EFTA,Turkey and EUROMED
AgreementsIsabelle Ramdoo, ECDPM
MEXA Workshop, 27 July 2012Labourdonnais Hotel
EU Trade Policy
1. European Free Trade Areaa) EFTA and the EUb)EFTA as a potential market
2. Turkeya)EU – Turkey Customs Unionb)Turkey Mauritius FTAc)Turkey safeguard on woven fabrics and apparel
3. Euromed Agreementsa)Tunisia – Morocco – Egypt
4. EU – South Africa : TDCA
Overview of Presentation
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1. EFTA and the EU
• The 4 EFTA countries are Iceland, Liechtenstein, Norway and Switzerland
• They signed an European Economic Area Agreement in 1994 with the EU, allowing them to participate in EU’s internal market
• It covers free movement of goods for industrial products. Tariff reductions are applicable for agriculture and fish and fish products
• EEA is not a customs union, and therefore each EFTA country applies its own rate of duty to all third countries.
European Free Trade Association
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Tariffs applied by EU Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preservedEEA 5.4% 7.2% 7.2%MFN 18.0% 24.0% 24.0%
EPA Mauritius 0.0% 0.0% 0.0%
EFTA as a potential market: trade relations with third countries
• EFTA has concluded 24 FTAs with a total of 33 partner countries and territories outside the EU: Albania, Canada, Chile, Colombia, Croatia, Egypt, the Gulf Cooperation Council (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the United Arab Emirates), Hong Kong, Israel, Jordan, Korea, Lebanon, Macedonia, Mexico, Montenegro, Morocco, Palestinian Authority, Peru, Serbia, Singapore, the Southern African Customs Union (Botswana, Lesotho, Namibia, South Africa and Swaziland), Tunisia, Turkey and Ukraine.
• Negotiations are on going with Bosnia, Central American States, India and Indonesia, Russia, Belarus and Kazakhstan. Negotiations are expected to be launched with Vietnam.
• EFTA has signed a Joint Declaration on Cooperation with Mauritius. This is not an FTA
• FTAs provides for free trade in industrial goods, including fish and other marine products; and tariff reductions in processed agricultural products;
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• Imports of textiles from selected EFTA countries :Norway
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Norway Yarn Cotton Fabric
Denim Fabric
T Shirts Cotton
T Shirts Man
madePull Wool
Pull Cotton Trousers Shirts
Cotton
Total imports ('€ 000) 2,543 109 27 105,447 148,432 2,520 138,633 146,051 73,272
China 1.5% 18.3% 18.5% 32.0% 34.1% 35.8% 61.3% 25.3% 41.0%Bangladesh 25.2% 13.1% 11.1% 5.8%
Turkey 14.4% 18.4% 7.1% 15.7% 6.7%Germany 48.6%
Italy 18.6% 18.5% 5.3% 12.6% 11.2% 2.0%tunisia 6.4%
Pakistan 6.0% India 5.1% 1.9% 2.8% 14.6%UK 13.0% 16.5%
Lithuania 12.1% 1.6% Peru 6.0% US 15.6%
Sweden 13.8% 3.7% 8.3%Hong Kong 18.0%
Tariffs applied by Norway on textile products
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Norway Tariffs Yarn Cotton
FabricDenim Fabric
T Shirts Cotton
T shirts man made
Pull wool Pull cotton Trousers Shirts
cotton
MFN 0.0% 0.0% 0.0% 10.7% 10.7% 10.7% 10.7% 10.7% 10.7%
GSP Rate (including
MRU)0.0% 0.0% 0.0% 10.7% 10.7% 10.7% 10.7% 0% 0%
LDCs 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Countries having FTAs with Norway
Egypt 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Morocco 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Peru 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Mexico 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
SACU 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Tunisia 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Turkey 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Norway GSP Scheme and Rules of Origin• GSP applies to all developing countriesCoverage:• Prepared or preserved fish benefit from 100% reduction from MFN• T-shirts, jerseys and pulls (Ch 61.09; 69.10) are excluded from GSP • Trousers and shirts (Ch 62) : GSP = 0%• LDCs have duty free, including from excluded products
General Rules- Change in tariff heading – i.e when all the imported materials (non-originating
materials) used are classified in a HS tariff heading (4 digits) different from the tariff heading under which the exported product is classified, except when specified in the specific rule
- Chapter 3 : fresh fish – wholly obtained;- Chapter 16: Canned tuna, prepared, preserved fish: fish to be wholly obtained.- Yarn: silk – manufacture from raw silk; - Woven fabric – manuf. from natural fibres (double stage transformation)- T shirts & pull (Ch 61) – Manufacture from natural fibres- Shirts (Ch 62) – Manufacture from yarn (double stage transformation)
-
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Value tolerance – 10% of ex works price (except where specified otherwise)
Cumulation: All countries must be GSP beneficiary; 3 types:1.Bilateral – with Norway2.Regional – between developing countries forming a regional grouping, at the request of the country and upon approval. 3.Diagonal – between Norway, EU and Switzerland and beneficiary country (except in Ch 1 – 24). It implies that materials originating in Norway, EU and Switzerland can be incorporated in goods produced in a GSP country, when the final product is exported to Norway, EU and Switzerland.
