West African Economic Monetary Union (also known as UEMOA)
5
ETLS Gap Analysis – Ghana ––December 2010
Executive Summary
Introduction
The essential features of the ECOWAS free trade area known as the ECOWAS Trade Liberalization
Scheme (ETLS) are the free movement of transport, goods and persons within ECOWAS, including
1
the removal of all tariff and non-tariff barriers to trade. The benefits of the ETLS for West Africa, when
fully implemented would be—greater economic growth, more jobs and lower consumer prices. In the
longer term, ECOWAS envisions progressing from a free trade area to a full customs union and
eventually a common market to facilitate trade in the region. The free trade area, however, is a
necessary precursor to these broader goals of enlarged local market, realizing economies of scale
and strengthening bargaining positions in global negotiations, and in order for it to be effective,
ECOWAS member states (Member States) need to implement the ETLS’s provisions uniformly.
The USAID West Africa Trade Hub, as part of its support to ECOWAS, undertook a gap analysis of
the ETLS (Gap Analysis) to identify which aspects of the ETLS protocols are being implemented in
individual Member States, and which aspects are not, and what public and private sector stakeholders
view as the obstacles to implementation. The study included detailed research in Member States in
order to provide a comprehensive presentation of the situation and offer recommendations for
improvement.
USAID funded the ECOWAS-wide gap analysis of the ETLS implementation in nine countries in the
sub-region. As part of this study, the Gap Analysis research team assembled a large volume of
protocols, laws, forms and other documents that pertain to the ETLS rules and procedures. These
documents were sometimes difficult to find, even for trade and customs experts.
The initial findings were published in May 2010 in one comprehensive report Gap Analysis—
ECOWAS Free Trade Area: Preliminary Findings. The Gap Analysis research team also published
drafts of individual country-specific reports. The research team subsequently undertook a validation
trip to various countries to update its findings in relation to rules and procedures and fill outstanding
gaps.
This report summarizes the Gap Analysis findings specifically in relation to Ghana following the
validation process. This report should be read together with the comprehensive regional report, which
contains a detailed introduction and complete presentation of the methodology for the study, as well
as a comparison of how Ghana and other ECOWAS economies comply with ETLS protocols.
The Ghana Gap Analysis provides a framework for action that can be used by the Government of
Ghana and ECOWAS to address the problems associated with the dysfunctional free trade area.
ECOWAS can use the tables and annexes provided within this report to update its website on
implementation of the ETLS by Member States and to monitor Ghana’s progress.
Government of Ghana officials and donors can use this report to identify issues of transparency,
information dissemination, technical capacity and legislative and/or regulatory changes necessary for
full ETLS implementation.
The private sector can use the report to better understand its rights and obligations when transporting
goods through Ghana and to advocate for proper implementation of the ETLS.
1 ECOWAS or the Economic Community of West African States is a regional community of fifteen countries, founded in 1975.
6
ETLS Gap Analysis – Ghana ––December 2010
Methodology
The Gap Analysis took stock of the broad issues facing the ETLS and pinpointed specific rules and
regulations that need to be modified, the ECOWAS Acts that need to be updated, and how to change
poor implementation behavior.
The Gap Analysis relied on both legislative analysis to see where trade laws and regulations stand in
terms of aligning with the ETLS protocols, and surveys of the public and private sector to provide a
realistic evaluation of the effectiveness of the ETLS implementation and ascertain the extent to which
information about the scheme was disseminated.
Results for Ghana
There are two major areas where ETLS Protocols have not been implemented which present
significant obstacles to increased regional trade.
1. Application of Duty by Customs on ECOWAS Originating Goods
The most important area of non-compliance with ETLS protocols involves the application of
duties to ECOWAS originating goods as reported by the private sector. Ghana applies a host
of other legal fees and taxes which add substantial costs to the conduct of trade. These
additional taxes and fees are not part of the ETLS but they do affect the competitiveness of
West African goods and the cost of goods to consumers.
2. Non-tariff Barriers including Seasonal and Quota Restrictions
The second most significant area of non-implementation of ETLS protocols which merits
2
attention relates to merchandise that is banned from importation or restricted by quotas. Only
a few items are subject to these restrictions but they tend to be unprocessed agricultural
items, which are exported from other Member States which could have a positive impact on
their respective economies if allowed to be traded freely. Moreover, these items are often
restricted for many months at a time and often treated inconsistently by customs officials.
Other areas where lack of implementation of the ETLS has an impact is in transportation and the
movement of goods.
Three overarching challenges prevent the full operation of ETLS protocols in Ghana:
1. The private sector is aware of the protocols but dissatisfied with the pace of implementation
and has an attitude that informality may be less costly in time and money than strict
adherence to the rules.
2. Complex and duplicative border procedures encourage incentives for informal trade.
3. Low earnings for public servants in trade and transport along with broader implementation of
Ghana’s newly established integrity program. The integrity program was designed to provide
incentives to customs officers for trade facilitation and respect within the public sector to act
as a role model for wiping out corruption.
Recommendations
The Ghana Gap Analysis study revealed that incomplete and inconsistent implementation of ETLS
protocols within the country has a host of negative effects, including increasing the costs and
unpredictability of trade and discouraging business expansion and investment. Notwithstanding, it
must be recognized that tariffs are an important source of revenue for customs operations.
The solutions are two-fold. First the trade community’s awareness and knowledge of the ETLS
protocols must be improved. Simultaneously trade officials’ capacity to understand and implement the
ETLS protocols needs to be increased. It will be difficult to improve implementation of the scheme if
regional customs officials and traders do not understand its provisions. Second, the political will must
exist to forego revenues gained from non-compliance with ETLS protocols, to ensure that businesses
2 Non-tariff barriers to trade (NTBs) are trade barriers that restrict imports but are not in the usual form of a tariff. Some
common examples of NTBs are import bans, general or product-specific quotas, seasonal import regimes.
7
ETLS Gap Analysis – Ghana ––December 2010
and investors can benefit from the regulations and legislations enacted in support of the free trade
area in case of a trade dispute, and foster an environment of legality and freer movement of transport
on the roads and at the borders. Ultimately, to make this work, neighboring countries need to do the
same.
8
ETLS Gap Analysis – Ghana ––December 2010
1
Introduction and Background
1.1 Objectives and Methodology
ECOWAS and ETLS
In 1975, the 15 ECOWAS member states made regional integration their primary objective. The
ECOWAS Trade Liberalization Scheme (ETLS) is a set of protocols that govern the movement of
3
goods and persons across the region. The objective of the ETLS is to establish a customs union
among the Member States, which was to have been achieved over a period of 15 years starting from
January 1990, the date upon which the ETLS entered into force. The ECOWAS customs union is to
include a free trade area that eliminates customs duties and taxes having equivalent effect, removal
of all non-tariff barriers, and establishment of a common external tariff (CET). Now, some 20 years
after the ETLS was launched, the level of implementation in each Member State remains inconsistent.
Given the enormous economic benefits that a fully functioning free trade area would provide to the
region, it remains of critical importance to identify obstacles to full implementation of the ETLS.
ECOWAS is not the only regional institution. It co-exists alongside UEMOA, the Union Economique et
Monétaire de Ouest Africaine or West African Economic and Monetary Union, and is a distinct
economic sub-group. This sub-group, which comprises eight countries, is a monetary and customs
union with a common currency, the CFA franc. Its member countries are Benin, Burkina Faso, Côte
d'Ivoire, Guinea Bissau, Mali, Niger, Senegal and Togo. There is a distinction in the manner in which
UEMOA and ECOWAS operate. UEMOA is part of ECOWAS but distinguishes itself not the least by
being a monetary and customs union. There are variations in protocol implementation between the
two organizations. For example, Ghana uses an automated system for customs declaration forms
which has no place for the ISRT Logbook, a UEMOA initiative. However, ECOWAS has an ongoing
program to extend automation across West African states and eliminate manual processing and
therefore the use of the ISRT Logbook.
Objectives for Gap Analysis
As part of its support to ECOWAS the USAID West Africa Trade Hub, designed a study to assess
progress in implementation of the ETLS protocols in nine Member States. The objectives of this ETLS
gap analysis are:
1. To assess whether the Member States have promulgated laws adopting the ETLS protocols
and whether those laws and regulations are easily accessible by the public;
2. To measure the level of implementation of ETLS protocols by the government agencies
tasked with day-to-day implementation, both in the capital city and at border posts which
process goods being transported into and through each country; and
3. To identify the areas where changes to properly implement the ETLS will have the greatest
impact on the competitiveness of West African products.
Methodology and Procedures for Gap Analysis
The research team examined the implementation of ETLS protocols in Ghana from three
perspectives:
1. Status of promulgation of the protocols in national legislation
2. Degree of implementation of protocols from the private sector’s perspective
3. Degree of implementation of protocols from the public sector’s perspective.
In Ghana, 21 companies and seven governmental agencies participated in in-depth interviews in the
capital city of Accra and at the borders of neighboring countries—Togo and Burkina Faso. The
3 In this report, the terms ECOWAS Acts and ETLS/ECOWAS protocols are used to describe: ECOWAS Acts, Decisions of the
Authority of Heads of State and Government, Regulations of the Council of Ministers, and secondary legislation – resolutions,
recommendations and declarations.
9
ETLS Gap Analysis – Ghana ––December 2010
research team compared the interview responses and contrasted the public sector’s understanding of
how protocols were being implemented with the private sector’s experience in trying to move goods
through the country. The team interviewed public officials at different levels of government to
determine whether guidance on protocol implementation is disseminated effectively through the
ranks.
The survey uses as its basis the Acts, Protocols, Decisions, Regulations, and Resolutions signed by
Member States for the implementation of the free trade area.
Two Trade Hub research teams conducted the Gap Analysis:
x
A public sector team interviewed, among others, customs, foreign affairs and trade officials to
determine which laws were being implemented in the areas of transit operations and transport,
and the movement of goods and people across borders; which issues were being encountered
in the implementation process; and to assess the need to change the protocols to meet
contemporary trade and implementation issues. The public sector team also retrieved sample
documentation necessary for cross-border movement and collected related legislation and
regulations.
x
A private sector team interviewed, among others, unions, truck drivers, and traders to
determine whether they were benefiting from full ETLS implementation; to assess their
experiences at border posts in each of the three areas of this study; and to identify the issues
they considered most important for trade in terms of reducing the cost and time spent.
1.2 Legislative actions of the Ghanaian Government
The ECOWAS Treaty of 1993, via Articles 5 and 9, instructs Member States to implement the
provisions of the Treaty, of which the ETLS protocols are an integral part. The Authority of Heads of
State and Government can act by ‘decisions’ whilst the Council of Ministers has to act by ‘regulations’.
Decisions of the Authority of Heads of State and Government are binding on the Member States and
all community institutions. Regulations of the Council of Ministers are binding on all subordinate
community institutions and bind Member States only up on their approval by the Authority of Heads of
State and Government. The Treaty requires each Member State to publish the decisions and
regulations in their national Official Gazette within 30 days of their signature. Member States are also
obligated to reconcile any conflicts between ECOWAS Protocols, Supplementary Acts, Decisions,
4
etc., and national laws or regulations.
The research team’s interviews with public and private sector officials in Member States have shown
that publication and reconciliation of ETLS protocols with national laws does not always occur. In
Ghana, the application of ECOWAS protocols to domestic law is not automatic. When there is preexisting national legislation on the subject of the newly signed protocol, the government generally
initiates a legislative process that reconciles national law with the terms of the agreed protocol.
The process begins when the representative signs an Act at an ECOWAS meeting, which only
constitutes a commitment to adopt at the ECOWAS level. For the Act to be passed at the national
level it is submitted to the national parliament for approval. In some cases a sub-committee may be
created to review a particular issue, which can be opened up to the public for comment. Once the
parliamentary process is complete, the draft legislation has to be approved by the President and
published in the national Official Gazette for at least 21 days. From the moment the President signs
the Act it becomes law, and should be implemented by the national agency responsible.
In instances where the subject of a protocol is not contemplated in national law, the Government of
Ghana may follow the same process as just described or the Government may not take legislative or
regulatory steps to enforce specific protocols. The legislation tables in this report show the alignment
of ETLS protocols vis-à-vis Ghana’s national laws and regulations.
4 For further reference, the full ECOWAS Treaty can be found here:
http://www.comm.ecowas.int/sec/index.php?id=treaty&lang=en.
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ETLS Gap Analysis – Ghana ––December 2010
1.3 Ghana Trade Background
Ghana is well endowed with natural resources and has roughly twice the per capita output of the
poorest countries in West Africa. Even so, Ghana remains heavily dependent on international
financial assistance. Gold, cocoa production, timber and individual remittances are major sources of
foreign exchange. The domestic economy continues to revolve around agriculture, which accounts for
about 35% of gross domestic produce (GDP) and employs about 55% of the workforce, mainly small
landholders. Sound macro-economic management along with high prices for gold and cocoa helped
5
sustain GDP growth in 2008.
Ghana, one of the best-performing economies in the region, rates well in terms of fiscal freedom,
6
government size, and property rights. The top rates of income and corporate tax are moderate, and
the overall corporate tax burden is not excessive as a percentage of GDP. An expanding private
sector, macroeconomic stability, and ongoing reforms in the financial sector have contributed to
7
relatively steady economic growth in recent years. With this economic underpinning, Ghana is poised
to take greater advantage of free, unhindered trade with its neighbors.
Ghana ranks 69th out of 179 countries in Transparency International's Corruption Perceptions Index
for 2007, a slight improvement from 2006. A poll measuring public trust in the Government found that
the courts were one of the least trusted institutions, second only to the police. The topic of corruption
is important, as the research team discovered during interviews with the private sector. The private
sector noted several instances in which it felt corruption played a role during cross-border movement.
While this may present an additional obstacle to the ETLS, the community is hopeful that Ghana can
8
take advantage of its strengths and work towards freer regional trade.
Despite all the measures taken for economic integration purposes the level of intra-ECOWAS trade is
very low. For instance, according to Ghana’s WTO Trade Policy Review, in 2005, less than 3% of
Ghana’s exports went to other Member States (mainly Guinea, Benin, and Nigeria) and only 2% of its
imports originated from ECOWAS (mainly Togo). This low level of sub-regional integration is
attributed to the low degree of implementation of the ETLS.
1.4 How to Use This Study
This study is divided into three sections: Transport, Movement of Goods, and Movement of Persons.
Each section contains three tables. ECOWAS can use these tables and the annexes to update its
website on ETLS implementation by Member States and to monitor Ghana’s progress towards
meeting the terms of ECOWAS agreements. Ghana’s government officials and donors can use the
tables to identify issues of transparency, information dissemination, technical capacity and legislative
and/or regulatory changes required for full ETLS implementation. The private sector can use the
report to better understand its rights and obligations when transporting goods through Ghana and to
advocate for proper ETLS implementation.
1. Table comparing rules and procedures
The first table in each section compares ECOWAS protocols with the corresponding national
laws. Citations for laws are provided where available. The legislation table also indicates
whether or not the national law is easily accessible by the public. All citations, from both the
ECOWAS Acts and Ghana’s legislation and regulations have been paraphrased or truncated
for the sake of brevity.. A full chart of national legislation and or implementing regulations as
they relate to the ETLS protocols can be found in Annex B.
5
2009 CIA World Factbook, https://www.cia.gov/library/publications/the-world-factbook/geos/gh.html
Economic Freedoms, http://www.heritage.org/Index/Country/Ghana
Democracy wins in Ghana, 17 Jan 2009, http://www.globalpost.com/dispatch/ghana/090114/democracy-wins-ghana
8
Doing Business in Ghana: A Golden Opportunity, 29 Apr 2009,
http://www.dynamicexport.com.au/export/managing/doing-business-in-ghana/
6
7
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ETLS Gap Analysis – Ghana ––December 2010
2. Table of ETLS implementation and interview response summaries
The second table in each section lists ECOWAS protocols, and compares the public and
private sector interview responses. In many cases, the responses on whether or not a
protocol has been implemented differed significantly between the public and private sector,
and also between the public sector at the capital and the public sector officials stationed at
the border. The table is color-coded for easy identification of problem areas. Action items are
recommended, and the table includes a column for important issues reported during the
interview process. The interview response compilations for the private sector can be found in
Annex D, and the interview response compilations for the public sector are in Annex E.
3. Priority recommendations
The third table summarizes the top recommendations for action in each section, including the
agencies responsible for effecting change.
Interview Result Discussions
In addition to the tables, each section contains discussions of the interview results reported by public
sector officials as well as the private sector.
12
ETLS Gap Analysis – Ghana ––December 2010
2 Overall Findings
2.1 Specific Findings Regarding Implementation of ETLS in Ghana
Capacity building required for public sector to assist the private sector more effectively
in facilitating trade
Most of the public institutions are cognizant of and profess adherence to the ECOWAS protocols.
However, interviews with public officials revealed some discrepancy in this answer, to the extent that
Ghana imposed some non-tariff barriers or quantitative restrictions. For example, in 2008, textile
imports were banned from all but one port of entry – and not the main port - in order to protect the
9
domestic textiles industry.
While a few documents are available on the Ghana Customs Excise and Preventive Service (CEPS)
website, it is unclear exactly where all necessary trade related documents are located and difficult for
the public sector to advise consumers on where to access customs and trade regulations. There also
appears to be some difference in the application of the Brown Card insurance scheme in Ghana and
Nigeria versus other Francophone countries. Ghana issues a Brown Card with 3 months’ validity of,
while Francophone countries issue a Brown Card valid for one year.
Communication of any updates in procedures for trade is conducted through word of mouth or by
sending the Official Gazette to border officials for their own interpretation. Few, if any, of the public
sector officials interviewed had any knowledge of the national implementing legislation for the
corresponding ECOWAS protocol.
As the Gap Analysis was being conducted and due to the lack of access to regulations regarding the
free movement of goods into Ghana from the ECOWAS region, a Trade Hub Customs Expert called
customer service for Ghana Community Network (GCNet).10 The call was initiated to gain an
understanding of the acronyms associated with the HS nomenclature listing and the import levies
assessed on someone exporting live goats from Nigeria into Ghana.11
The GCNet representative stated that the ECO levy, which he correctly defined as the ECOWAS
Levy, was a tax applied on imports from the ECOWAS region. In reality, it is a levy that is assessed
on goods originating from non-ECOWAS countries. When asked how an exporter of goats from
Nigeria could gain duty free access to Ghana, the representative told the caller that they would have
to work with a customs agent if they want concessions. When asked about the ECOWAS customs
union and free trade area, the GCNet representative said “I don’t know anything about that”, The
caller then asked representative to transfer him to a customs agent and was told that he could be
transferred , but that the customs agent would charge a fee for the query.
