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(#8 / 2018 - 8 May 2018)
Kenya’s clothing (H61 & HS62) imports in 2016 were worth about US$1bn
Kenya’s worn clothing (HS6309) imports in 2016 were worth about US$131.7m
Kenya’s textiles (HS50 to HS60) imports in 2016 were worth about US$642m
The Ayka Addis Textile & Investment Group, whose debt is three-fold higher than its paid-up capital and has loands worth more than US$47.3m (1.3bn E-Br) from the Ethiopian government, is now going to build an integrated cotton processing plant in Ouagadougou (Burkina Faso). The new investment is estimated to be worth around US$200m. The company, which in 2010, inaugurated its Ethiopian plant (in Alemgena, 20km west of Addis Ababa) with an initial investment of US$140m has been making a loss since 2013. As at December 2015 the company had accumulated losses of US$67.6m (1.86bn E-Br) while having a paid-up capital of US$24.7m (678.89m E-Br). It currently employs around 7,000 workers in Ethiopia. READ HERE >>

The Uganda State Planning Minister has confirmed several tax proposals. The 2018 tax amendment bills have been tabled by the Minister of Finance, Planning & Economic Development and are currently being discussed in the Ugandan Parliament. One proposal concerns the imposition of an export levy of US$0.4 (about USh1,500) per kg of wheat, maize, rice and cotton. It is planned that this levy will generate about US$5.4m (USh20bn). READ HERE >>

A People for the Ethical Treatment of Animals (PETA) READ HERE>> video exposé of the mohair industry in South Africa has prompted several top international retailers, including Zara, H&M, Gap and Topshop, to discontinue selling mohair apparel products. South Africa is a source of more than 50% of the world’s mohair clip READ HERE >>

Its likely that these boycotts will not only affect South Africa’s mohair clip. Some of the mohair processed in South Africa originates from Lesotho. South African traders come to Lesotho buy the raw fiber from farmers and send it to South Africa where it is further processes and then exported. It will be interesting to see how many of these traders will now want the Lesotho government to issue origin certificates for the mohair sourced from its territory. Furthermore the abuses by a small number of South African farmers may have had done more longer term damage to the entire industry. For there are now also reports that some major retailers may phase-out the sale of all mohair products by 2020. READ HERE >>

The Eldoret-based Rivatex Company is about to launch another phase of a US$30m (3bn KeS) modernisation programme using a credit line facility provided by India. Building works have been completed – now spinning and weaving equipment is to be installed by an Indian firm ... Lakshmi Machine Works. Once completed, it should increase the company’s production capacity from 10,000 bales of cotton per annum to around 70,000 bales. It has been stated that the modernisation is expected to create 10,000 new jobs. It is unclear as to what types of textiles the resucitated plant will be producing. Previously the Rivatex managing director has advised that the company had partnered with the Bura Irrigation Scheme to increase the firm's supply of cotton. At one stage the plant had been used as a textile training facility after it had been purchased by Moi University. READ HERE >> and READ HERE >>

Egypt’s exports of clothes jumped 17% in the first quarter of 2018, recording US$385m (LE 6.77bn), compared to US$330 million during the same period of 2017, the Egyptian Ready Made Garments Export Council revealed. US businesses bought 48% of Egypt’s ready-made garments exports in the first quarter of 2018 (worth US$185 million, compared to US$160 million in the same period of 2017 ... a 16% increase). Egypt is now eyeing the South African market place - it has high hopes that its apparel may be able to penetrate this market as soon as the Africa Continental Free Trade Agreement (AfCFTA) is fully operationalised. READ HERE >>

Major retailers are backing the Cotton Egypt Association’s (CEA) drive to rid the supply chain of falsely labelled Egyptian Cotton goods. John Lewis and Dunelm, have voiced support for CEA’s new rigorous accreditation process and ability to DNA test products. READ HERE>>


