PVoC and Certificate of Conformity – how to prepare a container for East Africa?

Exporting used clothing to East Africa requires not only correctly preparing the container, but also smoothly going through the procedures linked to PVoC – the pre-shipment inspection of used clothing and other goods – and obtaining a Certificate of Conformity. How should a shipment and its documentation be prepared to limit the risk of errors and problems, and, as a result, pass the conformity check correctly in Kenya, Tanzania, Uganda or other East African countries?

• When planning used clothing exports to Africa, check the requirements, standards and procedures in force in the chosen country.
• Before loading the container, check the Pre-Export Verification of Conformity procedures for used clothing and find out how to obtain a Certificate of Conformity.
• It is essential to prepare the documentation correctly – the Commercial Invoice, Packing List, PVoC documentation and other required documents, together with the container's actual contents, must all match.

What is PVoC – Pre-Export Verification of Conformity?

Pre-Export Verification of Conformity, or PVoC for short, is a procedure for verifying goods before they are exported to a given country. Its purpose is to check whether imported products meet the technical, quality, safety and other regulatory requirements in force in the destination country. In practice, PVoC most often includes document verification, a pre-shipment inspection of the goods, and an assessment of the goods' conformity with the applicable standards and regulations.

The PVoC procedure is designed to limit the risk of products entering the market that do not meet local requirements. It is worth noting that PVoC is not a single, universal procedure applied identically across all of East Africa – each country may have its own specific requirements.

Certificate of Conformity (CoC) – what is it and what is it for?

A Certificate of Conformity is a document confirming that a given shipment or batch of products meets the technical and regulatory requirements in force in the destination market. In countries where a PVoC program operates, obtaining a CoC is one of the key steps in preparing goods for export.

Certificate of Conformity – used clothing

A CoC confirms that a product has undergone the required conformity assessment procedure and meets the applicable standards, regulations or technical requirements. As part of the procedure, elements such as technical documents, laboratory test results, declarations of conformity, product labelling and many other factors may be reviewed. For used clothing, this mainly means assessing the quality, condition and category of the goods. This is because African countries guard against the import of clothing that could pose a health risk, such as used underwear or used hospital clothing, as well as against the import of goods that amount to waste, such as heavily worn and stained clothing unfit for use.

What information appears on a Certificate of Conformity?

A conformity certificate can differ slightly between documents issued for individual countries, but it generally contains data such as:

• exporter and manufacturer details,
• importer or consignee details,
• a description and identification of the products,
• the commercial invoice number,
• information on the quantity and value of the shipment,
• the HS code or codes,
• information on the standards and requirements applied,
• the certificate number or identifier,
• information on the inspection or tests carried out,
• the date the document was issued,
• details of the body that carried out the conformity assessment.

It is worth making sure that the data relating to the goods is consistent across all documents, including the Commercial Invoice and Packing List, since any inconsistencies can complicate the transport and container-clearance formalities.

It is also important that a CoC does not replace standard commercial documentation or the documents required for customs clearance. It is only one element of the whole export documentation package.

When should a CoC be obtained?

If the destination country's regulations require obtaining a Certificate of Conformity as part of the PVoC procedure, this process should be planned before the goods are shipped. Starting the procedure too late, or skipping it altogether, can result in delays to the export, the need for additional steps, or problems during import clearance. The most serious consequences of a container lacking the required PVoC certificate include financial penalties, a detailed inspection at the importer's expense, and having the goods sent back to the country of dispatch or destroyed at the exporter's expense.

Kenya, Tanzania, Uganda and other East African markets – is the procedure the same?

Although Kenya, Tanzania and Uganda belong to the same East African region, the requirements for importing used clothing are not identical. Each of these countries has its own conformity-control system, its own standards, and its own procedures for the documents required before goods can be placed on the market.

Generally, in all three cases the basis is a PVoC procedure carried out in the exporting country by designated control agents, on the basis of which a CoC can be obtained. The differences, while significant, are relatively small. For example, Kenya and Uganda apply conformity-certificate procedures to all used clothing, while Tanzania requires such procedures only for selected HS codes. Another difference is that Kenya requires an inspection covering not just the goods themselves but also the way they are sorted and packed, which is not taken into account in Tanzania or Uganda. Meanwhile, in the absence of a CoC, Uganda and Tanzania provide for an inspection at the destination at the importer's expense, plus an additional surcharge of 15% of the CIF duty on goods covered by PVoC, whereas Kenya does not apply this as a standard procedure.