Private sector demonstrates awareness of protocols and dissatisfaction with pace of
implementation
The research team’s investigations into the Ghanaian private sector’s trade experience showed a high
overall awareness of the ETLS and that certain paperwork-based elements of the regime were
operational on a regular basis (e.g. visa-free travel, ISRT Logbook). A majority of the respondents
demonstrated a familiarity with the ETLS and the way the process should be working. Similar to the
team’s findings in other countries, such gaps as exist between the ETLS protocols and their
implementation in the field, do not, at this stage, appear to result from a failure to promulgate. Rather,
9 In an attempt to control the smuggling of cheap textiles imports from China, via the Aflao border in particular, Ghana imposed
a NTB on textile imports that sought to authorize textiles through one port of entry – Takoradi.
10 GCNet is an electronic system for processing trade and customs documents.
11 The Harmonized System (HS) classification nomenclature is a goods classification system which was developed by the
World Customs Organization and has become the de facto standard used.
13
ETLS Gap Analysis – Ghana ––December 2010
respondents indicated that there were long-standing structural reasons for the overall slow rate of
implementing the ETLS, for example poor infrastructure and illicit fees.
In some respects, among the initial Gap Analysis countries, knowledge of the ETLS appeared highest
in Ghana. Research did not, however, demonstrate conclusively that this greater level of knowledge
translated into more confidence that ETLS was being successfully implemented. Indeed, the litany of
concerns continued—confusion at the borders and inconsistent application of the regulations, whether
national or ETLS based.
At Tema port, one of the busiest ports in West Africa, the trade community is used to dealing with
goods bound for many of the nearby countries. The freight forwarders and logistics companies were
well informed about the ETLS and attendant rules and regulations. Generally the port officials at
Tema received good reviews. However, once the cargo was on the road, it was a different story. In
particular, interviewees noted difficulties arising from the disparate requirements between Anglophone
and Francophone countries. Different documentary requirements, trucking protocols (e.g. 2/3 of all
Mali- and Niger-bound cargo must be shipped on those countries’ trucks) and agents unfamiliar with
the ETLS requirements were all mentioned as factors contributing to the difficult trade environment.
At the Aflao border with Togo, stories abound of month-long waits at border crossings for various
reasons, often beyond the control of the drivers or truck owners (e.g., valuation disputes between a
private inspection company and customs service). The expediters and truckers had different
understandings of some of the documentary and procedural requirements, but agreed on the failures
of ETLS to promote free movement. They witnessed the problems every day, and felt that only a
wholesale commitment by Member States to raise the quality and remuneration of the border officials
would change the status quo. Again, public sensitization, education and greater resources focused on
the problems were thought to be required.
The situation was perhaps best summed up by the President of the Association of Ghanaian
Industries who noted that every element of ETLS, from registration of companies to normalizing
border procedures, had failed to one degree or another. In his estimation, haphazard implementation
of ETLS protocols had left the state of trade in worse shape than before. He considered that more
rules lead to more opportunities to extract funds from the trading public, to the detriment of inter-state
commerce.
Inconsistent and incomplete implementation of the ETLS causes significant barriers to
trade
The Ghana study found significant gaps between official reported policy and traders’ experience
bringing goods across the country’s borders. The two most significant gaps, inconsistent and sporadic
duty-free entry of ECOWAS-originating merchandise and non-tariff barriers including seasonal
restrictions/quotas makes trade more expensive and increases the costs for manufacturers,
transporters and others involved in international trade. Even worse, inconsistent application of policies
and procedures makes the costs of trade unpredictable and discourages investment and business
expansion.
Key recommendations for the areas that will have the biggest impact on trade include prompt
implementation of the ECOWAS protocols calling for duty-free treatment of all ECOWAS-originating
merchandise and removal of non-tariff barriers including seasonal bans and quotas.
1. Allow duty-free access to goods of ECOWAS origin
The most important area of non-compliance with ETLS protocols involves customs’
application of duty on goods originating from ECOWAS. Ghana applies a host of non-ETLS
legal fees and taxes which add substantially to the costs of trade; this should be reviewed
with regard to increasing the competitiveness of African products.
2. Remove seasonal and quota restrictions
The second most significant area of non-implementation of ETLS protocols refers to
merchandise that is either banned from importation or restricted with quotas. Only a few items
are subject to these restrictions, and these tend to be unprocessed agricultural items exported
14
ETLS Gap Analysis – Ghana ––December 2010
from other Member States and could have a positive impact on their respective economies if
allowed to be traded freely. Moreover, these items are often restricted for many months at a
time and treated inconsistently by customs officials.
Private and Public
Implementation
Sector
Responses
to
ETLS
Protocol
The graph below shows, side by side, the aggregated views of private sector and public sector on the
percentage implementation of the ETLS in each area: transport, free movement of goods and free
movement of persons. For transport, it is interesting to note that the private sector reports a higher
percentage of implementation of the ETLS Acts than the public sector.
Figure 1: Ghana: Public and Private Sector Reporting of %age of Implementation of ETLS Protocols on Transport,
Movement of Goods and Persons
Transport
80% of private sector respondents report that the transport protocols have been implemented in
Ghana. Respondents state that many documents are required and clearance times vary from several
hours to several days.
Movement of Goods
The graph above shows that the largest gaps exist with respect to the movement of goods which
suggests that Ghana’s implementation of the ETLS protocols is considerably slower in this category
compared with the others. The private sector reported customs’ limited application of duty-free
provisions and the use of seasonal restrictions are slowing down ETLS implementation.
Movement of Persons
Most respondents indicate that Ghana is implementing the visa-free movement of persons. There
have been some scattered reports of payment of fees in the absence of a national identity card or
valid travel document.
15
ETLS Gap Analysis – Ghana ––December 2010
As Ghana is one of the most transparent and progressive countries in the region, it is curious that the
private sector has commented on the lack of proper implementation of the protocols. One possibility
for this discrepancy is the higher level of private sector members informed about ETLS compared to
other countries.
Summary of Respondents’ Recommendations for Cross-border Trade
x
Whilst ECOWAS does not penalize countries that do not adhere to its protocols, one
recommendation was to offer incentives to countries that do implement the protocols.
x
Better dissemination of ECOWAS Acts. Most ministries do not know to whom, in ECOWAS, to
address concerns or questions. Many ministries cited a lack of communication about what
mandates are required within their relevant sectors.
x
Simplify ECOWAS Acts and help make them more applicable and relevant to the realities on
the ground.
2.2 Key recommendations for Ghana
Table 1: Key Recommendations for Ghana
Priority
1
2
Topic
Duty-Free Treatment
of ECOWAS
Originating Goods
Seasonal/Quota and
other Non-tariff
Barrier Restrictions
Action
By Whom
Trade Impact
Grant duty free access to goods from
ECOWAS Member States- expand
ETLS preferred trader program and use
properly.
Customs,
Ministry of
Finance
(MOF),
Ministry of
Agriculture
(MOA)
Increasing imports and exports
and reducing costs, reduction in
informal trade, increase in
competitiveness of those
operating formally, increase in
fiscal revenue by coordinating
ETLS registration with revenue
authorities
Removal of seasonal and all other
identified non-tariff barrier restrictions
per ECOWAS protocol.
Customs,
MOF, MOA,
MOTI
Increases imports and reduces
costs, increases incomes for
farmers and increases regional
food availability/security during
off-season.
Reduces opportunities for
unofficial fees.
16
ETLS Gap Analysis – Ghana ––December 2010
3 Transport
In Ghana, the research team gathered and analyzed information regarding the implementation of
ETLS protocols on transit and transport, which is presented below. First, a table of rules and
procedures on transport compares ECOWAS protocols with Ghanaian law on several critical issues.
Next, interview results are presented, in chart form with brief discussions of each issue, and also in a
table form that compares and contrasts the perception of ETLS implementation across the public
sector (both in Accra and at border posts) with the experience of private sector traders.
Finally, the top recommendations for improving implementation of the ETLS regarding transport
appear in a table at the end of this section.
3.1 Rules and Procedures on Transport
Table 2: Rules and Procedures on Transport
Subject
Temporary
Vehicle
Import Permit
ECOWAS
Ghana
Passenger vehicles imported for private or commercial use
enter without import duties and taxes, prohibitions or
restrictions. Such vehicles will be covered by a temporary
important import permit and subject to re-exportation.
(Convention A/P1/7/85, Chapter II, Article 2, sections 1 and
2)
Private vehicles registered in the territory of
a Member State may enter the territory of
another Member State up to 90 days upon
presentation of the proper documentation a) Valid Driving License
b) Matriculation Certification (Ownership
Card) or Log Book
c) Insurance Policy recognized by Member
States
d) International Customs Carnet recognized
within the Community
Section 47, PNDC Law 330
CEPS Guide p. 18-19 “Temporary
Importation of Vehicles”
Brown Card
Vehicle
Inspections
ECOWAS Brown Card is established, and shall be
recognized as valid proof of insurance within MS and at
borders.
(Convention A/P2/5/82, Article 4)
The minimum period for mechanical examination is fixed at
every three months for passenger vehicles and every six
months for vehicles transporting goods.(Convention
A/P2/5/82, Article 10)
Agreement
Certificate for
an ECOWAS
Road Transit
Vehicle
Vehicles undertaking Inter-State transportation shall possess
a bilingual Inter-State Transport Permit valid for one
year.(Convention A/P2/5/82 Regulating Inter-State Road )
Truck
Dimensions
Truck dimensions established for length, breadth and height12
(Convention a/P2/5/82, Chapter III Highway Code, Article 5)
Ghana State Insurance Company (SIC)
implements the Brown Card scheme
Motor Vehicles (Third Party Insurance) –
ECOWAS Brown Card Law, 1986, Articles
1 and 2
Vehicle inspection and sticker/certificate
valid for 6 months
(Road Traffic Act, 2004 Act 683)
Publicly available regulation could not be
found
12 The maximum dimensions allowed for the road vehicles shall be as follows: Length: Vehicles with two or three axles 11m;
articulated vehicles 15m (under special arrangement made for container vehicles); articulated carriage (vehicle + trailer 18m);
Road train 22m.
a. Breadth All vehicles 2.50m - 2.50m.
b. Height-All vehicles ..1.60m - 4m.
17
ETLS Gap Analysis – Ghana ––December 2010
Subject
ECOWAS
Ghana
Axle limit
11.5 tonnes
Axle load limited to 11.5 tons. The Inter-State Road Transport
Convention limiting Axle Load to the approved weight of 11.5
tons. (C/Res1/12/88, Section 5)
Agreement
Certificate for
an ECOWAS
Road Transit
Container
Agreement Certificate established regarding approval of
containers, including how it is to be displayed. (Convention
A/P2/5/82)
Container
seals
When merchandise is transported under Customs seal,
customs authorities in each Member State shall ensure that
the seals are intact (Convention A/P.4/5/82, ISRT, Section
5.1)
The gross weight posted for a 2 axle
transport truck is 12 tonnes
http://ghanaports.gov.gh/GHPA/axle_load13
Publicly available regulation could not be
found
New Procedures in GPHA Transit Area:
x Sealing of cargo by CEPS
x Attachment of SIC trade plate
GCNet website. Ghana’s New Transit
System, 4 Sept. 2006.
ECOWAS
ISRT log
book/ Carnet
TRIE
ISRT log book established (Convention A/P.4/5/82 ISRT
Article 16, Sections 1-3).
Publicly available regulation could not be
found
ISRT
Convention
Guarantee
(Bonds)
A guarantee mechanism (bond system) for Inter-State Road
Transit of Goods is established.
(Supplementary Convention A/P1/5/90, Articles 2 and 3).
Customs Code – Volume II 1984
Part 7 Transit (5.) Security (a) Amount of
bond assessed (b) Bond certificate.
ISRT or
ECOWAS
Single
Customs
Declaration
Form
A single ECOWAS customs declaration form is adopted
(C/REG.4/8/99)
CEPS Guide
Import Procedure:
A. i) Required documents:
iv. Import Declaration Form (IDF);
Purchase an IDF from the Ministry of Trade
and Industry & PSI or the under-listed.
Banks in Accra; ii. Submit completed IDF to
the appropriate Destination Inspection on
Company (DIC) depending on the country
of export of the goods; a) Submit
declaration electronically to Ghana
Customs Management System (GCMS)
through the Ghana Community Network
(GCNet) where the facility is available or b)
Purchase and complete Single
Administrative document (SAD) at the
station of import (usually overland) where
the GCNet facility is not available
13 According to Transport News of 8-21-09, http://www.otal.com/ghana/index.htm; the axle-load law has been updated to add
1.5T per axle due to congestion at the port and as agreed between Ghana, Burkina Faso and Togo. It was initially suspended
for one week, but no news on removal of suspension has been found. See Annex I for axle-load diagrams.
18
ETLS Gap Analysis – Ghana ––December 2010
3.2
Private and Public Sector Responses to Survey on ETLS Protocols
The majority of private sector respondents said that many documents and other formalities must be
produced in order to bring a vehicle or truck across the border. These documents include an
insurance Brown Card, proof of inspection (roadworthiness), an agreement certificate for an
ECOWAS road transit vehicle, an inter-state transport permit, and declaration form. In addition, where
appropriate (for example in a transit of goods situation), a carnet TRIE/ISRT logbook, ISRT
guarantee, container seal, and an agreement certificate for an ECOWAS road transit container are
also required.
The following graph, which uses simple averages, illustrates the varying perceptions of the private
and public sectors regarding the degree of implementation of the specific protocols as they
understand them based on the research team’s Gap Analysis questionnaires. These findings highlight
the differences in their responses to protocol implementation and convey the gap in implementation
based on the letter of the protocol versus published Ghanaian rules and procedures.
19
ETLS Gap Analysis – Ghana ––December 2010
Figure 2: Transport: Public and Private Sector Reporting on % of Implementation of ETLS Protocols
Generally, the public sector believes to a greater degree than the private sector that the transport
protocols are being implemented. For two different protocols/practices, ISRT Logbook and customs
declaration form, private sector respondents’ perception of protocol implementation exceeded that of
the public sector respondents.
20
ETLS Gap Analysis – Ghana ––December 2010
Below is a summary of interview results for each specific issue covered by the surveys as drawn from
the ETLS Acts:
Temporary Vehicle Import Permit
ECOWAS Protocol
Because of the proliferation of smuggled used vehicles in the region, ECOWAS prepared a policy on
the movement of private vehicles across borders. Owners or drivers of personal vehicles are
supposed to complete a temporary import permit to guarantee that the vehicle will leave the territory
within 90 days or pay a duty, and within 30 days instead of 90 days in cases of commercial use.
Interview Results
The public sector reported that the Temporary Vehicle Import Permit is needed and 73% of private
sector respondents confirmed that temporary vehicle import permits are necessary for vehicles
crossing the border. Most respondents cite Ghana Customs and border police as the relevant
authorities for approval, with formal and informal payments being charged. The process takes a short
time to complete. Most found the process to be consistent across all borders and received the
documentation from the government agency.
During meetings with Ghana Customs and the Chamber of Commerce, it was revealed that deposits
are sometimes charged for the issuance of a TVI, which is in contravention of ECOWAS provisions,
based on suspicion of the likelihood that the trader is smuggling goods.
Brown Card Insurance
ECOWAS Protocol
The ECOWAS Brown Card motor insurance scheme was established under the ECOWAS
Convention A/P2/5/82, Article 4. Notwithstanding the terms of the insurance policy under which it is
issued, the card shall provide all the guarantees required by the laws or regulations governing
compulsory motor vehicle insurance in the country in which the accident occurred.
Interview Results
The Brown Card document is required at every border crossing according to 100% of both the public
and private sector and this information is disseminated through the State Insurance Company (or any
other private insurance company). However, an interviewee recounted that he had been waiting
several years to get reimbursed after an accident in Nigeria. His first challenge was to obtain an
official police report, which took several months, and now he was waiting for the transfer of funds.
The Brown Card regime is implemented in Ghana, and was almost universally recognized as a
necessary cross-border document by the private sector respondents. The Police and other
government agencies are charged with verifying this document at the border, and official fees range
from 20-50 cedis. The application for the card takes 1 to 3 hours. According to the National Insurance
Commission (NIC), any duly registered insurance company can issue the Brown Card. Similar to other
countries in this study; the Brown Card system does not operate effectively according to private sector
participants that were interviewed. While the card is respected at all borders and functions effectively
as a document required for passage, insurance claims resulting from accidents outside the originating
country are hardly, if at all, paid.
Vehicle Inspection
ECOWAS protocol
The protocol states that vehicle roadworthiness inspections must occur every six months with the aim
of reducing road accidents and use of sub-standard vehicles that damage roads.
Interview Results
Although about 70% of public sector respondents claim that this protocol is being implemented and
enforced, about half of the respondents were split as to when the inspections take place. Some said
that the biannual vehicle inspection is enforced. Vehicle inspections are required every 6 months,
according to about 55% of the private sector respondents; with many others replying that annual
inspections are the norm. Documentation of these inspections is reviewed by representatives of the
21
ETLS Gap Analysis – Ghana ––December 2010
Department of Transportation, with official fees payable. The approval process can take up to several
hours.
Inter-state Transport and Container Permits
ECOWAS Protocol
The Agreement Certificate for an ECOWAS Road Transit Vehicle or Inter-state Transport Permit and
the Container Permit are documents prepared by ECOWAS for the approval of road vehicles and
containers. These documents are required to be displayed in the vehicle cabin and are renewed
annually.
Interview Results
All of the Ghanaian officials that were familiar with the protocol said that these permits are necessary,
but that they do not use the ECOWAS format. Road transit certificates and road transit permits work
on a national basis and information on these can be found through the relevant agency even though
the permit is not uniformly checked at all border crossings. Customs is responsible for their approval.
The documentation for each of these is made available through the government agencies.
Just over half of private sector respondents indicated that these documents were required at the
border. Formal fees are imposed, and the approval process can take up to several hours, though this
may represent the total delay for all vehicle permit-related documentary processing.
Vehicle Standards - Dimensions and Axle-Weight Load
ECOWAS Protocol
An ECOWAS 11.5-tonne per axle limit applies to the 6-axle trucks commonly used in inter-state
14
transit. ECOWAS also sets standards for the height, length and width of vehicles.
Interview Results
All private sector respondents agreed that axle-weight requirements are being implemented, and
78% agreed on height, width and length standards, which shows that vehicle requirements are
implemented in conformity with ECOWAS rules. Since June 2009, Ghana has tried to strictly enforce
a relatively complicated axle-weight limit based on the type of vehicle (similar to UEMOA). In August
of 2009, it was reported that the axle-load limit was relaxed due to congestion of trucks at the port.