The Fashion Revolution has published its 2018 "Fashion Transparency Index". In their index they have ranked 150 of the biggest global fashion brands and retailers according to how much they disclose about their social and environmental policies, practices and impact. Many of these apparel brands and retailers source product from Africa. Adidas and Reebok top the Index again this year scoring 58% or 144.5 out of 250 possible points followed by Puma, H&M, Esprit, Banana Republic, Gap, Old Navy, C&A and Marks & Spencer in the 51-60% range. The mean average score amongst all 150 brands and retailers is 52 (21%) out of 250 possible points. According to the Fashion Revolution too many big brands and retailers continue to lack transparency. READ HERE >>


The South African Revenue Services (SARS) released - in mid April 2018 a mere 13 days after the end of its annual financial year - data related to the amount of goods seized by its Customs & Excise division, for the period 1 April 2017 to 31 March 2018 (for the full press release READ HERE >>). SARS' summarised its interceptions in the following manner.
Source: South African Revenue Services (SARS Press Release - 13 April 2018 SEE HERE >>

The "African Cotton, Textiles & Apparel Monitor" (ACTAM) requested that SARS clarify the data that it had presented in its mid-April 2018 press release. Below are ACTAM's questions and SARS' responses.
"Counterfeit clothing, footwear & other goods: 1,698 busts valued at R1,811,678,633" (US$144.3m)

ACTAM: Can SARS identify the kinds of goods that fall into the category “other goods"?
SARS: Typically retail clothing outlets refer to this as Accessories such as handbags, scarves, wallets, purses, buckles, belts etc. The Harmonized System is an international nomenclature for the classification of products. It allows participating countries to classify traded goods on a common basis for customs purposes. The coding is determined by department of trade and industry." SARS also mentioned that items falling into the "other goods" category would include products such as 'wrist-watches, cell phone accessories, caps, hats, jewelry, sunglasses, and DVDs'.

ACTAM: Can SARS provide a breakdown of this broad category, namely the value of the counterfeit: i) clothing seized – also how many "busts" was this? ii) footwear seized – also how many "busts" was this?
SARS: i) counterfeit clothing seized - 243 busts, valued at R133,812,640 (US$10.7m) ii) counterfeit footwear seized - 754 busts, valued at R217,370 230 (US$17.3m).
ACTAM Editor NOTE: This clarification significantly reduces the implied claim that clothing and footwear seizures were the key counterfeit items smuggled - in total approximately R351m (US$28m) of clothing and footwear were detained - out of R1.8bn (US$143m) counterfeit goods detained altogether.

ACTAM: Of the clothing and footwear seized what has become of these goods? Claimed by the legitimate brand holder? Destroyed by SARS? Disposed of by SARS by other means?
SARS: Subject to the provisions of the Counterfeit Goods Act, the Customs Authority is empowered to seize and detain counterfeit or suspected counterfeit goods whilst performing their duties under the Act. This in effect limits the area of operation of the Customs Authority to the time of importation / exportation / removal in transit and on goods that are under Customs Control in a Customs and Excise Warehouse. After the goods have been confirmed to be counterfeit, they are taken from the State warehouse to the Counterfeit depot by the brand holder attorneys for the purpose of destruction.
"Clothing and Textiles (second hand and other infringements): 51 busts valued at R76,860,835" (US$6.1m)

ACTAM: Can SARS provide a breakdown of this category, namely the value of: i) seized clothing (HS61+HS62), ii) seized textiles (H50 to HS60), iii) seized made-up textiles (HS63 – excluding second-hand/worn clothing & footwear under HS6309), iv) seized second-hand/worn clothing and footwear items (HS6309), v) seized footwear (HS64) [Editor Note: the SARS' statement makes no mention of footwear].
SARS: In the period provided SARS cannot provide a detailed breakdown, we would need to physically validate across all our warehouses and then provide such detail. However, what we can say is that this involved 4,925,644 items compared to 178,883 items the previous financial year. This 2,653.56% improvement is due to SARS’ significant focus on the clothing and textile sector over the past year.

