Uganda’s fish maw (enuni) exports drop

Fish maw (swim bladder) exports have dropped over three years; statistics by the Uganda Revenue Authority (URA) indicate.

Commissioner for Customs Abel Kagumire disclosed this on Thursday, November 30, 2023. He was appearing before the Agriculture, Animal Industries and Fisheries Committee chaired by Linda Auma Agnes (Lira City Woman MP, Indep).

Enuni is a local name for the swim bladder of a Nile perch fish. It is also known as emondo. Enuni is a valuable product with medicinal and economic value. It is sought after for its special qualities.

Increased export revenue

The slump however has not affected export revenue from fish maws which has risen from sh521 million to sh9.1 billion during the same period. 

According to Kagumire, this is attributed to an eight percent export levy that was slapped on the aforementioned product in 2021.

This followed an amendment of the Fish (Amendment) Bill two years ago.

“We have only collected Sh16billion from that period and customs value where we collected export levy was Sh632billion. So far the quantity is 1, 687,211kgs that has been exported,” he added.

Petition

His remarks come at a time when URA and fish maw traders represented by Charles Tebandeke are at loggerheads over related matters

“Under the Fisheries and Aquaculture Act, 2022 you’re required to have a technical committee to guide you on policy including taxes. What we are increasingly seeing is a lot of taxes imposed. Where are you picking guidance to make these policies without the Committee?” Tebandeke wondered.

“Government is just waking up with funny payment for movement permits, import, export, inspection without the committee to guide it,” he added.

Taxes

One of points of departure is the six percent withholding charge on persons importing goods into the country at a rate prescribed in Part 8 of the third Schedule.

Subsection five of the provision of the Act states that this does not apply to importations by organizations that lie in the exempt category.

However, according to Kagumire, there are mechanisms under which taxpayers can be exempted from this levy.

“The 6% tax which is withheld according to the Act is considered to have been paid by the payee and is credited against the tax which is assessed on the payee for the year in income in which the payment is made. So where the tax is withheld for the year of income together with any provisional tax paid under section 3 for that year and it exceeds the liability under an assessment for a taxpayer for that year, the excess is dealt with by the Commissioner under Section 113,” he elaborated.

“The tax payers who qualify and are compliant, always apply for either exemption from withholding tax while others apply for refunds. So there are two options, either you apply to be exempted or pay it, and then you claim for a refund if you exceed that amount in a year of income,” Kagumire added.

In a similar vein, the traders are unhappy over high import duty charges. It is understood that these are rooted in Article 12 of the East African Customs Union.

Apparently, any fish maws originating outside East Africa attract a charge of twenty-five percent but eliminates internal tariffs.

However, Kagumire intimated that in instances where the goods originate from the partner states with a certificate of origin and proof is adduced that it came from waterbodies within the region, they charge zero percent.

“Maybe I need to note that there are some countries in East Africa that have not yet signed the Common External Tariff. South Sudan, Democratic Republic of Congo, and recently Somalia. So when fish or any goods are coming from those countries even if they have a certificate of origin, the rate is at 25%,” he retorted.

Export levy

Another elephant in the living room is export levy that fish maw traders want significantly reduced.

This is collected as per Section 2 of the Fish (Amendment) Act of 2021 where the Fish Act was amended to insert Cap 30(a) that imposes a levy at the rate of 8% of the total value of fish maw that is exported out of Uganda.

Fish maw cost

A study by the Economic Policy Research Center (EPRC) in 2021 on the fish maw trade and challenges in Uganda established that a Nile perch swim bladder weighing a kilogram is capable of fetching $1000 (Sh3.7m) domestically and internationally.  

“So fish maw of varying sizes will fetch between $70-$90. Therefore, an export levy of 8% of the total value of fish maw exported from Uganda to us at URA we think is justified and necessary for tax revenue mobilization,” Kagumire concluded.  

The current Buvuma Islands MP Robert Migadde (NRM) pointed out that the last statement creates a fake impression.

“On average most of the fish maw exported doesn’t go to that higher value they are quoting. When you go to the fish factory, most of the fish is between 2-5kgs, which does not fetch. You may find only 10% of the fish which fetches that value in terms of the weight,” Migadde disagreed.

“Fish maw goes to China through smuggling; it is like a black market. Therefore, it is wrong for the URA to base on a value for smugglers. Actually, it goes through Hong Kong and then you see how to smuggle it to China but there is no serious market,” he added.