15
The new axle-load limits were supposed to be in place by November 30, 2009.
Standards on vehicles: according to the public sector, rules governing vehicle dimensions and
weight limits were enforced uniformly, and per-axle weight limits were applied at the border but not at
the 11.5 tonne limit.
Container Seals
ECOWAS Protocol
ECOWAS implemented a protocol to seal all transit cargo in order to ensure that the cargo is not
diverted, smuggled, tampered with or hijacked.
Interview Results
The rules governing containers and seals and inspection are implemented according to 100% of
both the public and private sector respondents that answered the question. Transporters are charged
50 cedis per day for a GPS tracking device to obtain a cargo seal in Ghana.
ECOWAS ISRT Logbook or Carnet TRIE
ECOWAS Protocol
According to ECOWAS, transit goods must be transported with an Inter-State Road Transit Booklet
(also called the carnet TRIE/ISRT Logbook). Each Member State office must maintain an official
14 Convention A/P2/5/82—Regulating Inter-States Transportation between Member States, Chapter III - Highway Code, Article
5.
15 See both axle-load limit descriptions located in Annex I.
22
ETLS Gap Analysis – Ghana ––December 2010
register that lists, in chronological order, all transit operations with reference to the number of the
logbook. The ISRT Declaration Leaflets are to be presented in each Member State and customs need
only check that the cargo seal is intact.
Interview Results
The ISRT Logbook is in general use according to 82% of the private sector, but respondents said that
a national logbook was required at each border crossing, not only the first. Ghana has its own ISRT
Logbook and bond guarantee provided by the State Insurance Company (SIC), appointed by the
Government of Ghana. Truck drivers must pay for and wait to receive a new logbook in Ghana. It was
interesting that the public sector respondents answering the question were split on the use of the
logbook. According to the State Insurance Company, the transitor is not required to deposit any
amount as guarantee but rather pay a premium of 0.5% of the bond value as premium to SIC who
provides a guarantee to CEPS to cover the risk of diversion. SIC therefore pays the duties that are
lost to CEPS whenever there is a diversion of cargo meant for transit.
ISRT Guarantee or Surety Bond
ECOWAS Protocol
The Community Guarantee Mechanism for Inter-State Road Transit of Goods consists of a chain of
national bodies responsible for guaranteeing the payment of duties, taxes and other fees incurred in
the territories of the Member States crossed in an inter-state transit trip. Each guarantee provided by
the national institution or designated body corporate is valid for a single transit trip. Truckers purchase
a bond at the start of each trip (0.5% of the value of the goods) which covers the transit of goods from
the customs office of departure to the customs office of final destination, regardless of how many
community countries are entered. The bond money should be released upon arrival in the country of
destination.
Interview Results
Similarly, the ISRT guarantee does not operate as intended in the ETLS. Instead of a single process
that functions throughout the region, a truck driver must reapply and pay for a separate guarantee in
each Member State. About 80% of the private sector respondents said that they were required to
purchase the guarantee to cross the border. While 100% of the public sector respondents said the
guarantee was necessary.
Declaration Form
ECOWAS Protocol
The protocol prescribes that a single import declaration form be used among Member States for
consignments. In practice, Ghanaian customs has its own declaration form necessary for its GCNet
system (an electronic system for processing trade and customs documents) and also requires a large
number of other documents to clear consignments at border crossings.
Interview Results
Ironically, 86% of private sector respondents believe that this requirement is being implemented
compared to 46% of public sector respondents. These perceptions suggest that neither sector is fully
aware of this form and its intended application or they do not include the use of the electronic format
through GCNet as applicable to the survey question.
Utilization of ECOWAS Templates
ECOWAS Protocol
As part of the ETLS measures, standardized document formats were prepared by ECOWAS
including: the ISRT Logbook and Bond Guarantee, the Brown Card, Temporary Vehicle Import
Permits, and Container and Transport Permits.
Interview Results
Ghana does use the ECOWAS format for the Brown Card and ISRT Logbook. See Annex C for a
direct comparison of ECOWAS templates and Ghanaian issued forms.
23
ETLS Gap Analysis – Ghana ––December 2010
Transport Costs and Delays
Interview Results
Of the many fees associated with cross-border travel, few are as widely condemned as escort fees.
Ostensibly, these fees were introduced to cover the costs of an official vehicle escorting individual
trucks through the country in order to ensure that goods in transit from the port are not prematurely
off-loaded (without payment of duties) and diverted. Trucks crossing into Burkina Faso are charged
escort fees, although no physical escort is provided. The process has been described as a “legal
bribe”.
Formal fees apply to virtually all of these documents and processes, as do unofficial or informal fees,
though in the latter case, specific amounts were not often mentioned. The entire process takes from
several hours to several days to complete. The longer delays are often associated with waiting to
receive documentation or authorization, rather than time spent actually clearing the consignments at
border crossings. Longer delays also arise if the document collection process involves multiple visits
to different agencies, ranging from the Ministry of Transport, chamber of commerce, department of
motor vehicles, the state insurance bureau, guarantee office or authorized bank, and of course,
customs, the border police, and immigration. Documents are available from government agencies or
authorized outlets (e.g. Brown Card from SIC); however the availability of information on the
governing laws depends to some degree on the agency involved.
Knowledge of ECOWAS Acts Relating to Transport
Interview Results
Information on new laws was available to some shippers, who received updates from the Ghanaian
Shippers’ Council. Other transporters unions also provided similar updates and daily newspapers
were another source of information for the international trade community.
The public sector seems conversant with ETLS protocols in relation to transport as does the private
sector, with the exception of the protocols for vehicle and container permits and the single declaration
form.
24
ETLS Gap Analysis – Ghana ––December 2010
3.3 Implementation of ETLS Transport Protocols
The following table summarizes and compares responses by public officials in both central and border
posts, and also the private sector. The status of trade-related legislation is also added and solutions
are recommended. A picture emerges of where efforts should be focused and what solutions could
promote implementation of ETLS protocols.
Table 3: Implementation of ETLS Transport Protocols
Key: (red) 0-25% reporting implementation, (yellow) 26-74% reporting implementation, (green) 75% or
more reporting implementation
ETLS
Protocols
Promulgat
ed in local
law/
regulation
?
Reporte
d
at
Capital
Reported At
Border
Reported by
Private
Sector
Solutions/Action
Items
Additional Notes
Temporary
Vehicle
Import
Permit
Start process of using
ECOWAS template
None
Brown Card
Initiate auditing of scheme
None
Vehicle
Inspections
every 6
months
Publish frequency and
standards requirements.
Legislation requires
vehicle inspection every 6
months. Border officials
claim inspections done
once a year.
Agreement
Certificate
for an
ECOWAS
Road Transit
Vehicle
Start using ECOWAS
template, post notice at
borders, train officials for
reason and use of
document, put use into
regulation.
None
Truck
Dimensions
Publish standards
requirements, make part of
vehicle inspections.
None
Axle load
limit (11.5
tonnes)
Publish standards
requirements, make part of
vehicle inspections,
enforce at border, set up
system to assist private
sector to comply.
None
Containers Certificate of
Agreement
for an
ECOWAS
Road Transit
Container
Start using ECOWAS
template, post notice at
borders, train officials on
reason for and use of
document, put use of
document into regulation.
None.
Container
seals
If seal, no inspection
required and no escort
needed.
None
ECOWAS
ISRT log
book - Carnet
TRIE
Only issue new log book if
truck is originating at
customs post - not a
vehicle in transit. Public
posting of any rules
regulating transit
documentation
requirements.
Public officials at the
capital said the logbook is
required, while officials at
the Paga border said that
it was not.
25
ETLS Gap Analysis – Ghana ––December 2010
ISRT
Convention
Guarantee surety or
bond
Only issue new bond if
truck is originating at
customs post- not a
vehicle in transit.
Public officials at the
capital said the bond is
required, while officials at
the Paga border said that
it was not.
3.4 Recommendations for Transport
The top recommendations for the full implementation of ECOWAS transit and transportation acts in
Ghana are based on the interviews and tabled below in order of priority.
Table 4: Priority Recommendations on Transport
Priority
1
Topic
Action
By Whom
a) National Guarantor and customs
offices
b) ECOWAS monitoring and
imposing sanctions for improper
application
c) Trade Hub hotline for reporting
ISRT Bond Guarantee System
Road Harassment/Axle-load
limit/Vehicle Inspections
a) National governments spotcheck monthly the elimination of
illegal road stops and enforce biannual inspections.
b) Inspection stations also ensure
the vehicles are standard (before
loading) weight/height/length etc.
in addition to road-worthiness.
National transportation offices
3
ISRT Logbook
As the ECOWAS Single
Administrative Document is being
implemented and computerized,
enforce the one logbook per
transit operation and not require a
new book upon entry into each
MS. Publish issuance and use of
logbook.
a) National customs office
b) ECOWAS monitoring and
imposing sanctions for improper
application
c) Trade Hub hotline for reporting
4
Brown Card
Audit of issuing agents by
insurance regulators.
National insurance regulators - with
reports to ECOWAS
5
Non-tariff Barriers
Removal of NTBs such as
unnecessary escorts, road
harassment, and transit quota
agreements.
Ministry of Transport
2
Whilst the private sector’s number one complaint in relation to transit and transportation are the
informal road stops which have been monitored and documented by the Trade Hub’s Transport
Team, it is the bond system which is more costly to trade.
Impact of Addressing Priority Recommendations in Transportation
The recommendations listed above will provide significant benefits to support increased trade:
Enforcement of one bond payment per transit trip and requiring its timely release will benefit traders
by freeing up monies that can be used to increase staff pay, reinvest or expand business. Having to
pay a new bond at each border ties up traders’ cash flow, and it is widely stated that the bonds may
either not be released at all, or may take up to a year for release. The cumulative effect of this
retention is considerable when multiplied by the number of times a trader may transport goods to or
through neighboring countries.
Spot checking for unnecessary road stops and outfitting inspection stations to review vehicle weight
and standards will produce multiple benefits in the form of less damage to roads, fewer accidents
26
ETLS Gap Analysis – Ghana ––December 2010
caused by stops and sub-standard vehicles, and the reduction of transit costs in terms of both time
and expense.
The use of one logbook per transit operation will reduce transit operators’ time at the border (waiting
on and preparing a new logbook), and reduce transporters’ costs as they pay for and are issued a
new logbook at each border, which averages $20.
An audit of the Brown Card scheme operators and regulations to ensure that they pay within a
specified time frame will reduce the cost to the persons involved in accidents and timely
reimbursement of their loss (and the loss of others) will enable them to get back into the business of
transit and transport. In some instances, the private sector complained that payments were not
processed at all.
The removal of NTBs will reduce the unpredictability of trading costs, encouraging increased trade
and business expansion. NTBs such as transfer of cargo to national trucks and use of escorts
unnecessarily cost transport operators time and money when ECOWAS transit permits; logbooks and
container seals should be in use.
27
ETLS Gap Analysis – Ghana ––December 2010
4 Movement of Goods
The movement of goods throughout ECOWAS is one of the primary areas addressed by the ETLS
protocols. The ETLS provides guidance on issues such as duty-free goods, certificates of origin, nontariff barriers, and registration of companies for duty-free access of industrial goods.
In Ghana, the research team gathered and analyzed information regarding the implementation of
ETLS protocols on the movement of goods, which is presented below. First, a table compares
ECOWAS protocols with Ghanaian law on several critical issues. The table notes whether the
protocols are promulgated in Ghanaian law and whether they are easily accessible to the public,
either in hard copy or electronic form.
Next, interview results are presented, in chart form with brief discussions of each issue, and also in a
table form that compares and contrasts the perception of ETLS implementation across the public
sector (both in Accra and at border posts) with the experience of private sector traders.
Finally, the top recommendations for improving implementation of the ETLS regarding the movement
of goods appear in a table at the end of this section.
4.1 Rules and Procedures on Movement of Goods
Ghana, surprisingly, does not seem to have published much trade information regarding the
implementation of the duty-free movement of goods within ECOWAS.
Table 5: Chart of ECOWAS Text and Ghanaian Trade Regulations on Free Movement of Goods
Subject
ECOWAS
Ghana
0% duty rate for unprocessed products of
ECOWAS origin
Unprocessed
Goods
Duties eliminated on imports from within the community on
unprocessed goods and handicrafts (ECOWAS Treaty 1990:
Chapter II, Article 35, Article 36, Sections 2, 3)
Proof of origin is not required for agricultural and livestock
products as well as hand-made articles.
(A/P1/1/03, Article 10)
General Exemption from Payment of Duty
(5) Foodstuffs, including raw foodstuffs and gari
originating from West Africa;
(6) Fish
ECOWAS Preferential Rates, Part A and B –
Unprocessed products and traditional handicraft
products totally exempted from import Duty and
Taxes
The Harmonized System and Customs Tariff
Schedules, Ghana, 2007, p. 671-676
Non-tariff Barriers
(by definition of
Quota, Quantity or
Seasonal
Restrictions)
Customs duties and non-tariff barriers abolished; duties or other
charges on Community-originating imports eliminated;
quantitative restrictions on Community goods removed.
(ECOWAS Treaty 1990: Chapter II, Article 3; (2) d. (i); Article 35,
Article 41)
Definition of non-tariff barriers that must be eliminated.
(C/DEC.4/5/82 Art. 2: 1,2,3, 4; Section C)
Customs duties and non-tariff barriers abolished; duties or other
charges on Community-originating imports eliminated;
quantitative restrictions on Community goods removed.
Non-tariff Barriers
(by definition of
Administrative
barriers)
(ECOWAS Treaty 1990: Chapter II, Article 3; (2) d. (i); Article 35,
Article 41)
Definition of non-tariff barriers that must be eliminated.
(C/DEC.4/5/82 Art. 2: 1,2,3, 4; Section C)
28
ETLS Gap Analysis – Ghana ––December 2010
Subject
ECOWAS
Ghana
0% duty rate for Agreed Enterprises and Industrial
Products of ECOWAS Origin.
Processed Goods
Each Member State will authorize approval of communityoriginating industrial products to benefit under the intraECOWAS preferential trade regime.
Procedure for this approval process is established.
(Regulation C/Reg. 3/4/02, Articles 1 and Article 4 and Annex 1)
ECOWAS Preferential Rates, Part C – Agreed
Enterprises and Industrial Products for goods
admissible under the ECOWAS Trade
Liberalization Scheme.
The Harmonized System and Customs Tariff
Schedules, Ghana, 2007, p. 671-676.
30% Value Added
Goods that are not wholly produced in Member States but which
have received a value-added of at least 30% of the ex-factory
price of the finished goods within a Member State can claim that
State’s origin.
(Protocol A/P1/1/03; Article 4)
Transit Goods
Full and unrestricted freedom of transit through Member States
for goods proceeding to or from one Member State to another or
to and from a third country; and such transit shall not be subject
to any discrimination.
Goods entered for trans-shipment or in transit
through Ghana in accordance shall be exempt
from payment of import duties.
PNDC Law 330, 1993 Part II – Taxes and Duties,
Section 48
Duty free entry requires a certificate of origin.
*ECOWAS
Certificate of Origin
An ECOWAS Certificate of Origin is adopted
(Regulation C/REG.4/4/0).
*ECOWAS
Declaration Form
An ECOWAS Single Customs Declaration form (SCD) is
adopted.
(C/REG.4/8/99).
4.2
(GCNet)
Ghana uses a computerized single harmonized
customs declaration form (CEPS Guide).
Private and Public Sector Responses to Survey on ETLS Protocols
The graph below illustrates the public sector’s response next to the private sector’s, using simple
averages, regarding the implementation of ETLS protocols for movement of goods.
The high rate of disparity between officials on protocol implementation (in reality it should be 100%
one way or the other) is due to the answers given at the capital or central government versus the
answers given by officials at the border. The private sector perceives that the protocols are not being
implemented for almost all of the categories relating to movement of goods.
29
ETLS Gap Analysis – Ghana ––December 2010
Figure 3: Movement of Goods: Public and Private Sector Reporting on %age of Implementation of ETLS Protocols
Each of these categories is discussed below, comparing the ECOWAS protocol with the interview
findings. The ECOWAS Protocols and/or national rules are not reproduced anywhere in this report in
their entirety.
30
ETLS Gap Analysis – Ghana ––December 2010
Non-Tariff Barriers (NTBs): Quota/quantity, seasonal restrictions, standards
ECOWAS Protocol
According to the ECOWAS Treaty, there should be no quota, quantity, seasonal restrictions or non16
tariff barriers on the trade of goods of ECOWAS origin.
Interview Results
In interviews with the private sector, some seasonal restrictions on rice were identified, and the
existence of these restrictions was disputed by several other private sector respondents. This may
reflect a misunderstanding of the difference between an officially imposed restriction and the vagaries
of the market, but the interviewees did not elaborate on the matter. About 50% of the private sector
respondents reported that some quantity and quota restrictions remained, in particular on foodstuffs
and other staples bound for landlocked countries. In addition, other non-tariff barriers remain in place
along the various routes, including the division of cargo between trucks of destination nationalities, as
well as checkpoints and other mechanisms to extract charges.
Another problem arises from legitimate paperwork required at the border, which is currently not
accepted by authorities from a different jurisdiction. For example, on occasion, a phyto-sanitary
certificate granted by Mali will not be accepted at the Ghanaian border, where the border officials
demand a document issued by a Ghanaian authority.
Ghana’s customs authorities reported at the time of the interview (June 2009) that the country does
not apply quotas, quantity restrictions, non-tariff barriers, or seasonal restrictions. Yet, in an attempt to
control the smuggling of cheap textile imports from China, via the Aflao border in particular, Ghana
imposed a NTB on textile imports that sought to authorize textiles through one port of entry—
Takoradi.
Unprocessed Goods
ECOWAS Protocol
Unprocessed goods (agricultural products, livestock, and minerals) and traditional handcraft products
should circulate duty free between Member States and not be subject to any quantitative or
administrative restrictions under the ECOWAS Trade Liberalization Scheme.
Interview Results
Fewer than 50% of the private sector respondents said that unprocessed ECOWAS-originating goods
entered duty free. Border officials at Aflao were eager to point out that they actively applied the dutyfree provision for minerals and raw materials but were unable to answer the question about the duty
free movement of products obtained from hunting and fishing.
Industrial Goods
ECOWAS Protocol
For processed/industrial products, customs duties and taxes having equivalent effect were to be
gradually eliminated over a period of 10 years starting from January 1990. In order to benefit from the
scheme, the products must originate from a Member State; be approved by the ETLS Committee; and
be accompanied by a Certificate of Origin and an ECOWAS Export Declaration form.