ACTAM: Can SARS specify what penalties have been paid, by the importers, in respect of these seizures?
SARS: Counterfeit and second-hand clothing are classified as prohibited and restricted goods therefore, we do not levy any penalties on seized prohibited and restricted goods. The act of seizure by Customs on such goods is by implication regarded as a form of a penalty.

ACTAM: With regards the R76,860,835 (US$6.1m) worth of goods being seized – what has happened to these goods? E.g. destroyed? disposed of by other means? still in SARS' possession as it constitutes evidence?
SARS: Goods which are seized and those cases not yet finalised are still kept in the state warehouse as evidence. Only once the case is finalised can they either be destroyed or put up for auction depending on the conditions of sale as per the Policy. SARS then provided addtional notes:
A distinction should be drawn between seizures and detentions. A detention is a holding process to allow for further investigation. Seizure takes place after goods have been established to have been dealt with in contravention of the Customs and Excise Act. Also, even if goods have been seized (or forfeited) the owner can make representations for the return of the goods, which can take place if good cause is shown, ownership is proved and certain conditions placed by us are met. This could include the payment of duties and payment of an amount in lieu of forfeiture. The exception to this is obviously counterfeit goods and second hand clothing which require a permit. Clothing, textiles and footwear, whether new or used, can never be sold on the local market. They can be auctioned for export away from the African continent only or destroyed. The only goods allowed for local use are donated goods which are further regulated by policies in terms of quantity and value and they have to comply to conditions set out for donated goods.


Starting on 1 May 2018, and continuing throughout 2018, the Netherlands based Clean Clothes Campaign (CCC) says it will place a spotlight on H&M - starting at the corporation's Annual General Meeting which is scheduled to be held on 8 May 2018.

According to the CCC: "Back in 2013 H&M announced that 850,000 workers would be paid a fair living wage by 2018. Instead of that materialising on workers’ pay slips, however, the goal itself has disappeared from H&M’s corporate communication, just as the original documents have disappeared from the brand’s website. H&M corporate communication now refers only to the introduction of the Fair Wage Method by supplier factories. The 850,000 workers and their actual incomes are no longer a part of the picture."

"The proposal to discuss the unfullfiled living wage commitment at the AGM on 8 May as part of the formal agenda was not taken on board. That is despite the fact that H&M benefited from the positive reception of that commitment in the media and among the socially conscious consumers; failing all those workers would undoubtedly harm H&M’s reputation. That is something that shareholders would typically be wary of, even if the company reports a 2.6 billion USD profit, as H&M did for 2017.

"Clean Clothes Campaign has repeatedly, yet unsuccessfully, called upon H&M to clearly state a living wage benchmark and to publish other concrete information that would enable a meaningful assessment of efforts in the area of living wage. Dominique Muller of Labour Behind the Label (Clean Clothes Campaign UK) said: “A brand that is shouting its supposed commitments off rooftops and is receiving a lot of credit for this must clearly and publicly demonstrate measurable and verifiable progress towards real change. What H&M keeps presenting us with instead is a lot of vague, opaque and ultimately meaningless posturing”."

Source: CCC press release of & May 2018 "Ahead of the AGM H&M called out for turning its back on the living wage commitment". The CCC has also launched a dedicated website related to its “Turn Around H&M” campaign. SEE HERE >>

The issue of H&M and its fair living wage initiative was covered in the “African, Cotton, Textiles & Apparel Monitor” newsletter #3 of 3 April 2018. SEE HERE>>

While the CCC has not mentioned Ethiopia in its current H&M campaign – it will only be a matter of time before the CCC focusses on the typical wages paid to production workers at H&M’s Ethiopian vendor factories.

