Component 2: Implementation of Policy and Procedural Reforms and Capacity Building to Facilitate Cross-Border Trade in Goods and Services
The project includes policy and procedural reforms to improve the efficiency, capacity, and security of border operations at the border crossings. As a result, new border facilities are designed to accommodate, possibly in a phased manner, procedural changes and inter-agency (and subsequently, cross-border) integration.
The reforms are essential to make border crossing procedures more transparent and predictable. This is of particular importance to small-scale traders, and especially women, who are typically more vulnerable given the asymmetry in power between the official and trader and the current lack of a functioning mechanism for addressing complaints and resolving disputes for small-scale traders. In addition, the reforms contribute to increasing safety and reducing the scope for harassment at the border, especially for women, to reducing time to cross the border and to allowing improved control and revenue generation at key border crossings.
Sub-component 2.1. Support for implementation of policy and procedural reforms at the targeted border crossings
This Sub-component focuses on basic rights and obligations for both traders and officials and the consistent application of simple rules at the border. The Sub-component supports the 3 countries:
- to implement the COMESA Regulations on the Minimum Standards for the Treatment of Small-Scale Cross-Border Traders (based on the Charter for Cross-Border Traders). The project establishes citizen engagement mechanisms, including through a toll-free hotline which allows traders to report harassment and seek information on regulations and border procedures;
- to extend the COMESA Regulations to small-scale trade in services by simplifying and making transparent immigration and health related procedures for crossing borders to provide or consume services.
- to implement the COMESA STR which provides for small-scale traders to qualify for duty-free entry for certain goods and for a more simple and reduced set of documentary requirements to cross the border.
The Charter, which constitutes the basis for the COMESA Regulations, has been developed and tested by the Bank at a number of other border posts in Sub-Saharan Africa. It enshrines a set of basic rights and obligations for traders and officials and aims to improve behavior at borders and to promote the gradual formalization of informal cross-border trade. Initially developed to facilitate trade in goods, the current version of the Charter includes both trade in goods and trade in services. The COMESA Regulations based on the language and principles of the Charter are tailored to reflect the specific challenges (including institutional reforms required in specific cases) faced by small-scale traders at targeted border crossings, and are extended to trade in services.
Extensive use of ICT technology is used to
- inform traders about the requirements for cross-border trading;
- monitor the enforcement of the COMESA Regulations; and
- address issues such as corruption, sexual harassment and physical violence.
The project supports the establishment or strengthening of Joint Border Committees (JBCs), the main forum for inter-agency cooperation and stakeholder consultation, at each of the border posts.
JBCs are important vehicles to support implementation of the procedural reforms under this project including adoption and implementation of the COMESA Regulations and the Simplified Trade Regime. JBCs also act as regular fora bringing together officials from each side, and sometimes from both sides, of the borders selected for project implementation, and be primarily responsible for discussing and resolving common issues, with the ultimate purpose of promoting inter-agency cooperation, improving border procedures and enhancing overall security.
JBCs play a major role in addressing concerns and complaints raised by traders through the ICT reporting mechanism, especially those that can be dealt with at border level and do not need to be escalated to HQs. Finally, the committees may be used to coordinate border officials attending trainings on the COMESA Regulations and the STR, and also be involved in the various awareness-raising activities for border officials planned under Component 2.
Sub-component 2.2. Training and capacity building for traders and officials to support greater integrity and ethical behavior in trade processes
The project supports customized training to strengthen basic capacity and skills of agencies for better border management. The focus is on a comprehensive program of training for officials at the border, including basic customer management, conflict resolution and gender awareness-raising among others, with the aim of supporting improved governance, drastically reduced levels of harassment and more efficient control and processing of goods and people. Training courses also cover the key principles and mechanisms of the COMESA Regulations, including extension to trade in services, and include sessions on the COMESA STR.
The project supports traders and traders associations by providing support on trade procedures, improving relations between traders and border officials, and access to market information and finance, among other things. Traders are trained in undertaking advocacy with their authorities to address issues related to harassment, insecurity, gender-related issues or other matters. Consultations with traders and association representatives suggest that there is a demand for increased training and information sharing on accessing market information/prices, understanding border procedures and documentation requirements, and developing and accessing credit/finance instruments. With the aim of building the capacity of those associations, traders’ representatives are involved in the delivery of dissemination and awareness-raising activities, as well as in the management of the reporting system to be used for responding to issues submitted by traders and to monitor the enforcement of the COMESA Regulations.