Interview Results
Both public and private sector respondents claim that ECOWAS and national Certificates of Origin
were in use and required for all goods, including industrial goods, to receive ETLS duty-free
treatment. All public sector respondents claim that industrial goods of ECOWAS origin entered duty
free as compared to 60% for the private sector respondents. In addition, at least one private sector
respondent did not believe it was possible to ship anything, in particular used goods, across borders
without paying duties of some sort.
16 Article 41 – Quantitative Restrictions on Community Goods -1 - Except as may be provided for or permitted by this Treaty,
Member States undertake to relax gradually and to remove over a maximum period of four (4) years after the launching of the
trade liberalisation scheme referred to in Article 54, all the then existing quota, quantitative or like restrictions or prohibitions
which apply to the import into that State of goods originating in the other Member States and thereafter refrain from imposing
any further restrictions or prohibitions.
31
ETLS Gap Analysis – Ghana ––December 2010
Transit Goods
ECOWAS Protocol
According to the revised ECOWAS Treaty: Chapter VIII, Article 45, (2) Each Member State, in
accordance with international regulations and the ECOWAS ISRT Convention on Goods, shall grant
full and unrestricted freedom of transit through its territory for goods proceeding to or from one
Member State to another, or to and from a third country; and such transit shall not be subject to any
discrimination, quantitative restrictions, duties or other charges.
Interview Results
According to both public and private sector respondents, transit goods enter duty free, in accordance
with the ETLS protocols.
ETLS Registration (Preferred Trader Program)
ECOWAS Protocol
Approval of originating industrial products to benefit under the intra-ECOWAS preferential trade
regime shall be granted by an authority designated by each Member State on the recommendation of
a National Approvals Committee (NAC) established for the purpose. More simply stated, firms wishing
to export processed goods duty-free must go through a registration and approval process, and be
assigned a number that is used to identify them as an approved ETLS Trader on Certificates of Origin
and Customs Declaration Forms.
Interview Results
Most firms report knowledge of the registration of firms under ETLS, and many were registered.
Formal application fees are required. Private sector respondents reported that they face difficulties
even as ETLS registered entities. Examples cited were of ETLS-approved Togolese companies
seeking to export goods into Nigeria and Ghana. A foam manufacturing company interviewed said it is
required to pay high duties when exporting to Ghana; and Nigeria requires pharmaceutical companies
to pay duties at the fifth band of 35% of cost insurance and freight (CIF) value.
Public sector respondents claim that ETLS-approved companies enjoy some other benefits from their
status such as concessionary tax rates for imports even if a product is not ETLS approved. For
example, an ETLS-approved company which has another factory in Niamey may sometimes run out
of its principal raw material used in production. Although the input material is not an ETLS-approved
product, the approved company benefits from a 5% concessionary tax rate and the VAT of 15% is
also waived. A non ETLS-approved company would have to pay 10% duty on CIF value, plus 15%
VAT on the amount. However, an ETLS-approved company has to pre-notify the customs sector lead
at the border prior to arrival. Public officials explained that prior application to the sector lead
facilitates the process and reduces the processing time at the border.
Time and costs of cross-border trade
Interview Results
Formal fees are charged for various documentation involved in the shipment of goods, such as a
certificate of origin, and phyto-sanitary certificates. Such fees range from 10-20 cedis for a Certificate
of Origin and 250 cedis for a container seal. Only a small minority claimed that any of the other
processes or documents involved or carried official fees.
In Ghana, very few interviewees responded to the questions on specific time spent complying with the
necessary paperwork and border procedures. Of those responding, most said that each procedure
could be completed in one to five hours, with anecdotal stories describing two to four days at a border
crossing, for instance when a necessary official is absent, disagreements arise over paperwork, or
someone refuses to pay.
32
ETLS Gap Analysis – Ghana ––December 2010
ETLS Knowledge
Interview Results
Many of the private sector respondents rely on specialized shipping and transport companies for their
information and paperwork, and therefore do not concern themselves with the location of documents
or updates to the law. They are informed, if at all, through networks of expediters and trucking
companies along with assistance from the unions wherever possible.
In contrast to other countries, Ghanaian customs border officers seem knowledgeable and informed
on the ETLS protocols. There are areas where officials' knowledge was sketchy. For example, none
of the officers, was able to state categorically whether minerals are duty free, citing the fact that it is
not being imported/exported through their particular entry/exit point, and they therefore had no need
to know.
Although legislation is available and was obtained by the research team, it is clear that national
customs legislation is not readily accessible by the public. According to officials, the private sector can
learn about Ghana’s tariff rates through the CEPS website or through the hard-copy tariff code which
17
is available at the Customs headquarters in Accra.
ECOWAS Document Templates
As part of the ETLS measures, ECOWAS prepared standardized document formats including: a
Certificate of Origin; Customs Declaration Form and also a common customs and statistical
nomenclature.
Ghana uses the ECOWAS Certificate of Origin template and the HS 2007 nomenclature.
C for a direct comparison of ECOWAS templates and Ghanaian issued forms.
18
See Annex
4.3 Secondary Findings and Anecdotal Reports
Import Process
The Ghana Customs Excise and Preventive Service (CEPS) is responsible for customs clearance and
collecting customs and excise duties and VAT on imports. It maintains 69 customs stations. The
CEPS uses the fully computerized Ghana Customs Management System for recording and clearing
imports. Based on a computerized risk assessment system, goods are directed to a red, yellow, or
green channel. The red channel is for products classified as high risk goods (HRGs), for which special
19
clearing and control procedures apply. Importers of HRGs must register with the Ghana Standards
Board. All imported HRGs must be accompanied by a certificate of conformity, with reference to the
applicable technical regulation, issued by a laboratory preferably in the exporting country. The yellow
channel involves more intensive scrutiny of documents, with examination depending on the level of
discrepancies and risk factors detected in the documents or in scanner results, while the green
channel is for low risk products, which may be released without examination.
Ghana Customs stated that there are no special registration requirements for importers. Imports must
be accompanied by: the Original Bill of Lading or Airway Bill; an invoice attested by the exporter
(Customs Form C.61); a Packing List; an Import Declaration Form (IDF); a Final Classification and
Valuation Report (FCVR) issued by a destination inspection company; a Tax Clearance Certificate
17 http://www.ghanacustoms.gov.gh/
18 The Harmonized System or HS is a goods nomenclature that is developed and maintained by the World Customs
Organization (WCO), and is governed by the International Convention on the Harmonized Commodity Description and Coding
System. Over 190 countries and economies use the HS as a basis for their customs tariffs and for the collection of international
trade statistics.
19 High risk goods include: food products; pharmaceuticals; electrical appliances; electrical products; electrical cables;
electronic products; LPG cylinders and accessories; toys; chemical and allied products; building materials; used goods;
petroleum products; pyrotechnic products; motor vehicle batteries; alcoholic and non-alcoholic products; African textile prints;
arms and ammunitions; machetes; vehicle spare parts; and industrial machinery.
33
ETLS Gap Analysis – Ghana ––December 2010
(issued by the Internal Revenue Service); a Taxpayer’s Identification Number; and an import permit, if
20
appropriate.
The IDF can be purchased at the Ministry of Trade and Industry or various commercial banks against
a fee of 5 cedis and can be submitted electronically. The use of an approved destination inspection
company for completion of the FCVR, including price verification, is mandatory for all imports of
21
US$2,000 and above.
The fee for destination inspection is 1% of the CIF value of goods. Goods
may be stored, under customs’ control and subject to fees, in a public or private bonded warehouse
without any payment of import duties for up to two years. No import insurance is required.
All ECOWAS products/traders are referred to BIVAC, a certified inspection agency, which determines
the CIF value of the product, and the information is then transmitted to the border officials. About 50%
of consignments are subject to physical inspection; however, CEPS aims to reduce this share to 20%.
According to officials the customs clearance process usually takes between 30 minutes and four
hours, depending on the outcome of the risk assessment, if the required documentation is in order.
Post-clearance verification may be carried out by Customs at the importer's premises if considered
necessary.
Ghana uses a Single Administrative Document (SAD) declaration form. ETLS-approved companies
are identified by the code 401001 on the SAD to enjoy preferential or no tariffs.
22
At Aflao, valuation questions held up the import process. The declared values stated on an invoice
are often challenged at the border, which leads to lengthy delays for verification. For higher value
transactions valuations must be conducted in Accra. An option exists whereby transporters or
shippers can pay a very large deposit (representing the highest estimated deposit plus 50%) to a
customs authority, and continue with the shipment. Once the final duty is settled, the depositor can
reclaim the excess or pay the difference without penalty. In practice, the amounts in question are so
large, and the repayment of excess so uncertain that this process is only used as a matter of last
resort.
20 The certificate attests compliance by taxpayers with income tax obli gations. Since 2001, a fee of 1% of the CIF value is
payable on goods imported in commercial quantities that are not covered by a valid certificate.
21 Below this threshold, an abridged FCVR may be submitted. In addition, a "head load" option for land borders was introduced
in October 2007, waiving the destination inspection requirement for imports of single items and of goods in very small
quantities.
22 Border crossing between Ghana and Togo.
34
ETLS Gap Analysis – Ghana ––December 2010
4.4 Implementation of Free Movement of Goods
The following table compares the degree of implementation of the specific protocols as understood or
experienced by both the public and private sectors, highlighting the differences in their responses to
protocol implementation. A green dot means at least 75% of respondents reported that the protocol is
being implemented. A yellow dot means 26-74% made such a report, and a red dot means 0-25%
reported protocol implementation.
Table 6: Implementation of Free Movement of Goods
Key: (red) 0-25% reporting implementation, (yellow) 26-74% reporting implementation, (green) 75% or
more reporting implementation
ETLS
Protocol
Promulgated
in local law/
regulation?
Reported
at Capital
Reported
at
Border
Reported
by Private
Sector
Solutions / Action Items
Additional Notes
None
No quota
restrictions
Removal of restrictions unless
for health or safety reason.
Spot
check
customs
processing. Public posting of
any rules regulating
or
regarding NTBs.
No quantity
restrictions
Removal of restrictions unless
for health or safety reason.
Spot
check
customs
processing. Public posting of
any rules regulating
or
regarding NTBs.
Rice and other grains were
reported by private sector as
restricted due to scarcity and
harvest.
Removal of restrictions unless
for health or safety reason.
Spot
check
customs
processing.
None.
No
seasonal
restrictions
Removal of restrictions unless
for health or safety reason.
Spot
check
customs
processing.
Officials at the capital stated
that
some
seasonal
restrictions were in place to
protect local production.
Minerals
duty free
Proper training of officials,
ECOWAS duty added to HS
code on customs website.
Public posting of any rules
regulating ECOWAS trade in
minerals.
Public
officials
offered
conflicting answers to the
duty free treatment of
minerals.
Proper training of officials,
ECOWAS duty added to HS
code on customs website.
None
Proper training of officials,
ECOWAS duty added to HS
code on customs website.
None
Proper training of officials,
ECOWAS duty added to HS
code on customs website.
None
Removal of
all non-tariff
barriers
Vegetables
and fruits
and duty
free
.
Live
animals
duty free
Products
obtained
from live
animals
duty free
35
ETLS Gap Analysis – Ghana ––December 2010
Products
from
hunting,
game,
fishing,
seas, rivers
duty free
Spot
check
customs
processing for any extraction of
informal fees.
Public
officials
offered
conflicting answers to the
duty free treatment of game
and fish.
Handicrafts
of ECOWAS
origin duty
free
Spot
check
customs
processing for any extraction of
informal fees. Public posting of
any rules regulating ECOWAS
trade in handicrafts. Add to HS
list.
None
Used
articles
from
ECOWAS
duty free
Spot
check
customs
processing for any extraction of
informal fees. Public posting of
any rules regulating ECOWAS
trade in ECOWAS generated
used articles.
None
Scrap &
waste from
manufacturing in
ECOWAS
duty free
Spot
check
customs
processing for any extraction of
informal fees. Public posting of
any rules regulating ECOWAS
trade in scrap and waste.
None
Value
added of
30% duty
free
Spot
check
customs
processing for any extraction of
informal fees. Public posting of
any rules regulating ECOWAS
trade in goods with at least
30% value added.
All public officials said that
ETLS registration was
required for firms to receive
duty free treatment of 30%
value added goods.
Registration
of Firms
under ETLS
Preferred
Trader
Scheme
Enforce duty free access for
ETLS registered companies.
None
ECOWAS
certificate
of origin
Utilization
of
ECOWAS
template with scan-enabled bar
code to reduce forged
documents.
Transit
goods duty
free
Spot check customs
processing for any extraction of
informal fees.
36
None
None
ETLS Gap Analysis – Ghana ––December 2010
4.5 Recommendations on Movement of Goods
Based on the survey results, the Trade Hub evaluated the gaps identified and ranked them by the
effect they have on restricting or discouraging trade. The table below states the top recommendations
for addressing gaps in the free movement of goods:
Table 7: Priority Recommendations for Free Movement of Goods
Priority
Topic
Action
By Whom
1
Non-tariff Barriers
Removal and enforcement of removal of all nontariff barriers including issues such as reciprocity
of standards, quality certifications, fees, levies,
seasonal, quantity, and quota restrictions on
ECOWAS originating goods.
National customs eliminates NTBs and monitors
the enforcement of elimination. Trade Hub
hotline for reporting of NTBs to ECOWAS,
Member State and public.
2
Duty free access of
goods originating from
ECOWAS
Unprocessed goods of ECOWAS origin enter
Ghana duty free. Companies of processed
goods register to be part of ETLS and receive
duty free treatment. Proper training of officials
and GCNet customer service agents.
Ministry of Finance, Customs
3
Harmonization of goods
processing
documentation
ECOWAS to review requirements with MS,
revise as necessary, and MS implement
ECOWAS only SAD and border documentation
ECOWAS and Member State customs offices
Public Awareness
Post signs at all borders on good processing
procedures in both English and French, fees if
applicable, and documents necessary. Use
pictures and numbers for those who may not
read French or English. Update websites.
4
Broad dissemination of ECOWAS protocols to
public and private sector stakeholders and
training
National customs agency with donor assistance
a) National MOF and ECOWAS Integration
Offices
b) Trade Hub via website and associations
5
ETLS Preferred Trader
Program
a) Wide action to encourage registration
b) Enforcement of ETLS registered traders for
tariff free access
c) Find solution for small/micro traders
a) MS campaign – Trade Hub assist through
value chains
b) Member States and ECOWAS
c) Member States and ECOWAS through
dialogue with stakeholders
6
Value Added
Rules on Value Added need to be defined,
published and posted
MOF, Customs
Lack of harmonization wastes time and creates cost and confusion for regional operators.
Harmonization of goods-processing documents in the region is therefore a regional high priority. By
streamlining procedures and introducing reciprocity, transport operators will be able to carry one set of
documentation, reducing their time at each border waiting for new and/or duplicate paperwork such as
standards certificates or logbooks. Transporters will no longer be at the mercy of the next border
official, able to demand a document different from his neighbor, or which the transporter may not be
aware of and have to wait or pay.
Public awareness of the procedures, fees and expectations is critical in any effort to reduce corruption
and lack of adherence to rules by both the public and private sectors. In each country study, the
Trade Hub highlights the fees payable, as these are not harmonized and cumulatively can become
burdensome in addition to being arbitrarily applied because of the lack of formal notification and
general awareness. In all cases, those interviewed requested broader and more in-depth information
on the Acts ECOWAS has prepared and how they are supposed to be applied.
The ETLS registered trader program’s rationale was to afford the benefits to locally-owned firms.
ETLS registration, if implemented properly, can afford benefits to both the private and public sectors.
For the public sector, this registration should formalize border processes, and by strictly adhering to
providing free trade for ETLS-registered firms, create an opportunity to reduce informal trading (and
connect these firms via registration to national tax databases), offering a truly free trade “carrot”. For
37
ETLS Gap Analysis – Ghana ––December 2010
the private sector, the free trade benefits include increasing competition by lowering prices and
bringing informal traders into the formal arena to compete on a level playing field. This program can
even evolve into a ‘fast-track’ preferred trader program.
Finally, the benefits of adding the ECOWAS duty and any applicable fees to the HS nomenclature is a
precise, quick and easy way to inform the public of any duties or fees based on the specific product.
Annex G lists all possible documents required for Movement of Goods in Ghana.
While not officially part of the ECOWAS Acts, the fees assessed by various Ghanaian agencies are
many and high. Annex H sets out additional fees published by the Ghana Institute of Freight
Forwarders, some of which include:
1. 1% ad valorem processing fee charged by the DICs;
2. Processing fee of 1% ad valorem charged on non-dutiable goods imports;
3. Fee of 0.4% ad valorem plus VAT charged for GCNet services;
4. Export Development Levy of 0.5% ad valorem levy on imports of non-petrol imports in
commercial quantities;
5. National Health Import Levy (NHIL) of 2.5% ad valorem (plus VAT);
6. Ghana Shippers’ Council levy;
7. Social impact levy;
8. Statistical fee of 0.5% ad valorem on non-ECOWAS imports;
9. Transit infrastructure fee ($200 per consignment plus $6.5/day escort fee for goods in transit);
and
10. Vehicle exam fee of 1% ad valorem.
According to the WTO’s GATT Article VIII, all fees and charges other than import and export duties
and other charges within GATT Article III imposed in connection with importation or exportation are
limited to the approximate cost of the services rendered. Fees cannot be used as indirect protection
for domestic products or as a tax on imports or exports for fiscal purposes. Fees and other charges
act as trade barriers and can diminish the impact of tariff reductions.
These fees are considered non-tariff barriers. Unreasonable fees increase costs for traders and
discourage international trade and, thus, economic growth. As discussed at some of the meetings and
at the stakeholders’ forum, traders consider Ghana’s fees to be particularly high and are likely to
influence traders to use neighboring ports rather than Ghana’s ports. The international community is
moving towards the elimination of fees as much as possible and, when fees are necessary, to ensure
that they do not exceed the cost of the services performed.
Ghana imposes several fees of a type that would not be appropriate under the WTO rules, in that
these fees are applied on an ad valorem basis, and they are not related to the specific transaction in
question. These include: the 0.5% ad valorem ECOWAS fee; the Export Development Levy (0.5% ad
valorem on all non-petroleum products imported in commercial quantities); the 2.5% ad valorem
National Health Insurance Levy (NHIL) and a network charge for NHIL; and a levy for the Ghana
Shippers’ Council. The ECOWAS fee is imposed on non-ECOWAS goods for the benefit of ECOWAS
goods; the Export Development Levy is charged against imports for the benefit of exports; the NHIL is
a fee imposed on imports to fund a health initiative not directly related to imports; and the Ghana
Shippers’ Council levy is imposed on imports for a fund used for the benefit of both imports and
exports.