Its known that one former key staffer of the CCC visited Ethiopia a couple of years back to look at any companies that may be making garments for Dutch apparel brands/retailers. READ HERE >>

In its 2016 “Sustainability ReportREAD HERE >> (pg77) H&M revealed the comparative wages paid to workers who made garments for it in factories around the world. The wages paid to workers in Ethiopian factories then wer, by far, the lowest paid out of any of the other countries that they sourced product from. H&M tried to contextualise the low Ethiopian wages paid by indicating that their vendors typically paid wages of US$44 per month when the Ethiopian minimum wage was US$26 per month - this completely ignoring the fact that Ethiopia does not have a system of minimum wages!

H&M is obviously cognizant that the issue of wages paid in Ethiopia could be a hot potato. They have, together with the Swedish International Development Agency (SIDA), already contributed to a funding pot which will enable the International Labour Organisation (ILO) to investigate the issue of minimum wages in Ethiopia SEE HERE >> (one of the sub-elements of this funding was a study on minimum wages in Ethiopia - the terms of reference for this study can be SEEN HERE >>).

How H&M responds to CCC pressure will be interesting – especially in Ethiopia. If its Ethiopian vendors pay better wages – its highly likely that some of the more skilled workers engaged at other Ethiopian factories will leave them and flock to H&M manufacturers. This is what happened in Lesotho when companies paid more thatn the statutory minimum; and when companies constantly offered workers more overtime work opportunities. This will not make other brands/retailers feel particularly comfortable when the labour market starts to work in favour of employees - for one of the prime reasons they set-up in Ethiopia in the first place was because of the low wages that could be paid.

No doubt some old debates in some Ethiopian industrial parks will resurface. Apparently, some time ago, one proposal put forward by an industrialist was that if any worker resigned from one company in the industrial park where they were located that this worker should not be allowed to work at any other garment manufacturing facility in that same industrial park. Fortunately this proposal was shot down.

It can, going forward, be predicted that there will be all sorts of obfuscation with regards the quantum of wages paid in Ethiopia. Some manufacturers and their buyer brands / retailers will start to finesse the level of the wages that they pay by including all sorts of other worker 'expenses' and earnings to bump-up the wage – items such as transport and meal allowances, the value of paid annual leave and public holidays, as well as the average extra income earned through productivity incentive schemes and overtime work, etc may start to be included in public information on how much a typical Ethiopian worker get paid.

There are interesting times ahead!


The main incentives available to textile and apparel investors are for those located in Kenya's Export Processing Zones (EPZ - which fall under the jurisdiction of the Export Processing Zones Authority ... a state corporation under the Kenya Ministry of Industry, Trade & Cooperatives). SEE HERE >>

Kenya's core EPZ incentives are:
  • 10 year corporate income tax holiday, and a 25% tax rate for a further 10 years thereafter
  • 10 year withholding tax holiday on dividends and other remittances to non-resident parties
  • perpetual exemption from VAT and customs import duty on inputs – raw materials, machinery, office equipment, certain petroleum fuel for boilers and generators, building materials, other supplies. VAT exemption also applies on local purchases of goods and services supplied by companies in the Kenyan customs territory or domestic market. Motor vehicles which do not remain within the zone are not eligible for tax exemption
  • perpetual exemption from payment of stamp duty on legal instruments
  • 100% investment deduction on new investment in EPZ buildings and machinery, applicable over 20 years
  • an industrial deduction - 2.5% capital deduction applicable within the first 40 years of operation - to cover capital expenditure incurred by a person on the construction of an industrial building to be used in a business carried out by them or their lessee. This allowance is claimed by the person who incurred the capital expenditure i.e. the owner of the building and the building must be used for the purpose of the business only so as to enjoy the industrial building deduction.
Source: Kenya Investment Authority (KenInvest) and MORE HERE >>

This booklet, funded by the UK's Department for International Development (DFID) provides a succinct overview of the incentives available. READ HERE >>

A range of other investment incentives, both fiscal and non fiscal, are available in Kenya to those enterprises outside of an EPZ - these are mainly provided for in terms of the Kenya Income Tax Act.