Derogation possible for LDCs only, if justified for economic development purposes
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Switzerland – Textile imports from main markets
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Switzerland Yarn Cotton Fabric
Denim Fabric
T Shirts Cotton
T Shirts Man made
Pull Wool
Pull Cotton Trousers Shirts
Cotton
Total imports (€ '000) 3,172 9,427 314 190,532 114,052 5,453 409,445 379,964 165,403
China 6.4% 4.5% 4.3% 8.0% 12.4% 11.2% 7.8%Bangladesh 9.2% 11.2% 8.4% 7.1%
Turkey 4.5% 4.5% 5.1% 3.4% 9.9%Germany 30.6% 11.6% 44.9% 38.7% 55.0% 26.4% 36.8% 29.2%
Italy 3.0% 44.1% 7.9% 6.0% 53.1% 12.4% 21.1%Belgium 13.7% France 22.5% 4.2% 3.7% 7.7% 5.7%
Madagascar 3.8% Japan 17.8% Spain 7.3%
Austria 13.5% India 4.8% 8.8% 4.5%
Pakistan 3.7% UK 5.8%
Denmark 26.5% Peru 4.0%
Estonia 19.1%
Tariffs applied by Switzerland: Note duties are specific
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Switzerland Yarn Cotton Fabric*
Denim Fabric*
T Shirts Cotton
T Shirts Man made
Pull Wool
Pull Cotton Trousers Shirts
Cotton
MFN Duty CHF 26 - 46/100 kg
CHF130/100 kg
CH 75/100 kg
CHF 152/100 kg
CHF 391/100 kg
CHF 306/100k
gCHF
120/100 kgCHF 182/100
kgCHF
200/100 kg
GSP CHF 13 23/100 kg
CHF 65/100 kg
CHF 37.5/100k
gCHF 76/100
kgCHF
195.5/100 kgCHF
153/100kg
CHF 60/100 kg
CHF 91/100 kg
CHF 100/100 kg
China MFN MFN MFN MFN MFN MFN MFN MFN MFNCountries having an FTA with Switzerland
Morocco 0 0 0 0 0 0 0 0 0Tunisia 0 0 0 0 0 0 0 0 0Turkey 0 0 0 0 0 0 0 0 0Egypt 0 0 0 0 0 0 0 0 0SACU 0 0 0 0 0 0 0 0 0
* for fabric, when manufactured from handlooms from Pak, Sri Lanka, India and China, Duty =0%
Rules of origin applied by Switzerland
• Since 2011, Swiss RoO for industrial products are identical to EU RoO; i.e differentiation between developing countries and LDCs
• For agricultural products (HS chapters 1 to 24), the rules of origin are specific to the Swiss GSP and apply the method of tariff heading change (HS 4-digit level) with the exception of four products, i.e. HS 1108 (starches), 1901 (malt extract), 1904 (cereal products), and 1905 (bread, pastry, cakes).