38
ETLS Gap Analysis – Ghana ––December 2010
5 Movement of Persons
ETLS addresses movement of persons within ECOWAS. Ending restrictions on the migration of labor
and capital is one of the four formal steps towards creating a customs union. On a practical level,
people travel or move in order to gain economic benefit. The free movement of persons is also
important since unnecessary immigration paperwork and illicit payments add costs and delays to the
process of moving goods across borders. The ETLS provides guidance on issues such as visa-free
travel, harmonized residence cards, passports and travel certificates as well as the right of residence
and establishment.
In Ghana the research team gathered and analyzed information regarding the implementation of
ETLS protocols on movement of persons, which is presented below. First, a table of legislation
compares ECOWAS protocols with Ghanaian law on several critical issues. The table notes whether
Ghanaian laws are compliant and whether they are easily accessible by the public, either in hard copy
or electronic form.
Next, interview results are presented, in chart form with brief discussions of each issue, and also in a
table form that compares and contrasts the perception of ETLS implementation across the public
sector (both in Accra and at border posts) with the experience of private sector traders.
Finally, the top recommendations for improving implementation of the ETLS regarding movement of
persons appear in a table at the end of this section.
5.1 Rules and Procedures on Movement of Persons
The protocol on Free Movement of Persons signed by the Authority of Heads of State in 1979 created
the right of residence and establishment. According to the protocols, all ECOWAS citizens may enter
another Member State without a visa and reside in any Member State for up to 90 days; the only
requirement is a valid travel document and international vaccination certificate.
Under A/P1/5/79 Protocol Relating to Free Movement of Persons, Residence and Establishment, “A
valid travel document means a passport or any other valid travel document establishing the identity of
the holder with his photograph, issued by or on behalf of the Member State of which he is a citizen
and on which endorsement by immigration and emigration authorities may be made. A valid travel
document shall also include a laissez-passer issued by the Community to its officials.”
The ETLS protocols do not prescribe fees except for the free issuance of the immigration/emigration
and embarkation and disembarkation forms. The ECOWAS Acts do prescribe the format of
documents Member States are to use.
Table 8: Rules and Procedures on Free Movement of Persons
Subject
Visa
ECOWAS
Ghana
Visa-free travel
ECOWAS citizens entry without visas Immigration
Regulation 2001
(Resolution A/Res 2/11/84 Free Movement of
Persons)
(Legislation Instrument 1691),Regulation 3.
Residence Card established for ECOWAS
Member States
*Residence Card
Description and format of Residence Card
(Decision A/Dec.2/5/90: Article 1, 2)
39
Legal entrants may apply and be issued a residence
permit.
Immigration Act 2000, 3(1)
ETLS Gap Analysis – Ghana ––December 2010
Subject
ECOWAS
Ghana
Convinced of need to adopt a harmonized
travel document other than national passport.
*Travel Certificate/Passport
(Decision A/DEC.2/7/85 Establishment of
ECOWAS Travel Certificate).
*Immigration/
Emigration and Embarkation/
Disembarkation Forms
5.2
Harmonized Immigration and Emigration
Forms are provided free of charge Decision
C/DEC.3/12/92, Art. 1 and Art. 2
Passport or other form of national identification must
be in the possession of persons entering the country,
ready for inspection upon request from the proper
authorities Immigration Regulation 2001.
(Legislation Instrument 1691)
Embarkation and Disembarkation forms are used for
arrival and departure from Ghana.
Immigration Act 2000, Section 2 (1).
Private and Public Sector Responses to Survey on ETLS Protocols
The graph below, using simple averages, illustrates the percentage of public and private sector
respondents’ answers on their perception of the implementation of the ETLS protocols for the free
movement of persons on visa-free entrance. They are almost in complete agreement that visa-free
travel is the norm in Ghana.
Figure 6: Movement of Persons: Public and Private Sector Responses on %age of Implementation of
ETLS Protocols
40
ETLS Gap Analysis – Ghana ––December 2010
Visa
ECOWAS Protocol
The protocol calls for visa-free travel involving ECOWAS citizens in the region.
Interview Results
Ghana reports that visas are not required for ECOWAS citizens to enter the country and this is
applied uniformly at border posts throughout the country.
According to 86% of the private sector interviewed, a visa is not required but in certain instances,
unofficial fees were demanded for cross border travel, regardless of document produced. The process
is not, however, consistent across the various borders, with some crossings demanding additional
payments or paperwork for processing, while others process fairly routinely.
Residence Card
ECOWAS Protocol
According to ECOWAS, Residence Cards are only required for stays longer than 90 days. These are
issued upon request for those who meet the criteria (work permit, adequate funds, etc). Residence
permits are needed to work or live in Ghana; once obtained they are valid for 4 years for an initial
request, and up to 8 years subsequently. Qualification for indefinite residence is subject to seven
subjective and qualitative conditions as outlined in the Immigration Act of 2000.
Interview Results
Only a very small minority of the private sector said that Residence Cards were required to cross the
border (8%).
Travel Certificate/ECOWAS Passport
ECOWAS Protocol
The Authority of the Heads of State and Government established a Travel Certificate for ECOWAS
Member States in 1985 to facilitate and simplify the formalities for cross-border movement. ECOWAS
citizens holding an ECOWAS Travel Certificate or passport are exempt from filling out immigration
and emigration forms.
Interview Results
According to Ghanaian immigration officials, travel certificates or passports are required as are
immigration or emigration forms. This information is made available through the immigration agency,
the immigration website and a pamphlet (see Annex E). These documents are inspected at the border
in each case.
According to Ghana Immigration Services, the Carte d’Identité or Identity Card from neighboring
Francophone countries are not accepted because they are not endorsable. ECOWAS Travel
Certificate, passport or any other endorsable identity document with a picture will get an ECOWAS
citizen through. In the absence of an endorsable identity document, an ECOWAS citizen has to pay a
fine to cross the border. No one is refused entry. Border residents are monitored separately according
to Ghana Immigration Service and do not need documents to cross.
Ghanaian officials at the time of the interview (May 2009), said they do not use the ECOWAS
passport for anyone other than public officials. However, as at March 2010, Ghanaian Immigration
Services has adopted a new passport, which meets international biometric standards, to replace the
old national passport. The official application fee for the new biometric Passport is 50 cedis, while the
old national passport will no longer be issued.
Private sector respondents highlighted that the situation was particularly troublesome at the
Ghana/Burkina Faso border, where a passport was arbitrarily required and Burkinabe travelers were
generally unprepared to provide a passport. Sixty percent of the private sector said they were
required to have a passport or travel certificate to cross the Ghanaian border.
41
ETLS Gap Analysis – Ghana ––December 2010
The private sector said that the unofficial fee at the border of entry was approximately CFA 500. The
official fees are published in the pamphlet as shown in Annex F and state a fee of 50 cedis for a
Residence Permit issued to ECOWAS Nationals; and from the Ghana Immigration website, the fee for
the old national passport was 10 cedis.
Immigration/Emigration and Embarkation and Disembarkation Forms
Interview Results
The Ghanaian central immigration office said that embarkation and disembarkation forms are required
at airports and immigration/emigration forms are needed at all borders. The Ghana Immigration Act of
2000 only mentions “complete prescribed forms” and does not specify who must complete them.
About 40% of the private sector said that they must complete an immigration/emigration form.
ECOWAS Document Templates
Interview Results
As at the time of the interview, Ghana was not using the ECOWAS templates for the free movement
of persons, but specifically issued a national passport, national residence cards, and entry forms.
See Annex C for a direct comparison of ECOWAS templates and Ghanaian-issued passport and
immigration forms.
Issuing an ECOWAS passport to ECOWAS citizens as they replace or renew travel documents will
start the process of individual travel documentation harmonization. It will also eliminate arbitrary fees
for ECOWAS citizens’ cross-border travel.
Time and cost of cross-border immigration
Interview Results
Private sector respondents claimed some fees were charged on an arbitrary basis and the fees stated
were 1.5 cedis and CFA 1,000 for ECOWAS residents from neighboring Francophone countries. All
respondents noted that it took a few minutes to move through immigration at the border.
5.3 Secondary Findings and Anecdotal Reports
Documents required for movement of persons from the ECOWAS region into Ghana:
x
x
x
National Passport or ECOWAS Passport or ECOWAS Travel Certificate or some other form of
endorsable document with photo
Completion of Immigration/Emigration at borders or if by plane Embarkation and Disembarkation
Forms.
A work permit is necessary to work in Ghana and a residence permit is necessary to work and for
a stay in Ghana.
42
ETLS Gap Analysis – Ghana ––December 2010
5.4 Implementation of Free Movement of Persons
The following table compares the degree of implementation of the specific protocols as understood or
experienced by both the public and private sectors, highlighting the differences in their responses to
protocol implementation. A green dot means that at least 75% of respondents reported that the
protocol is being implemented. A yellow dot means that 26-74% made such a report, and a red dot
means that 0-25% reported protocol implementation.
Table 9: Implementation of Free Movement of Persons
Key: (red) 0-25% reporting implementation, (yellow) 26-74% reporting implementation, (green) 75% or more
reporting implementation
Promulgated
in local law/
regulation?
ETLS
Protocol
Reported
in Capital
Reported
at Border
Reported
by Private
Sector
Solutions/Action
Items
Additional Notes
No Visa
Required
Some discrepancy - spot
checks of immigration
procedures at the border
to enforce.
None
Residence
Card required
after 90-day
stay, and can
be used as
travel
document
Some discrepancy - spot
checks of immigration
procedures at the border
to enforce.
Passport
The issuance of ECOWAS
Passports and Travel
Certificates by Ghana.
None
Immigration/
Emigration
Forms
None
None
None
5.5 Recommendations for Movement of Persons
Based on the survey results, the Trade Hub team evaluated the gaps identified and ranked them by
the effect they have on restricting or discouraging trade. To reduce the arbitrary nature of document
requirements and illicit payment requests and to facilitate the unencumbered movement of persons,
the following recommendations are made:
Table 10: Priority Recommendations for Free Movement of Persons
Priority
Topic
Action
By Whom
Visa and cost free
movement of persons
Spot check the collection of informal
payments by immigration
a) National Immigration Headquarters
b) ECOWAS Free Movement of Persons
Department
c) Trade Hub hotline
2
Public Awareness
Post signs at all borders on immigration
procedures in both English and French,
fees if applicable, and documents
necessary. Use pictures and numbers for
those who may not read French or English.
National immigration offices
3
ECOWAS Passport/
Travel Certificate
Start to issue ECOWAS-formatted
documents as residents apply for new or
renewed passport or travel documents
National Immigration offices
1
43
ETLS Gap Analysis – Ghana ––December 2010
6 Conclusions
The Ghana Gap Analysis study revealed that incomplete or inconsistent implementation of the ETLS
protocols, especially those pertaining to the free movement of goods, has a host of negative effects
within Ghana, including increasing the costs and unpredictability of trade, and discouraging business
expansion and investment. Because the ETLS is not being fully implemented throughout the region,
private sector firms are paying higher costs on both agricultural and industrial goods and shipments
both in and out of Ghana. These costs stifle the integration of regional value chains and generally
reduce the competitiveness of West African exports to global markets. For the country to reap the
benefits of the regional free trade area (including increased employment, higher tax revenues, and
increased foreign direct investment) the issues identified in this study must be addressed.
Legislation
The Gap Analysis revealed that while overall knowledge of the ETLS protocols is fairly widespread,
clarifications are needed by both the private and public sector persons interviewed.
Ghana ranks within the top three ECOWAS Member States in terms of access to rules and
regulations on-line, but even so, not all the necessary information is available. None of the
information could be obtained at the land border posts. Border points could serve the public better by
publicizing what, which and how processes or agencies are to be addressed at the borders for the
various categories of vehicles, goods and persons.
The ETLS protocols on transport have, perhaps the most serious impact on transport costs: The ISRT
Logbook and Bond Guarantees have a visible, identifiable financial impact on cross-border transit and
trade. Eliminating the bond at every border for transit trade would be a significant step towards
reducing formal costs of trade.
Many non-tariff barriers apply to the transportation of goods, but, with the exception of the escort fees,
they do not seem to be adding significant costs. A plurality of taxes and informal payments by border
countries also adds to costs. Removal of these taxes would take strong political will and the
expansion of Ghana’s integrity program among Customs and border police.
Implementation
Survey results in two areas (transport and movement of goods) indicate inconsistent implementation
of the ETLS in Ghana. While some protocols are reported as fully implemented by both the public and
private sector, the majority are not. Especially troubling are protocols reported as fully implemented by
the public sector, while the private sector experiences arbitrary procedures, non-tariff barriers and
demands for informal payments, especially regarding the movement of goods.
Recommendations
The recommendations made by this study emphasize robust and complete implementation of the
protocols currently being applied inconsistently. Public awareness is also emphasized, since many
problems arise when private sector members are not aware of their rights under the ETLS. The
recommendations call on government agencies (such as the Ministry of Transport and Customs) as
well as ECOWAS, the Trade Hub and other donors to collaborate on solutions that will allow the
ECOWAS free trade area to function for the benefit of all.
44
ETLS Gap Analysis – Ghana ––December 2010
7 Annexes
Annex A: Documents for Import and Export in Ghana
Import documents Necessary
Annual or per
border crossing trip
Form C. 59
Certificate of Origin
Bill of Lading
Attested Invoice (C.61)
Per trip
Per trip
Per trip
Per trip
Import Declaration form (IDF)
Per trip
Import Permits
Tax Clearance Certificate (TCC)
Tax Identification Number
certificate (TIN) or Shippers’
Council Card
Packing List
Annual
Annual
Final Classification and Valuation
Report (FCVR)
Single Administrative Document
(SAD)
Certificates of Title, Certificates of
Retail, Bill of Sales
Driving License
Vehicle Insurance Policy
International Customs Carnet
Matriculation Certification
(Ownership card) or Logbook
Re-importation Certificate
Phytosanitary Certificate
Veterinary Certificate
Pro forma invoice
Letter of credit
Brown Card
Passport
Vehicle Road Worthiness
Certificate
Transit declaration
Bank of Ghana form AI
Pre-shipment Inspection
Certificate (PSI)
Use
Source
Temp import
Ministry of Trade
Used in place of electronic
declaration where GCNET is
unavailable
See below
IRS
Annual
Per trip
Per trip
Destination
Inspection
Company (DIC)
Per trip
Import station
Per trip
Temp import of vehicles
Annual
Annual
Per trip
Inspections
Temp import of vehicles
Annual
Temp import of vehicles
Per trip
Per trip
Per trip
Per trip
Per trip
Annual
Annual
Vehicle inspections
Third party insurance
Immigration etc
Annual
Per trip
Per trip
Per trip
45
Usually
vehicle
in
the
ETLS Gap Analysis – Ghana ––December 2010
Export Documents
Bank of Ghana Exchange Control
Form A2
Electronic declaration form or SAD
Annual or per border
crossing trip
Use
Source
Per trip
Per trip
Export Declaration Form
In
absence
GCNet/GCMS
Certificate of Origin
Per trip
VAT and NHIL Invoice
Per trip
Waybill
Per trip
Inspection Certificates (Quality
Export Certificate) e.g plywood
inspection certificate
Export Permit
Per trip
ISRT Bond
Per trip
of
Annual
Relevant Permits/Certificates:
Some relevant permits or certificates, which may be required to accompany certain commodities,
include:
x
x
x
x
x
x
x
x
x
x
x
x
x
x
Cocoa Beans – Fumigation and Quality Assurance by Control Division of Ghana Cocoa Board
(COCOBOD)
Sawn Lumber – Permit by Forestry Commission (TIDD)
Manufactured/Processed Goods – Ghana Standards Board Certificate
Fresh/Processed Fish – Ghana Standards Board Quality Certificate
Coffee, Shea-nuts and Cashew nuts – COCOBOD Quality Assurance Certificate
Rock and Rock samples – Geological Survey Department Certificate
Chemicals – Certificate from EPA
Pharmaceuticals – MoH & FDB
Antique – Museum & Monuments Board permit
Timber and Wood products – Forestry Commission permit (TIDD)
Human remains – Certificate from Births and Deaths
Game & Wildlife certificate
Plant quarantine certificate
Food/Agricultural Produce
46
ETLS Gap Analysis – Ghana ––December 2010
Import Procedure
47
ETLS Gap Analysis – Ghana ––December 2010
Import Taxes and Fees
48
ETLS Gap Analysis – Ghana ––December 2010
Duty Exemption for Agricultural Goods
49
ETLS Gap Analysis – Ghana ––December 2010
Temporary Importation of Vehicles
50
ETLS Gap Analysis – Ghana ––December 2010
Commissioner’s Note on Temporary Importation
51
ETLS Gap Analysis – Ghana ––December 2010
52
ETLS Gap Analysis – Ghana ––December 2010
Vehicle Importation
53
ETLS Gap Analysis – Ghana ––December 2010
54
ETLS Gap Analysis – Ghana ––December 2010
55
ETLS Gap Analysis – Ghana ––December 2010
Annex B: Ghana Trade Regulations Catalog
FREE MOVEMENT OF PERSONS
ETLS Agreement
Visa
Residence
Permits
Travel
Certificate/
Passport
Ghana law
Conditions for Entry Into Ghana
Regulation 2 - Persons to Produce Passport
(1) A person
(a) entering or leaving Ghana; or
(b) applying for permission or renewal of permission to be
or remain in Ghana
shall produce that person's passport to the immigration
officer for inspection and stamping where necessary.
(2) A foreign national shall at any time when so requested
by an immigration officer of the rank of Inspector or above,
produce that national's passport for inspection.
Regulation 3 - Visa and Entry Permits
(1) A foreign national, except one from an ECOWAS
country, entering Ghana shall have stamped or affixed in
that national's passport a visa valid from the date on which
the foreign national enters Ghana.
Residence permits
13. (1) A person who has been lawfully admitted entry into
Ghana, may upon an application to the Director in the
prescribed manner, be issued with a residence permit.
(2) The Director may grant residence permit for up to a
period not exceeding eight years, except that, a residence
permit shall not be for more than four years in the first
instance
Travel Certificate not applicable in Ghana
Immigration Regulation 2001. Regulation 2 - Persons to
Produce Passport
(1) A person
(a) entering or leaving Ghana; or
(b) applying for permission or renewal of permission to be
or remain in Ghana
shall produce that person's passport to the immigration
officer for inspection and stamping where necessary.
(2) A foreign national shall at any time when so requested
by an immigration officer of the rank of Inspector or above,
produce that national's passport for inspection.