Training of officials jointly with small-scale traders to build empathy and understanding. Earlier programs have shown this to be an effective way of decreasing incidents and increasing people’s trust in their authorities. Reverse role-playing is an efficient tool for this. Gender sensitivity and the particular needs of women play a critical role in the trainings as well. These trainings include a cross-border dimension, with traders’ groups from both sides of the borders brought together to exchange ideas and experiences. In turn, these groups may play an important role in the monitoring of border agents’ performance, and engage in a constant dialogue to increase cross-border solidarity and social cohesion.
Sub-component 2.3. Support for regional coordination of the policy and procedural reforms at the targeted border crossings and regional training for traders and officials
To support the implementation of the STR, COMESA has established Trade Information Desks (TIDs) at a number of border posts in the region. These are intended to provide key information to traders on e.g. duty, documentary and other requirements, as well as to assist them in the clearance process e.g. in the filling of forms and other required documentation at the border.
Under Component 2, this project supports the enhancement of existing TIDs, or the creation of new ones, at the border crossings selected for implementation. The effective implementation of the STR requires bilateral negotiations to agreeing upon a common list of STR-eligible products, and a threshold for STR applicability at each border post. The COMESA Secretariat coordinates these activities through the TIDs that is established or reinforced at each border.
The project enables the initial staffing/increased staffing of these STR Information Desks to provide on-the-spot information to traders and support in the clearance process (e.g. by helping them filling the required forms). The project also supports the creation of an ad-hoc position for a dedicated COMESA TID Coordinator, who is based in the region and held responsible for overall supervision of all TIDs, as well as for regular collection of relevant data and statistics (to be then used for awareness-raising purposes). Given previous experience with TIDs, COMESA was considered the most suitable agency to lead in the implementation of all related activities.
More generally, the decision to include a regional institution among the implementing agencies responds to the need of ensuring overall consistency, and of introducing regional oversight, in the implementation of certain project activities such as training of the trainers, monitoring of the TID officers and policy dialogue and dissemination on regional initiatives, among others. The reliance on the COMESA Secretariat as an implementing agency is also expected to allow for enhanced coordination in the collection of data and statistics on small-scale trade in the three countries, and to offer increased potential for dissemination of that data at regional level.
COMESA plays a key role in ensuring regional coordination and communication regarding implementation of the COMESA Regulations and the STR. The project supports effective implementation of the COMESA STR. The project raises awareness of the scheme among traders and officials, and clarify the applicable threshold per transaction for traders to benefit from the STR regime. The project supports dialogue on the list of common goods that can benefit from the STR to expand the list to include products of particular importance for small-scale traders and for poverty reduction – where possible, this policy dialogue is also aimed at revisiting existing thresholds, and at ensuring overall threshold consistency between neighboring countries. There is also support for consistent implementation of the STR at all border crossing covered by the project. Extensive communication campaigns are put in place at the regional level by the COMESA Secretariat to support the dissemination and implementation of the STR.
The project supports regional coordination of training programs for small-scale
traders and officials including development of training materials, best
practices and training of trainers. In addition, the project supports regional
training for peer learning. The training will be implemented through the COMESA
Secretariat. These regional trainings are combined with a dialogue at the
capital city level to formalize and institutionalize cross-border collaboration
platforms, for information-sharing, troubleshooting and joint provision of
security to traders and others. This strengthens the already good (but ad hoc)
interaction of border officials. Specifically, training sessions are held at
regional level (under COMESA coordination) for national trainers, who then
deliver country-specific trainings to traders and officials. The overall
purpose of this exercise is to ensure regional consistency on themes and
subjects covered in the national trainings – similarly, regional training
materials to be used in those sessions are prepared beforehand as a result of
border visits and local consultations.
- To sumup, at the regional level the project supports:
- Regional communication to raise awareness on the STR, and the COMESA Regulations on Minimum Standards for the Treatment of Small-Scale Cross-Border Traders, including their extension to trade in services.
- And strengthens Trade Information Desks (TIDs) to support and monitor implementation of the COMESA Regulations on Minimum Standards for the Treatment of Small-Scale Cross Border Traders. This entails close monitoring conducted at border-level by an ad-hoc COMESA TID Coordinator, along with overall supervision and regional backstopping provided by dedicated officials within the COMESA Headquarters.
- Regional training activities and coordination of national training sessions to support the policy and procedural reforms.