Date: 02/03/2016

Trade Working Group Initial Meeting

On Wednesday, March 10, AmCham organized a very well attended and informative meeting on the topic of non-tariff barriers (NTBs) for import and export.

From the discussion at the meeting, it was evident that formation of a working group dealing with matters of foreign trade is very well based in the current needs of AmCham members.

Members present were representing food and beverage, chemical, pharma, recycling industry and retailers, and they have expressed concern regarding both import and export related ones (especially regarding export to BiH and Macedonia).

Most common issues discussed relate to:

Risk based analysis is far from implementation resulting in constant stoppages, analysis, sampling of the same products;
Lengthy and unpredictable procedures for quality assessment analysis, which are especially critical for the perishable foodstuffs: the issues being the procedure for sampling, identification of go to laboratories, deadlines for finalizing the analysis, lack of IT solutions enabling instantaneous delivery of results (causing additional delays) or relying on relevant updated data-bases;
Import /export licenses burdensome: argumentation focusing on the lengthy period for obtaining/renewing licenses in congruence with the short period of their validity;
Gaps in laws and/or implementing regulations allowing for arbitrary interpretations by the authorities, resulting in very different treatment depending on the inspectors, outposts etc. or different interpretations of implementing institutions
Lack of transparency of internal guidelines causing unpredictable outcomes for companies that are seeking to be compliant;
Overlaps or gaps in the competencies of different inspections: while some shipments can be sampled and checked for the same checkups twice (e.g. in accordance with the Law on plant health and Law on food safety), for some (e.g. biocidal products) there is significant compliance burden, but there is little or no checkup at the border;
Outdated regulations or lack of synchronization with EU rules – either both laws and by-laws or just implementing by-laws, leaving room for arbitrariness of inspectors in implementation.

It was also mentioned that companies could benefit from exchanging experiences among them, as well as on convening briefing sessions with the authorities, who would clarify unclear points.