The package investment incentives offered by Kenya and by Ethiopia have been successful in attracting investors. Recent incentive regime improvements by Kenya will undoubtedly attract additional value chain (and associated) investors.

The issue of incentives offered by these two countries will raise some challenges for other sub-Saharan African nations who want to develop significant textile and apparel manufacturing industries - notably Tanzania, Lesotho, Swaziland and Botswana. It is unfortunate that many of the political decision makers in these countries have bought into a (ultra-) conservative brand of development economics whose general mantra is - "you do not need industrial incentives; introduce a lower tax rates for all businesses; and improve your doing business environment" and your country will prosper.

This economic conservatism, often peddled by the IMF and some World Bank types, will leave many textile and apparel aspirant nations trailing. With some countries in Africa offering incentives targetting textile / apparel / footwear / leather product incentives and others that do not it is clear that those that do not will be at a disadvantage.

I find it ironic that when capitalism went though severe stress in 2008 (the "global financial crisis") that the IMF found that incentives were necessary then (they even conjured up pots of money to fund incentives) - but generally not now! Of course this is not to say that a policy of throwing incentive - either in cash or on a tax revenue forgone basis - at investors is going to be a magical panacea.

In my view incentive programmes should be developed that will build industries in a country / geographic area of a country (in other words effective clusters); incentives should also ensure that enterprises that receive them should become progressively more competitive in terms of the products that they make - improvements in the quality and the quantity of the items produced; and, perhaps, progessively making higher value add products. If these issues are not nuanced - all it will mean is that manufacturers remain hooked on incentives like addicts that are hooked on prescription and other drugs.

Care must also be taken that new incentive schemes do not unfairly disadvantage investors that are already in a country where the incentives are being handed out. Of course any incentive regime should be properly costed, and underpinned by a set of well defined and transparent rules - for without this corruption is bound to rear its head.

Clearly though incentives are not the only things that attract investors. Governmebts should ensure that a functional business environment that allows manufacturing to easily take place develops (and I am not talking here about greater labour market flexibility - something that certain elements of the World Bank are now raising). Governments also need to ensure that there is sufficient and effective public industrial infrastructure in the form of adequate and reasonably costed power, water, industrial waste water treatment, landfills, etc. Governments will also need to work out arrangements that will enable investors to have adequate industrial structures that they can rent. And, of course - any nation's trade policies and practices must also ensure that trade agreements and trade preference programmes are nurtured.
In the period 1 January 2018 to 31 March 2018 the US bound apparel exports of Africa's four largest exporters could be (approximately) broken down as follows:
Egypt: Not eligible for trade preferences in terms if the US' African Growth & Opportunity Act (AGOA). US$90.4m worth of cotton apparel; US$106.6m worth of man made fiber apparel; and US$6.25m worth of woollen garments. In 2017 Egypt exported cotton garments worth US$79.2m to the US; man made fibre garments worth US$383.8m to the US; and, woollen garments worth US$22.6m to the US.

Kenya: Eligible for AGOA. US$42.9m worth of cotton apparel; and US$46m worth of man made fiber apparel. In 2017 Kenya exported cotton garments worth US$153m to the US; and, man made fibre garments worth US$185.3m to the US.

Lesotho: Eligible for AGOA. US$16.9m worth of cotton apparel; and US$55.5m worth of man made fiber apparel. In 2017 Lesotho exported cotton garments worth US$97.5m to the US; and, man made fibre garments worth US$192.9m to the US.

Madagascar: Eligible for AGOA. US$24.4m worth of cotton apparel; and US$18.1m worth of man made fiber apparel. In 2017 Madagascar exported cotton garments worth US$74.4m to the US; and, man made fibre garments worth US$81.8m to the US.

Source: US Office of Textiles & Apparel (OTEXA) "Major Shipper Reports" (US import data released on 6 May 2018).
Kenya’s Window of Opportunity in Manufacturing is Open: Hela Garments”. Dirk Willem te Velde. Programme Director – Supporting Economic Transformation (SET). April 2018. London, United Kingdom. SET is funded by the UK Department for International Development (DFID).