• General value tolerance: 15% ex-works price, with the exception of textile and clothing, where specific rules apply
Derogation possible for LDCs only, if justified for economic development purposes
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Cumulation:
- Bilateral, between Switzerland and beneficiary country;- Diagonal, with Norway, EU and Turkey (with Turkey, not yet in force) - limited to industrial products of HS Chapters 25-97- Regional – between countries belonging to same regional group provided that a request is made and approved by Switzerland and there is sufficient processing. Products of chapters 50 to 63 and HS 6401 to 6405 are excluded from regional cumulation .
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Imports from Norway and Switzerland – Fish and Fish products
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Norway
Fish fillets, fresh, frozen, chilled
Tuna, skip jack
fish prepared
and preserve
dTotal
imports (€’000)
49,917 10,649 31,503
China 34.4% Russia 13.9%
Thailand 12.3% 85.9% 0.3%Poland 6.8%
Faroe Isl 5.8% Vietnam 3.5% 4.8%
Italy 2.7% Philippines 2.5%
Portugal 1.0% Sweden 71.9%France 8.6%
Denmark 4.6%Japan 3.3%
Switzerland
Fish fillets, fresh, frozen, chilled
Tuna, skip jack
fish prepared
and preserved
Total Imports (€ ‘000) 79,270 8,509 16,779
Vietnam 17.2% Germany 10.6% 34.0% 16.2%
Denmanrk 9.2% 5.9%Russia 9.2% China 8.7% Italy 17.0% 15.9%Spain 36.8%
Morocco 7.4% France 2.5% 23.2%
Netherlands 16.8%
Tariffs applied by Switzerland and Norway
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Norway Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preservedMFN 0.0% 0.0% 0.0%
GSP Rate (including MRU) 0.0% 0.0% 0.0%LDCs 0.0% 0.0% 0.0%
Countries havinf FTA 0.0% 0.0% 0.0%
Switzerland Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preservedMFN None None CHF 0 -13.00/100kgGSP None None None
Countries having FTAs None None None
Rules of origin: fish fillets: Wholly obtainedTuna and prepared fish: fish must be wholly obtained
• A Customs Union between Turkey and the EU entered into force in December 1995.
• The scope of the customs union with Turkey is limited to industrial
products and processed agricultural products.
• Some products do not fall within the scope of the customs union: they remain subject to a preferential treatment based on origin. These are agricultural products and coal and steel
• In a nutshell: Turkey – EU CU covers textile and apparel but does not cover fish and fish products
2. TURKEY
1. EU – Turkey Customs Union
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T Shirts Cotton
T Shirts Man Made Trousers Pull
CottonShirts Cotton
Denim Fabric
Cotton Fabric Yarn Pull
Wool
Total Exports to world (€ '000)
1,951,195 1,102,113 1,034,069 674,244 494,457 316,756 53,916 6,170 5,241
EU 87.1% 82.1% 81.7% 86.0% 74.0% 35.5% 53.9% 84.5% 66.1%Hong Kong 8.3% Freezones 21.7% Morocco 4.3% Tunisia 17.9% Egypt 10.9% Russia 1.1% 2.8% 8.7%
US 0.9% 1.1% 4.3% Iraq 10.9%
Exports of Turkish textile products to main markets
Tariffs: duty free
Fish and fish products: Exports from Turkey to main marketsTariffs: Duty free
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Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preserved
Total Exports to world (€ '000) 43,720 291 6,190
EU 86.7% 55.3% 80.4%US 7.6% 20.3% 5.5%
Azerbaijan 13.0%
Rules of origin:For industrial products – Movement of goods within customs unions
is not based on their originating status but on the fact that they comply with provisions on free circulation
For agricultural products – pan-Euro-Mediterranean ProtocolVessel requirements (all conditions must be fulfilled):- Registration and flag- Ownership: 50% by nationals; or companies headquarted in Turkey
or EU where executive staff (managers, board members etc) must be nationals;
- Masters and officials are nationals- At least 75% of crew must be nationalsValue tolerance: 10% of ex-works price Derogation: None
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Cumulation: Simplification to cover, EU27, EFTA (Iceland, Liechtenstein
Mediterranean countries (Algeria, Egypt, Israel, Jordan, Lebanon, Morocco, Syria, Tunisia, Palestine, West Bank and Gaza) - 42 countries in total. Key elements:
- Bilateral cumulation – between EU and Turkey;
- Full cumulation between European Economic Area (EU27 + Iceland, Liechtenstein, Norway), Turkey, Algeria, Morocco, Tunisia
- Diagonal cumulation – with other Euro Med countries having FTAs among themselves and identical rules of origin
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1. Mauritius – Turkey FTAMauritius signed an trade agreement with Turkey in 2011. The Agreement
has not yet entered into force.
