Namibia completes its first-ever Time Release Study (TRS) report for the Walvis Bay Port

At the beginning of December Namibia completed and launched its first-ever Time Release Study (TRS) report for the Walvis Bay Port. The report was prepared by a Technical Working Group made up of representatives from the Namibia Revenue Agency and different Ministries and other Government Agencies through the analysis of data extracted from the Customs Automated system (ASYCUDA World), complemented by a survey addressed to the private sector structured with the support of the World Customs Organization (WCO) whose form is annexed to the TRS. The Study provides a series of recommendation on how to improve the clearance process at the Walvis Bay port.

In particular, the TRS report informs that a benchmark analysis with the IT customs system of Zambia has shown that the functionalities of the Namibian Customs IT system are not used optimally. It therefore suggests to upgrade/enhance this system to make possible for declarants to self-assess their declarations with direct electronic submission of data to ASYCUDA World prior to the arrival of the vessel so that an assessment notice can be generated by the system that makes possible the activation of risk analysis based on the pre-arrival data communicated by the declarant. In this regard, the Study notes that the pre-clearance process (anticipated transmission of clearance information before the vessel arrives at the port), although implemented, is in practice underutilized at the port. Moreover, there is a lack of harmonized border processes amongst the different border agencies operating at the Walvis Bay Port. For instance, the Meat Board of Namibia can only issue permits upon arrival of the cargo in the port, as it does not have access to the Customs IT system in order to verify declarations submitted by traders with reference to imports of meat and meat products.

Time Release Studies (TRS) are a trade facilitation tool used to quantify the average times taken for the clearance of goods at the various entry locations in a certain country (e.g. ports, airports, land borders or road corridors). They aim at measuring the time required from the arrival of goods to their release, in an attempt to identify bottlenecks, delays and constraints in the clearance process, so that corrective actions can be implemented for improving its efficiency. TRS are recommended by WTO Trade Facilitation Agreement (TFA), whose article 7.6 encourages members to periodically measure and make available to all relevant stakeholders (publication) the average release time of goods. A provision that exactly mirrors art. 7.6 of the TFA is also contained in the AfCFTA agreement, that at Annex 4 to the Protocol on Trade in Goods (Article 12) encourages State Parties "to measure and publish their average release time of goods periodically and in a consistent manner, using tools such as the Time Release Study of the World Customs Organization", adding that (par. 2) "Each State Party may determine the scope and methodology of such average release time measurement in accordance with its needs and capacity.

To guide countries in their development, the World Customs Organization had developed a WCO TRS Guide which describes the methodology to be used in conducting these studies. Moreover, the WCO has developed a specific software (available only to WCO members) where countries can input data collected throuugh a web interface and produce statistical reports to be incorporated in the TRS. Currently, countries in Africa that have completed TRS are not many. They include Kenya, Zambia, Benin, Malawi, Eswatini, Togo, Cape Verde, Ghana and Nigeria, among others (even though the Ghanaian and Nigerian TRS have not yet published, despite the AfCFTA obliges to do so). COMESA launched in 2017, with a funding from the African Development Bank, a “regional” Time Release Study at selected border posts in 10 COMESA member States, while more recently, the Southern African Development Community (SADC), launched a similar regional TRS along its corridors to assess bottlenecks in the clearance of goods at crossing border posts in the region, in view of increasing their efficiency. On the other hand, the Northern Corridor undertook a corridor-level Time Release Study in 2016 to identify bottlenecks along this corridor between Mombasa (Kenya) and Kampala (Uganda).

Differently from “traditional” TRS, TRS “plus” (or TRS+) use an innovative approach which has been developed by the World Bank and implemented in some Southern Africa countries such as Eswatini and Zambia (not publicly available, in violation of art 12 of Annex 4 to the Protocol on Trade in Goods of the AfCFTA). Based on the WTO TRS methodology, the TRS plus approach, although not analytically described by the World Bank in a guide similar to the one adopted by the WCO, includes a measurement of time taken for pre-border processes (such as the time for obtaining certificates, licenses, and permits and for meeting Customs requirements to import or export), thereby providing a bigger picture of bottlenecks that affect the clearance time of goods. In practice, the TRS plus take into account also the delays caused by processes that need to be carried out long time before and are a condition for a customs transaction to be initiated.

For more details on TRS read this article.