56
Source
Form
The
Immigration
Regulations,
2001 (LI 1691)
Passport
Immigrant
Act, 2000 (Act
573)
Residence
Permit
N/A
The
Immigration
Regulations
2001
National or
ECOWAS
Passport
ETLS Gap Analysis – Ghana ––December 2010
Immigration/
Emigration Form
Regulation 1 - Condition of Entry
(2) Form Ai [sic] in the Schedule (Disembarkation) shall be
used for the purposes of section 2 (1) of the Act.
Regulation 20 - Forms to be Completed on Leaving
Form S in the Schedule shall be used for the purpose of
section 10(2) of the Act which provides for the examination
of a person appearing before the immigration officer and
the completion of a prescribed form by that person.
Section 10 - Appearance Before Immigration Officer of
Person Leaving Ghana.
(1) A person leaving Ghana shall appear before an
immigration officer at the immigration post at any of the
approved places of departure.
(2) The immigration officer may examine a person who
appears before him and shall ask that person to complete a
form as may be prescribed.
(3) The immigration officer may dispense with personal
attendance of any person leaving Ghana if he is satisfied
by documentary or other evidence of the person’s identity
and his right to leave Ghana.
Section 12 - Conditions of Departure.
Subject to this Act where an immigration officer is satisfied
that a person leaving Ghana:
(a) is not a wanted person;
(b) is in possession of a valid travel document;
(c) has a valid visa to enter the country of destination; and
(d) is not in arrears of payment of fees or penalty to the
Director, the officer may permit that person to leave Ghana
on completing the prescribed form and endorse his
passport or travel document.
57
The
Immigration
Regulations
2001 (LI
1691).
Immigrant
Act, 2000 (Act
573)
Forms as
provided by
Immigration
ETLS Gap Analysis – Ghana ––December 2010
TRANSPORT
ETLS
agreement
Ghana Law
Temporary
vehicle
import
CEPS Guide
i) Private vehicles
A private vehicle registered in the territory of a
Member State may enter the territory of another
Member State and remain there for a period not
exceeding ninety days, upon presentation of the
following documents to the competent authority of the
Member State:
a) Valid Driving License
b) Matriculation Certification (Ownership Card) or Log
Book
c) Insurance Policy recognized by Member States
d) International Customs Carnet recognized within the
Community
see Customs Code – Volume II/Part 6 (1984) (B)
Instruction for Temporary Vehicle Import
Brown Card
Ghana State Insurance Commission (SIC) implements the
Brown Card scheme
Inspection
Road Traffic Act, 2004 ( Act 683)
Issue of road use certificate/sticker
95. 1) The Licensing Authority shall upon payment of
the prescribed fee, issue to the applicant a certificate
in the form of a sticker for the motor vehicle.
2) The sticker shall be carried on the front windscreen
of the motor vehicle so as to be readily identified by a
police officer or the Licensing Authority.
3) The road use certificate shall remain valid for six
months in the case of commercial vehicles and twelve
months in the case of private motor vehicles from the
date of issue and shall then expire.
Agreement
certificate
for an
ECOWAS
road transit
vehicle/
Interstate
road
transport
permit
Publicly available regulation could not be found
58
Source
Form
Customs Excise and
Preventive Service
(CEPS) Ghana Hard Copy
Document
C.B. 15
Motor Vehicles (Third
Party Insurance) –
ECOWAS Brown Card
Law, 1986, Articles 1
and 2
Brown
Card
Ministry of Roads
and Transport - Hard
Copy Document
ETLS Gap Analysis – Ghana ––December 2010
Length
11m/articulated vehicles
for
containers
15m/
articulated
carriage or
truck
w/trailer
18m/breadth
Publicly available regulation could not be found
http://ghanaports.gov.gh/GHPA/axle_load
Categories
of vehicles
axle configuration
Axle
type
Single
vehicle
Single
vehicle
Front: 6 tons
Rear: 12 tons
Front: 6 tons
Mid: 10.5 tons
Rear: 10.5 tons
Front: 5.5 tons
Mid 1: 5.5 tons
Mid 2: 10.5 tons
Rear: 10.5 tons
Front: 6 tons
Mid: 12 tons
Rear: 12 tons
Front: 6 tons
Mid 1: 12 tons
Mid 2: 10 tons
Rear: 10 tons
Front: 6 tons
Mid 1: 11.5 tons
Mid 2: 8.5 tons
Mid 3: 8.5 tons
Rear: 8.5 tons
Front: 6 tons
Mid 1: 10 tons
Mid 2: 10 tons
Mid 3: 10 tons
Rear: 10 tons
Front: 6 tons
Mid 1: 10 tons
Mid 2: 10 tons
Mid 3: 8.5 tons
Mid 4: 8.5 tons
Rear: 8.5 tons
Front: 6 tons
Mid 1: 10 tons
Mid 2:10 tons
Mid 3: 8 tons
Mid 4: 8 tons
Mid 5: 8 tons
Rear: 8 tons
2 axle
1.2
3 axle
Single
vehicle
Articulated
vehicle
Articulated
vehicle
Axle limit
11.5 tons
23
Articulated
vehicle
Articulated
vehicle
Articulated
vehicle
Articulated
vehicle
Max
Gross
Weight
18
27
4 axle
1.1.22
32
3 axle
1.2-2
30
4 axle
1.2-22
30
5 axle
1.2-222
43
5 axle
1.22-22
46
6 axle
1.22222
51
7 axle
1.222222
58
Ghana Ports and
Harbors website
23 According to Transport News of 8-21-09, http://www.otal.com/ghana/index.htm; the axle load law has been updated to add 1.5T per axle due to
congestion at the port and as agreed between Ghana, Burkina Faso and Togo. It was initially suspended for one week, but no news on removal
of suspension has been found.
59
ETLS Gap Analysis – Ghana ––December 2010
Containers certificate of
agreement
for an
ECOWAS
road transit
container
Publicly available regulation could not be found
Container
seals
Ghana’s New Transit System, 4 Sept. 2006:
New Procedures in GPHA Transit Area:
- Vehicles leave port to Transit Area under escort
- Sub-consignment registration into system
- Sealing of cargo by CEPS
- Attachment of SIC trade plate
ECOWAS
ISRT log
book Carnet TRIE
Publicly available regulation could not be found
ISRT
convention
guarantee surety or
bond –single
or multiple
transit
Customs Code – Volume II 1984
Part 7 Transit (5.) Security
(a) Amount of bond assessed
(b) Bond certificate
GCNet
www.ghanatrade
Net.com
Customs Code Hard Copy
Document
60
ETLS Gap Analysis – Ghana ––December 2010
Declaration
Forms
CEPS Guide
Import Procedure:
A. i Required documents: Original bill of Lading/Airway
Bill
ii. Attested Invoice (Customs Form # C.61)
iii. Packing List
iv. Import Declaration Form (IDF)
v. Final Classification and Valuation Report (FCVR)
vi. Tax Clearance Certificate (issued by the Internal
Revenue Service)
vii. Taxpayers Identification Number (TIN)
viii. Permits and Licenses as appropriate (See Import
Restrictions)
B. Procedure:
i. Purchase an IDF from the Ministry of Trade and
Industry & PSI or the under listed Banks in Accra
ii. Submit completed IDF together with Bill of Lading or
Airway Bill, Invoice and Packing List to the appropriate
Destination Inspection on Company (DIC) depending
on the country of export of the goods
iii. Obtain FCVR from DIC
iv. a) Submit declaration electronically to Ghana
Customs Management System (GCMS) through the
Ghana Community Network (GCNet) where the facility
is available or
b) Purchase and complete Single Administrative
document (SAD) at the station of import (usually
overland) where the GCNet facility is not available.
v. a) On validation of the declaration, or after
acceptance of SAD,
b) Pay relevant duties at the bank (where applicable).
vi. a) Proceed to the Long room with hard copy of
declaration for further Processing by Compliance
Officer or
b) submit pay-in slips together with SAD to the
Customs cashier for processing
vii. Proceed to the Outdoor (cargo section) for
examination and or release of goods. N.B.
Examination of goods may be by a scanner or physical
examination.
viii. Post clearance verification may be carried out by
Customs at the importer’s premises as and when so
determined.
61
CEPS - Hard Copy
Document
IDF, Entry
Form C.44
for transit
goods,
cargo
manifests
ETLS Gap Analysis – Ghana ––December 2010
FREE MOVEMENT OF GOODS
ETLS Agreement
Ghana law
No quota or quantity
restrictions
Publicly available regulations could not be found
Removal of all non-tariff
barriers
Publicly available regulations could not be found
No seasonal restrictions
Publicly available regulations could not be found
Minerals duty free
Publicly available regulations could not be found
Vegetables and fruits
need duty free
General Exemption from Payment of Duty
(5) Foodstuffs, including raw foodstuffs and gari originating
from West Africa
GCNet
www.ghanatradenet.com
General Exemption from Payment of Duty
(5) Foodstuffs, including raw foodstuffs and gar originating
from West Africa;
GCNet
Live animals need no
certificate of origin and
duty free
Source
Products obtained from
live animals
Requires Ministry of Agriculture/Trade permit. See Import
Restrictions under non-tariff barriers.
Products from hunting,
game, fishing, seas, rivers
are duty free
General Exemption from Payment of Duty
(5) Foodstuffs, including raw foodstuffs and gari originating
from West Africa
(6) Fish
Industrial goods of
ECOWAS origin
Publicly available regulations could not be found
Handicrafts of ECOWAS
origin - duty free
Publicly available regulations could not be found
Used articles from
ECOWAS duty free
Publicly available regulations could not be found
Scrap & waste from
manufacturing in
ECOWAS duty free
Publicly available regulations could not be found
ETLS Register
Sample application for registration under ETLS available
from GIPC
Transit goods duty free
48. Goods entered for trans-shipment or in transit through
Ghana in accordance with any regulation made under this
Law shall be exempt from payment of import duties.
Value added of 30% duty
free
Publicly available regulations could not be found
Certificate of Origin
List of documents to ensure shipments clear customs in a
timely manner. CEPS Guide also states that a Certificate
of Origin is necessary for duty free entry into ECOWAS.
62
Form
GCNet
GIPC – Ghana
Investment Promotion
Centre
CEPS Law, 1993 Part II
– Taxes and Duties,
Art. 48 - Hard Copy
Document
GCNet
ECOWAS
form
ETLS Gap Analysis – Ghana ––December 2010
Types of Taxes and Fees
x
x
x
x
x
x
x
x
Import VAT (12.5%)
National Health Insurance Levy (NHL) (2.5%)
Import Excise Duty (tobacco 140%, Beer 50%, Water 20%, Malt Drink 5% all others 1%)
Export Development and Investment Fund Levy (EDIF) (0.5%)
ECOWAS Levy (0.5%)
Examination of Vehicles Fee (1%)
Certification Fees for vehicles (?)
Processing Fee (1%)
63
ETLS Gap Analysis – Ghana ––December 2010
ANNEX C: ECOWAS Templates versus National Templates
ECOWAS EMBARKATION/DISEMBARKATION CARD
GHANA EMBARKATION/DISEMBARKATION CARD
64
ETLS Gap Analysis – Ghana ––December 2010
65
ETLS Gap Analysis – Ghana ––December 2010
GHANA ISRT LOGBOOK
66
ETLS Gap Analysis – Ghana ––December 2010
Certificates of Origin
ECOWAS CERTIFICATE OF ORIGIN
GHANA CERTIFICATE OF ORIGIN
67
ETLS Gap Analysis – Ghana ––December 2010
Travel Certificates
ECOWAS PASSPORT
GHANA PASSPORT
68
ETLS Gap Analysis – Ghana ––December 2010
Brown Card Insurance Scheme
ECOWAS BROWN CARD
GHANA BROWN CARD
69
ETLS Gap Analysis – Ghana ––December 2010
Brown Card Law
70
ETLS Gap Analysis – Ghana ––December 2010
71
ETLS Gap Analysis – Ghana ––December 2010
72
ETLS Gap Analysis – Ghana ––December 2010
73
ETLS Gap Analysis – Ghana ––December 2010
74
ETLS Gap Analysis – Ghana ––December 2010
75
ETLS Gap Analysis – Ghana ––December 2010
76
ETLS Gap Analysis – Ghana ––December 2010
77
ETLS Gap Analysis – Ghana ––December 2010
ECOWAS versus Ghanaian Format for Bond Guarantee
78
___2-$150 formal
(17%) __informal
n/a __86______%
Customs_________%
Bor. Pol._________%
Other____14_____%
n/a______86_____%
Notes: IMM
Customs_ 14_____%
Bor. Pol. _21_____%
Other____21_____%
n/a______44*____%
yes_____7_______%
no____79_______%
other___7_______%
n/a ____7_______%
yes___ 43_______%
no___ 28_______%
other__21_______%
n/a___ 7_______%
Notes: Not necessarily
official
Visa
ECOWAS Residence
Card
ECOWAS Travel
Certificate or Passport
____formal (28%)
________informal
n/a___72_____%
____formal (7%)
____informal (7%)
n/a ___86_____%
Customs___7_____%
Bor. Pol.___7_____%
Other___________%
n/a______86_____%
Agency - who
approves, signs,
seals (Total %
per answer)
yes___14_______%
no___ 86________%
other___________%
n/a_____________%
Free Movement of Persons
ETLS Agreement
Documents
needed to cross
border - add extra
if necessary
(Total % answer)
Cost/fee/or
tariff imposed
(input amount
range in local
currency or
N/A for both
formal and
informal)
Which Border Posts or Corridor are you passing through?
79
(5-30min)______ 36%
(1hr)___________ 7%
______________days
n/a___56_________%
(5-30min)______ 14%
(1-5 hrs) ________7%
___-__________ days
n/a____79_______ %
(5-30min)___
7%
(1-3hrs)_____
7%
______-____ days
n/a__86_____
%
Time to complete
process (Input
time range for
each mins, hrs or
days)
Country:
yes___43___%
no_________%
n/a___57___%
yes__ 14___%
no___ 7____%
n/a___79___%
yes__ 7____%
no___ 7____%
n/a__86____%
Is process
consistent
along all
borders
(Total %
per
answer)
agent_____14______%
Internet___________%
shipper___________%
other____14_______%
n/a____72_________%
agent___14________%
Internet___________%
shipper___________%
other____7______ %
n/a_____79________%
agent__14_________%
Internet___________%
shipper___________%
other___7_________%
n/a____79_________%
Where do you
obtain
documents
needed (Total %
per answer)
n/a = No answer
What is your mode of transport? ie. Container, refrigerated, open crates, tarpaulin covered, etc.
Generally what is your load weight, cargo, amount, origin and destination?
Other than the documents listed below, what documentation are you required to present?
Private Sector Survey Questions
Annex D: Private Sector Survey Compilations
ETLS Gap Analysis – Ghana ––December 2010
yes____36______%
no_____________%
n/a____64______%
yes____7_______%
no_____________%
n/a___93_______%
yes____________%
no_____7_______%
n/a___93_______%
Are the laws
regarding
procedures
readily
available (Total
% per answer)
Ghana
1) y__36__no_____%
2) y__21__ no_____%
3) y__no__21_____ %
n/a ____32_______%
1) y__7__no_____%
2) y__7__ no______%
3) y__no_ 7_____ %
n/a __93-93-93____%
1) y____no_______%
2) y____no_______ %
3) y____no_______ %
n/a ____ 100______%
1) Are
Inspections
required?
2) At every
border? 3) Is a
sample taken?