What has been obtained?
2. Turkey as a potential market
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Turkey Tariffs Yarn Cotton
FabricDenim Fabric
T Shirts Cotton
T shirts man made Pull wool Pull cotton Trousers Shirts
cottonMFN 3.8% 8% 8% 12% 12% 12% 12% 12% 12%GSP 3% 6.4% 6.4% 9.6% 9.6% 9.6% 9.6% 9.6% 9.6%
Mauritius FTA from date of
entry into force
0% 0% 0%25% per year
from entry into force of agreement
25% per year from entry
into force of agreement
0%25% per year
from entry into force of agreement
25% per year from entry
into force of agreement
25% per year from entry
into force of agreement
TurkeyFish fillets, fresh, frozen, chilled Tuna, skip jack
fish prepared and preserved
MFN 30% 80% 80%GSP N0 Preferences
Mauritius FTA 100% reduction on MFN on 100 KG
20% reduction on MFN (no quota limits)
50% reduction on MFN rate for 100 kg
Value tolerance: 15% ex works priceGeneral Derogation: possible for development purposesDerogation for tuna: annual quota of 3.000 tonnes for preserved tuna and
tuna loins and 2.000 tonnes for fish fillets (valid for 7 years, with possibility of renewal)
Vessels:Registration and flag requirements; and at least one of the following:- ownership: 50% national- Owned by companies with HO in country + 50 % ownership by nationals
Cumulation:BilateralDiagonal – as with EPA, Mauritius can source its products with Turkey or EU
or EPA countries, provided they are sufficiently processedWith neighbouring countries, provided a PTA is applicable, the RoO are
similar and countries have concluded an agreement on customs cooperation
Mauritius Turkey FTA – Rules of Origin
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Specific rules: Textiles
• Yarn – Manufacture from raw silk
• Fabric – single stage transformation – manufacture from yarn
• T Shirts and pullovers – single stage transformation - manufacture from fabric
• Trousers and Shirts – single stage transformation - manufacture from fabric
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• In January 2011, Turkey initiated safeguard procedures regarding imports of woven fabric and apparel
• Approved by Turkish Authorities in September 2011
• The safeguard currently applies to Mauritius but will be lifted as soon as the the FTA will enter into force
Special safeguard measure applicable on textiles
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Turkey special
safeguardCotton Fabric
Denim Fabric
T Shirts Cotton
T shirts man made Pull wool Pull cotton Trousers Shirts
cotton
MFN 8% 8% 12% 12% 12% 12% 12% 12%Countries
other than EU and FTA countries
MFN + 30%
MFN + 30%
MFN + 40% MFN + 40% MFN + 40% MFN + 40% MFN + 40% MFN + 40%
GSP MFN + 28%
MFN + 28%
MFN + 37% MFN + 37% MFN + 37% MFN + 37% MFN + 37% MFN + 37%
LDCs MFN + 21%
MFN + 21%
MFN + 27% MFN + 27% MFN + 27% MFN + 27% MFN + 27% MFN + 27%
3. EUROMED Agreements:
Case of Tunisia, Morocco and Egypt
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Key elements of the EU Med Agreements1. Coverage: Algeria, Egypt, Israel, Jordan, Lebanon, Morocco, Tunisia, Palestine,
Turkey, Syria (not signed)
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• Cover essentially trade in goods, being complemented with a number of additional negotiations to open up additional agricultural trade;
• Duty-free access to the EU for Med industrial products and around 80% of agricultural produce
• Common rules to allow cumulation of origin within the Euromed and beyond.