Synopsis: Over the past two decades, many low-income countries have faced major challenges in developing their manufacturing sector. In much of Africa, the share of the sector in gross domestic product has declined or barely changed in the past two decades (although there are also some examples of success, and in absolute terms manufacturing production doubled in a decade). The value of preferential market access has been under erosion, and jobless industrialisation is increasingly a reality. UK-owned Hela Clothing located in the Athi River Export Processing Zone (EPZ) (close to Nairobi, Kenya) shows that it is still possible to establish a major labour-intensive factory in Africa. They have exported $40 million (equivalent to around 10% of Kenya’s garments exports) within one year and have already created 4,000 jobs directly. The mini report can be accessed HERE >>.

Strengthening the Cotton, Textile & Apparel Value Chain in East Africa: An Assessment” East African Trade Hub (EATH) for the US Agency for International Development (USAID). 2014. Nairobi, Kenya.

Synopsis: The study evaluates the cotton, textile and apparel value chain throughout the East Africa region, it identifies its constraints and provides recommendations on key interventions to strengthen the entire pipeline. In addition to providing a reference for USAID/East Africa programming, the study’s findings and recommendations can provide a guide for bilateral programs and initiatives, especially those with economic growth and food security objectives. The full report can be accessed HERE >>.
  • Africa Occupational Safety & Health (A-OSH) - Trade Show - 22-24 May 2018. Johannesburg, South Africa. For more information:
  • Source Africa - Trade Show - 20-21 June 2018. Cape Town, South Africa. For more information:
  • 14th Symposium of the Southern & East Africa Cotton Forum - Workshop - 4-6 July 2018. Harare, Zimbabwe. For more information: SEACF
  • Apparel Sourcing New York - Trade Show - 23-25 July 2018. New York, United States. For more information:
  • Sourcing at Magic - Trade Show - 12-15 August 2018. Las Vegas, United States. For more information:
  • International Textile Manufacturers' Federation (ITMF) - Annual Conference - 7-9 September 2018. Nairobi, Kenya. For more information:
  • Origin Africa – Trade Show - 9-11 September 2018. Nairobi, Kenya. For more information:
  • Apparel Sourcing Paris - Trade Show - 17-20 September 2018. Paris, France. For more information:
  • Africa Sourcing & Fashion Week (ASFW) - Trade Show - 1-4 October 2018. Addis Ababa, Ethiopia. For more information:
  • Textile Exchange Sustainability Conference - Annual Conference - 22-24 October 2018. Milan, Italy. For more Information:
  • Destination Africa - Trade Show - 17-19 November 2018. Cairo, Egypt. For more information:
  • ATF Expo - Trade Show - 20-23 November 2018. Cape Town, South Africa. For more information:
  • 77th Plenary Meeting - International Cotton Advisory Committee (ICAC) - Annual Conference - 2-7 December 2018. Abidjan, Ivory Coast. For more information:
Looking for staff? Want to engage a consultant? Have equipment to sell? Do you need 2nd hand machinery? Have a tender? For a limited period the "African Cotton, Textiles & Apparel Monitor" will publish (free of charge) select classified advertisements from firms / development organisations active in the Africa's crop to shop value chain. Adverts limited to 50 words / 300 characters (and may include a mini logo).
about Mark Bennett - Editor
"The African Cotton, Textiles & Apparel Monitor"
I have almost 30 years' experience working in Africa's cotton, textiles and apparel value chain. Initially I was, for 15 years, a sector trade unionist in South Africa; then, from 2004 onwards, I worked as a development consultant for various Southern / Eastern African governments, and domestic private sectors. In my development activities I have been engaged by private sector foundations, and by DFID and USAID funded contractors. I find it rewarding creating development interventions that help cotton, textiles and apparel stakeholders to better processes, improve productivity, increase sales and add investment. See my full CV at Devex or LinkedIn.
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