Do the other East African markets operate the same way as Tanzania, Kenya and Uganda?
It is worth knowing that some countries take a more restrictive approach to importing used clothing than others. Zimbabwe has a ban on importing second-hand clothing, except for entities holding special permits and meeting specific conditions. A ban on importing used clothing for resale also applies in Ethiopia. Rwanda and Burundi likewise impose very high barriers. Madagascar, Mozambique and Somalia, on the other hand, do not impose special restrictions on used clothing and treat it like any other imported goods. That is why, when planning exports to East Africa, it is necessary to verify each time which procedures apply in the specific country of interest.

Expanding international sales for used clothing wholesalers – what you need to know?

How to prepare goods for export to East Africa?

To run used clothing exports to East Africa, you need to start by establishing the destination country's requirements. Next, it is necessary to determine what will actually be in the container, eliminating items that are banned in specific markets, such as used underwear in Tanzania. HS codes then need to be established for the goods, or for their individual categories. For used clothing, HS 6309 is often used – the international customs classification code covering used clothing and other used articles – though it is worth verifying whether this classification is the right one in a given case, and whether that code makes the goods subject to the PVoC procedure. If the PVoC procedure is required, contact must be made with a company accredited as an inspector by the given country. Documentation such as the Commercial Invoice and Packing List – which will also be needed later during customs clearance – must already be ready at the content-inspection stage, along with the goods themselves for export. Once the CoC has been obtained, the container can be loaded and sealed. Only then can the container of used clothing set off for Africa.

Documentation needed for PVoC and obtaining a CoC

Preparing the documentation for exporting used clothing should begin even before the shipment is submitted for inspection. The documents must not only confirm the transaction but, above all, must allow the goods, their quantity, value, classification and the shipment subject to inspection to be identified unambiguously.

Export to East Africa – documentation

Broadly, the most important documents required for exporting used clothing to African countries are:

• the Commercial Invoice,
• the Packing List - specifying the shipment's contents,
• the PVoC declaration or application form,
• information on the HS code and description of the goods,
• documents on the origin of the goods, if required,
• documentation on sorting and packing, if required,
• other documents required by the relevant authority or PVoC agent.

Check the key information for a used clothing importer.

How to avoid inconsistencies between documents?

A common problem for exporters and importers is not missing documentation but inconsistent data. For example, this can mean using different HS data, entering a different weight for the goods or a different number of packages (usually bales), or using different terminology for the same clothing categories, and so on. It's enough to write „used clothing” in one document, „second-hand garments” in another, and „used textile products” in a third to create an inconsistency in the documentation, even though in theory each phrase means exactly the same thing. All such differences can lead to difficulties obtaining a CoC, delays during clearance, and additional costs. To avoid inconsistencies, it is therefore necessary to establish the shipment's basic data, keep the description of the goods unchanged across documents, verify that the Packing List matches the container's actual contents, check that the documents are uniform before submitting the PVoC application, and avoid making changes after the PVoC submission – and especially after the CoC has been obtained.

Common mistakes made by exporters

With used clothing exports to East Africa, any problems that arise usually stem not from the inspection itself but from inadequate preparation for the whole operation.

Starting the PVoC procedure too late

Starting the PVoC procedure too late is one of the situations frequently encountered. The inspection may include document verification, a physical check of the goods, and, in certain cases, testing and other steps. Starting it just before the planned loading increases the risk of a delayed shipment.

Shipping the goods before obtaining the required CoC

Obtaining a Certificate of Conformity cannot be treated as a purely formal matter that just rounds off the procedure. Trying to sort out this document only after the container has already sailed can mean it cannot be obtained at all, which will carry consequences, above all for the importer.

Differences between the documents and the container's actual contents

The description of the goods, the parties' details, the shipment's value, the number of bales, the container's weight and other data should be consistent across all the documentation, and at the same time consistent with the actual cargo. Any changes should be properly reflected by correcting the documents.

Incorrect marking of the goods

The markings on bulk packages, such as bales or other cargo units, should meet the requirements in force for the given product and market. For used clothing, information identifying the goods, as well as information on the sorting and packing method, is particularly important.

Assuming that all countries on a given continent have the same requirements and procedures

Assuming that all countries on, for example, the African continent have the same requirements and procedures is one of the riskiest shortcuts in thinking. The mere fact that an exporter has previously sent used clothing to one of these countries does not mean the same set of documents and the same procedure will apply for the next shipment to a different country. It is important to bear in mind that some countries allow the import of used clothing, some impose additional restrictions, and some ban this kind of activity altogether.

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