• Regional convention on PanEuroMed preferential rules of origin agreed in 2011
• However: proper implementation of the requires complete South-South FTA network
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Exports of selected textile products of Tunisia to main marketsTariffs: duty free on all selected products below
1. Tunisia
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Trousers T Shirts Cotton
T Shirts Man Made
Shirts Cotton
Pull cotton
Denim Fabric
Pull Wool
Cotton fabric Yarn
Total Exports to world (€
'000)495,427 276,907 100,246 60,256 53,344 35,681 22,873 24 48
EU 97.1% 99.8% 98.3% 99.3% 95.4% 42.7% 100.0% 0.0% 100.0%
Tuna, skip jack fish prepared and
preservedFish fillets, fresh,
frozen, chilled
Total Exports to world (€ '000) 2,789 792 111
EU 15.3% 99.9% 100.0%Libya 73.8% UAE 7.4%
Exports of selected textile products of Morocco to main marketsTariffs: Duty free on all selected products below
2. Morocco
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Trousers T Shirts Cotton
T Shirts Man Made
Shirts Cotton
Pull cotton
Denim Fabric
Pull Wool
Cotton fabric Yarn
Total Exports to world (€ '000)
273,888 189,384 82,744 71,126 43,162 29,050 922 538 19
EU 95.7% 98.8% 98.9% 98.7% 99.9% 98.3% 99.3% 86.6% 100.0%
Fish prepared and preserved Tuna, skipjack
Total Exports to world (€ '000) 83,213 2,484EU 92.1% 77.4%Syria 3.1% 10.3%Eq. Guinea 1.3% 9.4%
Exports of selected textile products of Egypt to main marketsTariffs: Duty free on selected products below
3. Egypt
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T Shirts Cotton
T Shirts Man Made Trousers Shirts
Cotton Yarn Pull Wool Pull cotton
Total Exports to world (€ '000) 246,712 42,450 135,314 31,137 2,476 65 84
EU 47.9% 50.8% 24.4% 68.9% 8.0% 9.2% 0.0%Turkey 4.5% 7.6% 82.0%
US 42.6% 43.6% 65.0% 28.3% 90.8% 95.2%
Egypt does not export fish and fish products (tuna, skipjack) to the EU. However, duty on tuna is 20.5%
Textile products: YarnManufacture from raw silk, natural fibres, chemicals or paper make
materialsValue tolerance: 10% weight of yarnFabricSingle stage transformation - Manufacture from yarn Value tolerance: 10% weight of fabricApparel:Double stage transformation – manufacture from yarnValue tolerance: 8% ex works price
Fish and fish products:Same as above for Turkey
A closer look at rules of origin in the Euromed Zone
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• Jordan, Morocco, Egypt and Tunisia have an FTA since 2006.• This FTA is based on their EUROMED agreement.• The RoO that apply are the EU RoO• This allows them to use the full cumulation principle, when
they export to the EU. It means that any of those four countries can source their inputs among themselves and export to the EU and still benefit from duty free access to the EU market.
Cumulation
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EU South Africa Trade relationshipTDCA
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• South Africa is the EU's largest trading partner in Africa• EU concluded a trade, development and cooperation agreement in 1999
Rules of originCumulation – Bilateral between SA and EUCumulation with ACP:- SACU – Any working or processing carried out within SACU shall be
considered as having been carried out in South Africa, when further worked or processed there
- Other ACP –Products acquire originating status in the Community or South Africa only when the value added there exceeds the value of the materials used originating in any one of the ACP States and when it has undergone sufficient working or processing. However, EPA RoO should apply between SA and ACP country. This is currently not the case.