(Total % per
answer)
yes___ 28______%
no____ 43______%
other____________%
n/a____ 28______%
Customs__28_____%
Bor. Pol.___7_____%
Other_____7_____%
n/a______57_____%
Customs__21_____%
Bor. Pol._________ %
Other______7_____%
n/a______72_____%
yes____93______%
no_____________%
other___________%
n/a____7_______%
yes___ 43______ %
no___ 36______ %
other__________ %
n/a___21______ %
yes___ 57_______%
no____28_____ %
other_ 7_____ %
n/a___ 7_____ _%
yes___36______%
no___ 28______ %
other_ 7_____ %
n/a___ 28______ %
yes___ 72______ %
no____21______ %
other___7______ %
n/a____________%
Brown Card
Inspection every 6
months
Agreement Certificate for
an ECOWAS Road
Transit Vehicle
Inter-State Transport
Permit
Length 11m/ articulated
vehicles for containers
15m/ articulated carraige
or truck w/trailer 18m/
breadth 2.5m/ height 4m
Customs__28_____%
Bor. Pol.___7_____ %
Other____ 43_____ %
n/a______ 21_____%
Customs_ 21_____ %
Bor. Pol._________ %
Other____64_____%
n/a_____ _14______%
Notes: Insurance Co.,
INS
Customs__14_____%
Bor. Pol.___7_____%
Other____28_____%
n/a______ 50______%
Notes: DULO, DVA
yes__ 56_______%
no____21_______%
other__________%
n/a__ 21_____ %
Notes: Good for 1
month
Customs__36_____%
Bor. Pol.__21_____%
Other___________%
n/a______42______%
Customs__14_____%
Bor. Pol.__7______%
Other____14_____%
n/a____64_______%
Notes: IMM
Temporary Vehicle
Import Permit/ Customs
Clearance Booklet/
Importation &
Exportation Voucher
Free Movement - Transport Modes
Immigration or
Emigration Form/
Embarkation and
Debarkation Form
ETLS Gap Analysis – Ghana ––December 2010
________formal
(43%)_-__informal
n/a___57_____%
________formal
(28%) ___informal
n/a__72____%
_______formal
(43%)
____-__informal
n/a___57____%
$1-10 formal (57%)
____-___informal
n/a___43___%
$20-444 formal
(72%)-____informal
n/a__28____%
$23-100 formal
(50%)_____informal
n/a___50____%
10-15 formal (28%)
____informal (7%)
n/a___64_____%
80
______ - ______min
________hrs __ 36%
_____days_____7%
n/a____57______%
mi n__________14%
hrs ___________ 7%
_______-______days
n/a____79______%
______ - ______min
_________hrs 23%
______-______days
n/a_____72_____%
_____min____ __ 7%
_____21%__hrs (21%)
1-2 days________28%
n/a____43_______%
(1-30 min)_____ 28%
(1-3 hrs) _____ (28%
_____21%__ __ days
n/a___21 _______ %
(1-15 min)_____ 14%
___28%_____ __ hrs
______7% ____days
n/a_____50 ______%
(10-15 min)_____28%
(1-3 hrs) _______ 7%
______-______days
n/a____64____ ___%
yes__43___%
no___ 7___%
n/a__50___%
yes__21__%
no_______%
n/a__79___%
yes___36_%
no_______%
n/a___64__%
yes__36____%
no___ 7____%
n/a__57___%
yes__ 72__%
no_______%
n/a___28__%
yes__28 %
no___28_ %
n/a__ 44_%
yes___21___%
no____7____%
n/a___72___%
agent___28 ______%
Internet___________%
shipper___________%
other____7________%
n/a_____64________%
agent_____________%
Internet___________%
shipper___________%
other___21_______%
n/a____79_________%
agent_____________%
Internet___________%
shipper___________%
other___14_______%
n/a_____86________%
agent___14________%
Internet___________%
shipper___7_______ %
other____28_______ %
n/a_____50________%
agent___28______ %
Internet__________%
shipper__7______%
other_ 43________%
n/a____ 21________%
agent____ 36______%
Internet___________%
shipper___________%
other____21_______ %
n/a______42_______%
agent____28______%
Internet___________%
shipper___________%
other____14_______%
n/a___56________%
Notes: Border Police
yes____21_____%
no_____ 7______%
n/a_____72_____%
yes_____7_____%
no_____________%
n/a_____93_____ %
yes____________%
no____21_____%
n/a___ 79______ %
yes__14______%
no___14______%
n/a__72______%
yes____50_____%
no_____ 7_____%
n/a____43______ %
yes____42_____%
no____ 14______%
n/a____42____%
yes____21______%
no_____14_____%
n/a____ 64______%
1) y__14_no______%
2) y__14__ no_____%
3) y____7_ no__7__%
n/a _86-86-86_____ %
1) y__7__no______%
2) y__7__no______%
3) y__no_7_______ %
n/a __93-93-93____ %
1) y__7__no______%
2) y__7__ no______%
3) y__no_7___%
n/a _93-93-93_____ %
1) y__28_no______%
2) y__14_no_____%
3) y__ no_7_______%
n/a _72-86-93_____ %
1) y__57_no_____%
2) y__50_ no______%
3) y__no_50___
%
n/a __43-50-50___ %
1) y_21__no______%
2) y_21__no_____%
3) y_no__21______ %
n/a _79-79-79_____ %
1) y_21_no______%
2) y_21_no______%
3) y_ no_14______ %
n/a _79-79-86_____ %
$2 formal (50%)
___7%__informal
n/a___43___%
$30-59 formal ________informal
n/a____43__%
Notes: or .25%
Customs__57_____%
Bor. Pol.________%
Other_____ 7_____%
n/a______ 36_____%
Customs__50_____ %
Bor. Pol.________%
Other_____7______%
n/a______ 43_____ %
Notes: SIC
Customs__63_____%
Bor. Pol.________%
Other___________%
n/a______ 36______%
yes___ 64_______%
no____14_______%
other___________%
n/a___ 21_______%
yes___ 57_______%
no____14_______%
other___________%
n/a____28______%
ISRT__21_______%
ECO:__ 7_______%
National__57____%
Other__________%
n/a__14______%
License Plate - front and
rear, ISRT, National or
ECOWAS plates
ECOWAS ISRT log book
- Carnet TRIE
ISRT Convention
Guarantee - surety or
bond - multiple or single
transit
Declaration Form
Registration of Firms
under ETLS
yes___ 43______ %
no____36______ %
other___7______ %
n/a___ 14______ %
Customs__21_____%
Bor. Pol.________%
Other____14______%
n/a______ 63_____%
$100 formal (57%)
____-____informal
n/a___43___%
ISRT_____14_____%
ECO:___________%
National__57_____ %
Other___________%
n/a______ 28_____%
yes___ 78______ %
no_____________%
other___________%
n/a___ 21___ ___%
Containers seal
Free Movement of Goods
$250 formal (50%)
___$0.10_informal
n/a__43___%
Customs__72_____%
Bor. Pol._________ %
Other___________%
n/a______28_____%
yes___63______ %
no_____________%
other__21______ %
n/a___ 14______%
______formal
(36%) ________informal
n/a___72__%
_______formal
(36%)
_____informal (7%)
n/a___57___%
$1-30 formal (28%)
$0.20 informal
n/a__57_____%
Customs__36_____%
Bor. Pol._________%
Other____14_____%
n/a______50______%
yes___ 57 ______%
no____28_______%
other_________ _%
n/a___14_______%
Containers - Certificate
of Agreement for an
ECOWAS Road Transit
Container
_______formal
____informal (14%)
n/a___14__%
Axle limit 11.5 tonnes
Customs__28_____ %
Bor. Pol.__14_____ %
Other____ 50_____%
n/a_______7______%
yes___100______%
no_____________%
other___________%
n/a____________%
ETLS Gap Analysis – Ghana ––December 2010
81
______min____ _ 7%
______-_______ hrs
____21%____ _ days
n/a____72________%
_________min __ 7%
_________hrs _ 28%
1-2 days ______14%
n/a___50_______%
________min 7%
1-2 hrs. 43%
______-______days
n/a___50_____%
(5-30 min)_____ 14%
_____50%____ _ hrs
______-______ days
n/a____36_____ _ %
yes___36___%
no_________%
n/a___63___%
yes__43___%
no___7____%
n/a___50__%
yes__36___%
no_________%
n/a__63___%
yes__36___%
no____7____%
n/a___57__%
yes__28__%
no___21__%
n/a__50___%
yes__14___%
no_21_____%
n/a__64___%
___min ________ 7%
1-3 hrs _______ 43%
1-4 days ______ 14%
n/a____36____ __ %
(1-5 min)______ 21%
________hrs __ 36%
______-______days
n/a____43______%
yes__28___%
no___7_____%
n/a___63___%
yes___57__%
no__ 21__%
n/a___21__%
min______ ____ 14%
hrs_____14%_____
1-4 days_________7%
n/a_____63_______%
(1-10 min)_____ 36%
______hrs_____ 36%
_________days 14%
n/a______14%_____%
agent__ 14_______%
Internet___________%
shipper__ 7_______%
other___21______%
n/a_____57______ %
Notes: CC
agent___14_______%
Internet___________%
shipper___________%
other____57_______ %
n/a_____28________%
agent___14________%
Internet___________%
shipper__7________ %
other____21_______ %
n/a______57_______%
Notes: COFC
agent___14________%
Internet___________%
shipper__14_______ %
other____14_______ %
n/a_____57_______%
agent____7_______ %
Internet___________%
shipper___________%
other____28_______ %
n/a_____64_______%
agent___43______%
Internet___________%
shipper___7_______ %
other_____7_______ %
n/a_____43________%
agent___36_______ %
Internet___________ %
shipper__7________ %
other___14________ %
n/a____43_______%
agent__14______ %
Internet___________%
shipper_14________ %
other___14_______ %
n/a_____57________%
yes____21______%
no______7______%
n/a_____72_____ %
yes_____21____%
no_____________%
n/a_79
%
yes____28______%
no_____________%
n/a___72_______%
yes_____21_____%
no_____7______%
n/a____72______ %
yes____________%
no_____7_______%
n/a____93_____%
yes____21______%
no_____ 7______ %
n/a____72______ %
yes____21_____%
no______7______%
n/a____72______ %
yes____43_____%
no_____ 7______%
n/a____50_____%
1) y__21_no______%
2) y__21_ no______%
3) y__no__7______ %
n/a _78-78-93_____ %
1) y__14__no_____%
2) y__14__ no_____%
3) y__14_ no_____%
n/a __57_________ %
1) y__7__no______%
2) y__7__ no______%
3) y__no__7______ %
n/a _93-93-93_____ %
1) y_7__no______%
2) y_7___ no______%
3) y_no__7_______ %
n/a _93-93-93_____ %
1) y__no_7_______ %
2) y__ no_7_______%
3) y__ no_7_______%
n/a _93-93-93_____ %
1) y__36__no_____%
2) y__28__ no_____%
3) y_14__ no__14_%
n/a _63-72-72_____ %
1) y__36_no______%
2) y__28_ no______%
3) y__14__ no__14_%
n/a__63-63%
1) y_36_no______%
2) y_21_no__14__%
3) y_7__no_14____ %
n/a _64-64-64_____ %
_____-_____formal
_____informal (7%)
n/a__93____%
_____-_____formal
____-____informal
n/a___100___%
_____-_____formal
____-____informal
n/a___100__%
_____-_____formal
____-____informal
n/a__100____%
Customs___7_____%
Bor. Pol.________%
Other___________%
n/a______ 93______%
Customs_________%
Bor. Pol.________%
Other___________%
n/a_____100_____ %
Customs_14______%
Bor. Pol.________%
Other___________%
n/a_____ 86______%
Customs__14_____%
Bor. Pol.________%
Other___________%
n/a______ 86______%
Customs_________ %
Bor. Pol.________%
Other____________%
n/a_____100_______%
Customs__________%
Bor. Pol.__________%
Other____________%
n/a_____100______%
Customs_________%
Bor. Pol.________ _%
Other___________%
n/a_____100______%
yes___57______%
no____21_______%
other___7_______%
n/a___14_______%
yes___ 21_______%
no____50_______%
other___7_______%
n/a___ 14_______%
yes___21_______%
no____36______%
other__________%
n/a___43_______%
Notes: Partial
yes____7______%
no_____7______%
other___7______%
n/a___ 78_____%
yes___7_______%
no__14________%
other___________%
n/a__78________%
yes____7_______%
no____14_______%
other__________%
n/a___ 78_______%
yes____7________%
no____14________%
other___________%
n/a___78________%
Quantity restrictions
Removal of all non-tariff
barriers
Seasonal restrictions
Minerals duty free
Vegetables and fruits
duty free
Live animals duty free
Products obtained from
live animals duty free
Products from hunting,
game, fishing, seas,
rivers are duty free
______formal (7%)
_____informal (7%)
n/a____86___%
_____-_____formal
____-____informal
n/a___100____%
_____-_____formal
_____informal (7%)
n/a__93____%
______formal (7%)
____-____informal
n/a____93___%
Customs_________%
Bor. Pol.________%
Other_____ 7_____%
n/a______ 93_____ %
yes___14_______%
no____72_______%
other___________%
n/a___14_______%
Quota restrictions
_____formal (7%)
____-____informal
n/a___93__%
Customs__14_____%
Bor. Pol._________ %
Other_____ 7_____%
n/a______ 78_____%
yes___28_______%
no____57______%
other__________%
n/a___14______%
ETLS Gap Analysis – Ghana ––December 2010
yes________%
no___ 7____%
n/a__93____%
yes________%
no_________%
n/a__100___%
______ - ______min
_______hrs___ _ 7%
______-______days
n/a___93________%
______ - ______min
______-_______hrs
______-______ days
n/a____100______%
82
yes________%
no_________%
n/a__100__%
yes________%
no_________%
n/a__100__%
______ - ______min
______-_______hrs
______-______days
n/a____100______%
______ - ______min
______-_______hrs
______-______days
n/a____100______%
yes________%
no_________%
n/a__100_%
yes________%
no_________%
n/a__100___%
______ - ______ min
______-_______ hrs
______-______ days
n/a___100________%
______ - ______min
______-_______hrs
______-______days
n/a____100_______%
yes__ 7___%
no_________%
n/a__93___%
yes__7___%
no_________%
n/a__93___%
______ - ______min
__________hrs _ 7%
______-______days
n/a___93_______%
______ - ______min
_______hrs____ 14%
______-______days
n/a___86_________%
yes__7____%
no___7_____%
n/a__86___%
______ - ______min
_________hrs ___7%
______-______days
n/a_____93______%
agent____7______%
Internet___________%
shipper___________%
other___14______%
n/a_____78_______%
agent_____________%
Internet___________%
shipper___________%
other____7_______%
n/a_____93________%
agent_____________%
Internet___________%
shipper___________%
other_____7_____ %
n/a_____93_______%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100________%
agent____7 ______%
Internet__ _________%
shipper___________%
other_____________%
n/a_____93__ _____%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100________%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100_______%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100_______%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100_______%
yes____________%
no_____________%
n/a___100_____%
yes____________%
no_____________%
n/a___100___ ___%
yes____________%
no_____________%
n/a___100______ %
yes____________%
no_____________%
n/a____100_____%
yes____________%
no_____ 7______ %
n/a____93______ %
yes____________%
no_____________%
n/a___100______%
yes____________%
no_____7______%
n/a_____93____%
yes____________%
no_____________%
n/a___100______%
yes_____7______%
no_____________%
n/a_____93_____%
1) y_____no______%
2) y____ no______%
3) y_____ no______%
n/a ____100______%
1) y____no_______%
2) y____ no______%
3) y____ no______%
n/a ____100_____%
1) y____no_______ %
2) y____ no_______%
3) y____ no______%
n/a _____100______%
1) y____no______%
2) y____no______%
3) y____no______%
n/a ____100_____%
1) y_no__7_______ %
2) y_no__7_______ %
3) y_no__7______ %
n/a _93-93-93_____ %
1) y____no______%
2) y____no_______ %
3) y____no______%
n/a ___100_______%
1) y____no_______%
2) y____no______%
3) y____no______
n/a ___100_______%
1) y____no______%
2) y____no______%
3) y____no______%
n/a ____100_____%
1) y_7__no______%
2) y_7__no_______ %
3) y_no__7___
%
n/a _93-93-93_____%
$0.20-10 (64%)
formal ________informal
n/a___36____%
_____formal (64%)
__informal (36%)
n/a__________%
Notes: .25%
_____-_____formal
____informal (14%)
n/a___86____%
$0.05 formal (21%)
___-____informal
n/a____ _78____%
Customs _14_____ %
Bor. Pol.________ _%
Other____ _7_____%
n/a______ 78_____%
Customs__72_____%
Bor. Pol._________ %
Other____21_____%
n/a_______ 7_____%
Customs__78_____%
Bor. Pol.__14_____ %
Other____________%
n/a______14_____%
Customs_________%
Bor. Pol._______ __%
Other____ 14_____%
n/a______ 86_____%
Customs_________%
Bor. Pol.________ _%
Other____ 21_____ %
n/a_____ _78_____ %
Notes: Human Health
Customs___7_____%
Bor. Pol__.________%
Other____36_______%
n/a______ 57______%
Customs_________%
Bor. Pol._______ __%
Other____________%
n/a_____ 100 _____%
yes___14______%
no____36_______%
other__________ %
n/a___50_______%
yes__93________%
no____7________%
other___________%
n/a____________%
yes___ 64_______%
no_____7_______%
other__14_______%
n/a___14_______%
yes___14______%
no_____7_______%
other__________%
n/a___78______%
yes___14_______%
no_____7______%
other__________ %
n/a____78_____%
yes__ _43_______%
no_____7_______%
other__________%
n/a___ 50_______%
yes___________%
no_____________%
other___________%
n/a__100_______%
Used articles from
ECOWAS duty free
Scrap & waste from
manufacturing in
ECOWAS duty free
ECOWAS certificate of
origin
Transit goods duty free
Value added of 30% duty
free
Veterinary
Phytosanitary
Other
_____-_____formal
____-____informal
n/a____ _100____%
$14 formal (36%)
____informal
n/a__
64____%
_____-_____formal
_______informal
(14%) n/a
__86____%
_____-_____formal
____-____informal
n/a__100____%
Customs_________%
Bor. Pol._________ %
Other____________%
n/a_____ 100_____%
yes_____7______%
no____28______%
other___7_______%
n/a____57______%
Handicrafts originating
in ECOWAS duty free
_____-_____formal
____-____informal
n/a____100_%
Customs___7___ %
Bor. Pol.________ _%
Other____________%
n/a______93_____%
yes____________%
no_____7_______%
other__14______%
n/a___78_______%
Notes: Some
ETLS Gap Analysis – Ghana ––December 2010
yes__21___%
no________%
n/a___78__ _%
yes________%
no_________%
n/a__100___%
_________min _ 21%
_________hrs _ 21%
______-______days
n/a____57______%
______ - ______min
______-_______hrs
______-______days
n/a__100________%
83
yes__7_____%
no_________%
n/a__93____%
yes______ %
no__14___ %
n/a__86_____%
yes__36___ _%
no___14____%
n/a__50____ %
yes__57____%
no___7_____%
n/a__36____%
yes__7____%
no___7____%
n/a__86___%
yes________%
no_________%
n/a__100__%
yes________%
no_________%
n/a__100___%
__________min 7%
__________hrs _ 7%
______-______ days
n/a____86%_______%
______ - ______min
______-_______hrs
_________days 14%
n/a_____86_____%
_________min _ 36%
_________hrs _ 36%
_______days ___7%
n/a____36_______%
_______min ___ 21%
(1-5 hrs) ______ 28%
1 day ________ 14%
n/a_____36_____%
______ - ______min
______-_______hrs
_____days___14%
n/a__86________%
______ - ______min
______-_______hrs
______-______days
n/a__100_______%
______ - ______min
______-_______hrs
______-______days
n/a___100_______%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100________%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a____100_______%
agent____7________%
Internet___________%
shipper___________%
other_____________%
n/a_____93________%
agent___43________%
Internet_14________ %
shipper_14__ ______%
other___28_______ %
n/a_______________%
Notes: CC, COFC
agent___36_______%
Internet___________%
shipper__14_______%
other____21_______ %
n/a_____28________%
agent_____________%
Internet___________%
shipper___________%
other___7_________%
n/a____93_________%
agent_____________%
Internet___________%
shipper__7_______%
other_____________%
n/a____93________%
agent__21_________%
Internet___________%
shipper___________%
other___7_________ %
n/a____72_________%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a___100_________%
yes____________%
no_____________%
n/a____100_____ %
yes____________%
no_____7_______%
n/a____93______%
yes___________%
no_____________%
n/a___100______ %
yes___________%
no____14______%
n/a____86______ %
yes____28_____%
no___28________%
n/a____43______%
yes____43_____%
no____ 14______%
n/a____43_____%
yes____ 7______ %
no_____7______%
n/a_____86_____%
yes____________%
no_____________%
n/a____100_____ %
yes____________%
no_____________%
n/a__100______%
1) y_____no______%
2) y_____ no______%
3) y_____ no______%
n/a _____100_____%
1) y_28__no______%
2) y_28__ no______%
3) y__7__ no__14__%
n/a __72-72-78____ %
1) y__7__no______%
2) y_____ no______%
3) y_____ no______%
n/a _93-100-100___ %
1) y__7___no_____%
2) y__7__ no______%
3) y__7__ no______%
n/a _93-93-93_____ %
1) y__21_no__7___%
2) y__21__ no__7_%
3) y__14__ no__14_%
n/a __72-72-72____ %
1) y__28__no_14__ %
2) y__36_ no__7__%
3) y__14_ no_____%
n/a _57-57-86_____%
1) y____no______%
2) y____no______%
3) y____no______%
n/a ___100_______%
1) y____no______%
2) y____ no______%
3) y____ no______%
n/a ____100______%
1) y____no______%
2) y____no______%
3) y____no______%
n/a ___100_______%
Documents
Required (Circle
Answer)
yes____80_____%
no_____________%
other___________%
n/a_____20____%
yes___80______%
no_____________%
other___________%
n/a____20_______%
yes______ 40_____%
no_______ 20_____%
other_____20_____%
n/a______ 20_____%
yes___ ___80_____%
no_____________%
other___________%
n/a______ 20_____%
yes___ ___80_____%
no_____________%
other___________%
n/a__ ____20_____%
Visa
ECOWAS Residence
Card
ECOWAS Travel
Certificate or Passport
Immigration or
Emigration Form/
Embarkation and
Debarkation Form
yes___80___%
no_____________%
other___________%
n/a____20______%
yes___80______%
no_____________%¶
other___________%¶
n/a____02______%¶
Do you have
legislation/
procedure
pertaining to the
ECOWAS listed
topic? (Circle
Answer)
yes____________%
no___ ____80_____%
other___________%
n/a______ 20_____%
Free Movement of Persons
ETLS Agreement
Public Sector Survey Questions
yes____80_____%
no_____________%
other___________%
n/a____20______%
yes___80______%
no_____________%
other___________%
n/a___20______%
yes___80_____%
no_____________%
other___________%
n/a____20______%
yes____80____%¶
no___________%¶
other_________%¶
n/a__20______%¶
Is this procedure
implemented at
the border?