Vessels (all):a. Registration and flag requirementsb. Ownership requirement : 50% (also for companies headquartered)c. Nationality requirement for masters and officialsd. Crew requirement: 75% should be nationals (c and d to be replaced by 50%
crew requirement once tariffs are reduced on fisheries)
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General value tolerance: 15% ex works price, except for products falling within chapter 3 and 24 (incl fish and fish products), where 10% ex works price
Specific rules:Fish and fish products: wholly obtained
Yarn: Manufacture from raw silk or natural fibres
Fabric: Single stage transformation – manufacture from yarn or natural fibres
T-shirts and pullovers: Double stage transformation – manufacture from yarn or natural fibres
Shirts and trousers: Double stage transformation – manufacture from yarn or natural fibres
Value tolerance: 10% weight of yarn
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Tariff applied to South Africa under TDCA
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Yarn Cotton Fabric
Denim Fabric
T Shirts Cotton
T Shirts Man made
Pull Wool
Pull Cotton Trousers
Tariff applied by EU under TDCA to South Africa
0% 0% 0% 0% 0% 0% 0% 0%
Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preserved
No preferences under TCDA - GSP applied 14.5% 20.5% 20.5%
Exports of selected textile products of South Africa to main markets
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T Shirts Cotton Trousers T Shirts
Man MadeShirts Cotton
Pull Cotton Pull Wool Denim
Fabric
Total Exports to world (€ '000) 4,615 4,334 2,818 2,109 254 220 165
EU 10.7% 13.2% 6.1% 4.9% 16.1% 4.5% 0.0%Zambia 11.7% 11.3% 17.1% 15.0% 27.6% 30.9%
Zimbabwe 10.9% 14.2% 12.5% 32.5% 9.4% 18.2%Mozambique 15.0% 18.6% 10.5%
Mauritius 8.7% 5.5% 5.5% 5.5% 14.6% 9.1% 81.2%DRC 10.8%
Angola 8.3% Kenya 26.8%
• South Africa is the largest trading partner of Mauritius in Africa
Imports from South Africa from main competitors in selected products
South Africa as a potential market
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South Africa YarnCotton Fabric
Denim Fabric
T Shirts Cotton
T Shirts Man made
Pull Wool
Pull Cotton Trousers
Shirts Cotton
Total imports 820 2,215 6,884 118,304 51,255 2,790 28,288 121,537 64,779Italy 6.0% 10.1% 1.0% China 15.2% 20.2% 45.4% 48.3% 68.4% 65.6% 62.7% 41.3%Turkey 76.8% 1.1% 0.9% 1.7%Austria 6.5% Bangladesh 3.9% 2.1% 3.6% 6.5% 11.0%Hong Kong 2.3% India 6.7% 8.6% 1.3% 1.8% 1.2% 8.6%Bulgaria 4.9% Mauritius 2.1% 58.1% 35.1% 28.1% 12.3% 52.2% 9.1% 18.9% 10.3%Mexico 3.2% Thailand 3.8% 3.2% Madagascar 2.2% 28.2% 9.8% 4.1% 17.0%Tanzania 1.0% Indonesia 2.9% 3.7%Vietnam 1.3%
South Africa imports from fish and fish products from main market
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South Africa Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preservedTotal imports 5,412 30,526 3,047
China 18.4% 23.5%Vietnam 15.0% Norway 23.7%
Mauritius 7.8% 0.2% Philippines 2.0%
UK Thailand 95.5% 10.7%Argentina 6.4%
Taipei 1.1% Indonesia 0.4%
Italy 0.2% Uruguay 41.8%
Duties applied by South Africa to SADC countries
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Yarn Cotton Fabric
Denim Fabric
T Shirts Cotton
T Shirts Man made
Pull Wool
Pull Cotton Trousers
MFN Rate 0% 22% 22% 45% 45% 45% 45% 45%
Duty applied to SADC countries 0% 0% 0% 0% 0% 0% 0% 0%
Fish fillets, fresh, frozen, chilled Tuna, skip jack fish prepared and
preserved
MFN Rate 25% 25% or $240 whicher is the highest $ 7.2 per tonne
Duty applied to SADC countries 0% 0% 0%
• Fish and Fish products: Wholly obtained
• Yarn: (51.06.10) – change in tariff heading
• Fabric: Single stage transformation – manufacture from yarn
• T Shirts and pullovers: Double stage transformation - manufacture from yarn
• Shirts and trousers: Double stage transformation - manufacture from yarn
SADC Rules of Origin
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