(Circle Answer)
Annex E: Public Sector Survey Compilations
ETLS Gap Analysis – Ghana ––December 2010
agent____80_____%
Internet___________%
shipper___________%
other_____________%
n/a_______20______%
agent_____80______%
Internet___20_____%
shipper___________%
other_____________%
n/a_______________%
agent___80______%
Internet___________%
shipper___________%
other_____________%
n/a_____20________%
agent______80____%
Internet___________%
shipper___________%
other_____________%
n/a______20______%
agent____80____%
Internet___________%
shipper___________%
other_____________%
n/a_____20________%
agent____80______%
Internet___________%
shipper___________%
other_____________%
n/a___20_________%
84
agent_____80_____ __ %¶
Internet__20_________ %¶
shipper___________ __ %¶
other_____________ __ %¶
n/a________________ %¶
How is private sector
informed? (Circle
Answer)
n/a = No answer
agent_____80______%¶
Internet___________%¶
shipper___________%¶
other_____________%¶
n/a____20________%
Where is document/
process found?
(Circle Answer)
Country:
1) y_80__no_____%
2) y__60_ no_20_%
n/a __20-20___%
1) y_80__no_____%
2) y_80_ no_____%
n/a ___20-20____%
1) y_80__no_____%
2) y_20_ no_60__%
n/a ___20-20___%
1) y_60_no__20__%¶
2) y__60_ no_20_%
n/a ___20-20____%¶
1) Are
inspections
required?
2) At every
border on entry
and exit?
Ghana
yes______80____%
no_____________%
other___________%
n/a_____20_____%
yes____40______%
no____20______%
other___________%
n/a___40____%
yes___60______%
no_____________%
other___________%
n/a____40_____%
yes____40______%
no_____________%
other___________%
n/a__60_______%
yes____80_____%
no_____________%
other___________%
n/a___20________%
yes____20______%
no_____________%
other___________%
n/a____80______%
yes____20______%
no_____________%
other___________%
n/a____80______%
yes______ 60_____%
no_______ 20_____%
other____________%
n/a_____ 20_____%
yes_____ _60____ %
no____________%
other__________%
n/a______ 40____ %
Notes: From SIC
yes______ 40_____%
no______ _20_____%
other___________%
n/a______ 40_____%
ISRT___________ %
ECO:__________%
National__40____%
Other__________%
n/a______ 60____%
ISRT___________ %
ECO:__________%
National_ _80____ %
Other__________%
n/a______ 20____%
yes______ 20____%
no____________%
other__________%
n/a______ 80____%
yes___
%
no_____20____%
other________ %
n/a____80___ %
Temporary Vehicle
Import Permit/ Customs
Clearance Booklet/
Importation-Exportation
Voucher
Brown Card
Inspection every 6
months
License Plate - front and
rear, ISRT or ECOWAS
plates
Inter-State Transport
Permit
Length 11m/ articulated
vehicles for containers
15m/ articulated
carriage or truck
w/trailer 18m/ breadth
2.5m/ height 4m
Axle limit 11.5 tonnes
Transport
ETLS Gap Analysis – Ghana ––December 2010
yes____20______%
no_____________%
other___________%
n/a____80______%
yes____20______%
no_____________%
other___________%
n/a____80______%
yes____40______%
no_____40______%
other___________%
n/a____20_______%
yes____40______%
no_____________%
other___________%
n/a____60_______%
yes___40______%
no____20_______%
other___________%
n/a_____60_____%
yes____60______%
no_____________%
other___________%
n/a___40_______%
yes___80____%
no_____________%
other___________%
n/a____20______%
1) y__20__no___%
2) y__20_no____%
n/a ___80-80____%
agent____20______%
Internet___________%
shipper___________%
other_____________%
n/a____80________%
agent____20______%
Internet___________%
shipper___________%
other_____________%
n/a____80________%
85
1) y__20__no___%
2) y__20__ no___%
n/a ___80-80____%
1) y_80__no______%
2) y__40_ no_40_%
n/a ____20-20__%
Internet/(20%)
Agency/Shipper
Other/ (80%) n/a
Internet/(80%)
Agency/Shipper/
Other/(20%) n/a
1) y__40__no____%
2) y_20__ no_20_%
n/a ____60-60___%
1) y__40__no_20_%
2) y_40_no___20_%
n/a ____40______%
1) y__60_no_____%
2) y_60_ no_____%
n/a _40-40___%
1) y_80___no____%
2) y_80_ no_____%
n/a ___20-20__%
Internet/(20%)
Agency/Shipper/
Other/ (80%) n/a
Internet/ (80%)
Agency/Shipper/
Other/ (20%) n/a
agent____40_______%
Internet___________%
shipper___________%
other_____________%
n/a_____60________%
agent____60______%
Internet___________%
shipper___________%
other_____________%
n/a___40_________%
agent____60______%
Internet___________%
shipper___________%
other_____________%
n/a___40_________%
agent______40___%
Internet___________%
shipper___________%
other_____________%
n/a_____60_______%
agent______60____%
Internet___________%
shipper___________%
other_____________%
n/a____40_______%
agent____80______%
Internet___________%
shipper___________%
other_____________%
n/a_____20_______%
agent_____60_____%
Internet___________%
shipper___________%
other_____________%
n/a____40________%
agent___80_____%
Internet___________%
shipper___________%
other_____________%
n/a______20_______%
yes_____60_____%
no_____________%
other___________%
n/a____40______%
yes____20______%
no_____________%
other___________%
n/a___80_______%
yes___60______%
no_____________%
other___________%
n/a____40______%
yes______ 40_____%
no_______ 20_____%
other___________%
n/a______ 40_____%
yes_____ 20____%
no_____________ %
other____20_____ %
n/a_____ 60____%
Notes: SIC
yes_____________
no______40____%
other____ 20_____
n/a_____40____%
Notes: National
Containers seal
ECOWAS ISRT log book
- Carnet TRIE
ISRT Convention
Guarantee - surety or
bond - multiple or single
transit
ISRT or ECOWAS Single
Customs Declaration
Form
yes____20_____%
no_____________%
other___________%
n/a___80_______%
yes____20_____%
no_____________%
other___________%
n/a_____80_____%
yes____________ %
no______ 60____ %
other__________ %
n/a_____ 40____ %
yes____________ %
no_____ 60____%
other__________%
n/a_____ 40____ %
Quota restrictions
Quantity restrictions
Free Movement of Goods
yes____60______%
no_____________%
other___________%
n/a__40________%
yes____60______%
no_____________%
other___________%
n/a__40________%
yes_____ 60_____%
no_____________%
other___________%
n/a______ 40_____%
yes____20_____%
no_____________%
other___________%
n/a_____80_____%
yes____20______%
no_____________%
other___________%
n/a___80______%
yes____________%
no_____60____%
other___________%
n/a______40____%
yes____20_____%
no___20_______%
other___________%
n/a___60______%
yes____40___%
no_____20____%
other___________%
n/a_____40____%
yes____20______%
no_____________%
other___________%
n/a____80______%
yes____20______%
no_____________%
other___________%
n/a____80______%
ISRT____________%
ECO:___________%
National__ 20_____%
Other___________%
n/a______ 80_____%
Containers - Certificate
of Agreement for an
ECOWAS Road Transit
Container
ETLS Gap Analysis – Ghana ––December 2010
agent___60______%
Internet___40______%
shipper___________%
other_____________%
n/a_______________%
agent___60_____%
Internet__20______%
shipper__20_______%
other_____________%
n/a_______________%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
86
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent_____20______%
Internet___________%
shipper___________%
other_____________%
n/a___80________%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent____20_______%
Internet___________%
shipper___________%
other_____________%
n/a___80_________%
agent____20______%
Internet___________%
shipper___________%
other_____________%
n/a____80________%
agent___60_______%
Internet___________%
shipper___________%
other_____________%
n/a_____04________%
agent___60_______%
Internet___________%
shipper___________%
other_____________%
n/a_____04________%
agent____20______%
Internet___________%
shipper___________%
other_____________%
n/a_____80_______%
agent____20______%
Internet___________%
shipper___________%
other_____________%
n/a____80________%
agent____20______%
Internet___________%
shipper___________%
other_____________%
n/a____80________%
1) y__20_no____%
2) y_20__ no____%
n/a __80-80__%
1) y___no__20__%
2) y____ no_20__%
n/a __80-80__%
1) y___no___60_%
2) y___ no__60__%
n/a __40-40____%
1) y___no__20__%
2) y____ no_20__%
n/a __80-80__%
1) y__40_no_20_%
2) y_20__ no_40_%
n/a ___40-40___%
1) y_60__no____%
2) y__20_no_04_%
n/a __40-40_____%
1) y__20__no___%
2) y__20_no____%
n/a ___80-80____%
yes____20_____%
no_____________%
other___________%
n/a_____80___%
yes____60_____%
no_____________%
other___________%
n/a___40_______%
yes____40______%
no_____________%
other___________%
n/a___60_______%
yes__40_______%
no_____________%
other___________%
n/a____60_____%
yes__40_______%
no_____________%
other___________%
n/a___60________%
yes____20______%
no_____20______%
other___________%
n/a____60______%
yes___20______%
no_____________%
other___________%
n/a___80_____%
yes______ 20____%
no_______ 20____%
other___________%
n/a______ 60_____%
yes______40____%
no_______20_____%
other___________%
n/a______40_____%
yes____ __40_____%
no_____ __20_____%
other____________%
n/a__ ___ 40______%
yes___ ___20____ %
no____ ___20____ %
other__________ _%
n/a___ ___60____%
yes_____________%
no____ __ 40______%
other___________%
n/a___ ___60_____%
Seasonal restrictions
Minerals duty free
Vegetables and fruits
duty free
Live animals duty free
Products obtained from
live animals duty free
Products from hunting,
game, fishing, seas,
rivers are duty free
yes_____40_____%
no_____________%
other___________%
n/a____60______%
yes___40______%
no_____________%
other___________%
n/a___60______%
yes____20______%
no_____________%
other___________%
n/a____80____%
yes____20_____%
no_____________%
other___________%
n/a_____80_____%
yes____20_____%
no_____________%
other___________%
n/a_____80_____%
yes__ ____20____ %
no______ _40____ %
other__________ %
n/a___ ___40____%
yes____20_____%
no_____________%
other___________%
n/a_____80_____%
yes____20_____%
no_____________%
other___________%
n/a_____80_____%
yes_____ _20____%
no______ _40____ %
other__________%
n/a______40_____%
Removal of all non-tariff
barriers
ETLS Gap Analysis – Ghana ––December 2010
1) y__20__no___%
2) y__20__ no___%
n/a ___80-80____%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent____60______%
Internet___________%
shipper___________%
other_____________%
n/a______40______%
agent____40______%
Internet___________%
shipper___________%
other_____________%
n/a___60_________%
agent_____40______%
Internet___________%
shipper___________%
other_____________%
n/a__60_________%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent______60____%
Internet___________%
shipper___________%
other_____________%
n/a____40_______%
agent____40______%
Internet___________%
shipper___________%
other_____________%
n/a____60________%
agent___40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_______%
87
1) y__40__no___%
2) y__20_ no_20_%
n/a __60-60_____%
agent____40_______%
Internet___________%
shipper___________%
other_____________%
n/a_____60______%
agent____40_______%
Internet___________%
shipper___________%
other_____________%
n/a_____60______%
1) y__60_no____%
2) _40_no_20___%
n/a __40-40_____%
1) y__40__no___%
2) y__40_ no____%
n/a ___60-60____%
1) y__20_no____%
2) y_20__ no____%
n/a __80-80__%
1) y__20_no____%
2) y_20__ no____%
n/a __80-80__%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
1) y__20_no____%
2) y_20__no____%
n/a __80-80__%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
agent___20_______%
Internet___________%
shipper___________%
other_____________%
n/a_____80________%
yes____20______%
no_____________%
other___________%
n/a____80_____%
yes____20______%
no_____________%
other___________%
n/a____80_____%
yes____60_____%
no_____________%
other___________%
n/a___40_____%
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes______ 40_____%
no_____________%
other___________%
n/a_______60____%
yes____ __40_____%
no_____________%
other___________%
n/a______ 60_____%
yes______ 40____%
no_____ __20____ %
other__________%
n/a______ 40____ %
yes______ 60_____%
no_____________%
other___________%
n/a______ 40_____%
yes____ __60_____%
no_____________%
other___________%
n/a______ 40_____%
yes_____________%
no______________%
other_____60_____%
n/a______40_____%
Notes: National
yes______ 60_____%
no_____________%
other___________%
n/a______ 40_____%
Handicrafts of ECOWAS
origin -duty free and no
Certificate of Origin
Used articles from
ECOWAS duty free
Scrap & waste from
manufacturing in
ECOWAS duty free
Duty free movement of
industrial goods
Registration of Firms
under ETLS
ECOWAS certificate of
origin
Transit goods duty free
ETLS Gap Analysis – Ghana ––December 2010
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes____________%
no____60______%
other___________%
n/a____40_____%
yes____60____%
no_____________%
other___________%
n/a____40_____%
yes____60_____%
no_____________%
other___________%
n/a___40_____%
yes____20______%
no_____________%
other___________%
n/a____80_____%
yes____20______%
no_____________%
other___________%
n/a____80_____%
1) y__60__no___%
2) y__20_no_40_%
n/a ___40-40__%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
agent_____60______%
Internet___________%
shipper___________%
other_____________%
n/a_____40________%
88
1) y_60__no____%
2) y__60_ no____%
n/a __40-40____%
agent_____60_____%
Internet___________%
shipper___________%
other_____________%
n/a______40_______%
agent_____40____%
Internet___________%
shipper___________%
other_____________%
n/a______60______%
1) y__60__no___%
2) y__20_no_40_%
n/a ___40-40__%
1) y_60__no____%
2) y___60_ no___%
n/a ___40-40____%
1) y_60__no____%
2) y_60__ no____%
n/a ___40-40____%
1) y_20__no____%
2) y_20___ no___%
n/a __80-80_____%
agent_____20_____%
Internet___________%
shipper___________%
other_____________%
n/a_____80_______%
agent_____20_____%
Internet___________%
shipper___________%
other_____________%
n/a_____80_______%
1) y_20__no____%
2) y_20___ no___%
n/a __80-80_____%
agent_____20_____%
Internet___________%
shipper___________%
other_____________%
n/a_____80_______%
agent_____20_____%
Internet___________%
shipper___________%
other_____________%
n/a_____80_______%
yes___40____%
no_____________%
other___________%
n/a___60______%
yes___40____%
no_____________%
other___________%
n/a___60______%
yes___40____%
no_____________%
other___________%
n/a___60______%
yes___40____%
no_____________%
other___________%
n/a___60______%
yes____________%
no_____________%
other___________%
n/a____100______%
yes______ 40____%
no____________%
other__________%
n/a____ __60____%
yes___ ___40____%
no____________%
other__________%
n/a______ 60_____%
yes___________%
no____________%
other__________%
n/a_____ 100____%
Customs
Veterinary
Phytosanitary
Other
yes____________%
no_____________%
other___________%
n/a______100___%
yes___40_____%
no_____________%
other___________%
n/a_____60_____%
yes___40_____%
no_____________%
other___________%
n/a_____60_____%
yes_____ _40_____%
no_____________%
other___________%
n/a_____60______%
yes____20_____%
no_____________%
other___________%
n/a____80______%
yes___20______%
no_____________%
other___________%
n/a_____80_____%
yes______ 40_____%
no_____________%
other___________%
n/a______ 60_____%
Value added of 30%
duty free
ETLS Gap Analysis – Ghana ––December 2010
agent____40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_________%
agent____40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_________%
agent____40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_________%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a______100______%
agent____40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_________%
agent____40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_________%
agent____40_____%
Internet___________%
shipper___________%
other_____________%
n/a____60_________%
agent_____________%
Internet___________%
shipper___________%
other_____________%
n/a______100_____%
89
agent____20_____%
Internet___________%
shipper___________%
other_____________%
n/a___80_______%
agent____20_____%
Internet___________%
shipper___________%
other_____________%
n/a_____80_______%
1) y____no_____%
2) y____ no_____%
n/a ___100_____%
1) y_40___no___%
2) y____ no__40_%
n/a ___60-60____%
1) y_40___no___%
2) y____ no__40_%
n/a ___60-60____%
1) y__40__no___%
2) y__40__ no___%
n/a __60-60__%
1) y__20_no____%
2) y__20__ no___%
n/a ____80-80__%
ETLS Gap Analysis – Ghana ––December 2010
ANNEX F: Immigration Pamphlet
90
ETLS Gap Analysis – Ghana ––December 2010
ANNEX G: List of Possible Cross-Border Documentation
Requirements for Ghana as produced by GCNet
91
ETLS Gap Analysis – Ghana ––December 2010
ANNEX H: Ghana Institute of Freight Forwarders List of Fees
92
ETLS Gap Analysis – Ghana ––December 2010
Ghana Institute of Freight Forwarders List of Fees
93
ETLS Gap Analysis – Ghana ––December 2010
ANNEX I: Ghana Axle-Load Diagrams
94
ETLS Gap Analysis – Ghana ––December 2010
95
ETLS Gap Analysis – Ghana ––December 2010
96