Uganda, hub of substandard products: Can UNBS turn the tide?

Findings of a value-for-money audit undertaken on the effectiveness of interventions by the Uganda National Bureau of Standards (UNBS) to regulate the quality of locally manufactured goods, found that systemic challenges like budget constraints, lapses in policy and legislation, poor planning and understaffing, as well blatant inefficiency, have left Ugandans at the mercy of low-quality manufacturers as they consume what may be harmful products.

“Uganda’s manufacturing sector is flooded with substandard production, as more than half of goods in the domestic market are below quality standards. This proliferation of inferior products impacts consumer safety and the competitiveness of Ugandan goods regionally and globally,” the December 2023 report notes.

“The increase of substandard local goods also creates environmental issues for Uganda due to the market being flooded with unsafe or non-degradable materials. And overall, the lack of formal quality standards as an enforcement mechanism essentially renders government policy inactive and ineffective. Policies aimed at protecting consumer safety, enabling trade, and driving quality manufacturing remains ineffective as long as standards development and implementation continue to lag,” the report adds.

A survey conducted by the audit team on various locally produced goods in the categories of foods, drinks, beverages, and cosmetics, found that 77.4 percent did not display the Q mark indicating non-compliance with safety, health, or performance standards.
Twenty-six of the sampled products did not have any branding information. The survey, conducted across retail outlets and wholesale vendors, found the eastern region with the highest number of non-compliant goods, followed by northern, western, and central Uganda.

The absence of inspection at the border points, with only 32 out of 555 customs points manned by quality enforcement staff has also left the door open wide for substandard goods to flood the market
The worrying trend casts under the spotlight the UNBS, the principal body charged with ensuring the quality of goods, along with its parent, the Ministry of Trade and Cooperatives, which oversees policy, and associate enforcement agencies, including the Private Sector Foundation, Uganda Manufacturers Association, Uganda Revenue Authority (URA), as well at the law enforcement agencies like the police.

The UNBS was established in 1989 as the principal government agency to protect the health and safety of consumers by policing the quality of goods and preventing trade in substandard goods.
This is done through formulation, reviewing national standard specifications, enforcing the standards, testing products for conformity, and educating stakeholders about the standards.
While the Bureau, the AG notes, has been working hard developing and implementing several standards and carries out regular inspections and testing of goods, systemic challenges, including budget constraints, and gaps in policies and legislation, leave a lot to be desired.

UNBS, according to the audit that spanned four years, performed dismally in the development and enforcement of standards, and quality assurance, while certifications of goods also took absurdly elongated periods.

“The lack of adequate standards in Uganda has led to a reduction in the competitiveness and quality of locally manufactured products. Locally made goods struggle to compete with the influx of poor-quality imported items that often do not meet “fit for purpose” or value for money products. This results in Ugandan-produced products having limited access to external export markets, hindering the government’s strategic priority of increasing exports. Additionally, the public ends up exposed to unsafe, low-quality products in the domestic market as no minimum safety and performance criteria have been established through detailed standards,” the Auditor General notes.

The Auditor General also faulted the Ministry of Justice and Constitutional Affairs, as well as Parliament for sitting on key legislation like the UNBS Amendment Act 2013, Weights and Measures Amendment Act Cap 103 1965, Weights and Measures (Pattern Approval) Regulations, The Weights and Measures (static tanks) Rules, and Weights and Measures (water metre) Rules that would empower the Bureau to carry out its mandate more effectively.

“Despite the Bureau having in place adequate standards for regulation of the quality of services and manufactured products in Uganda, some critical gaps persist across legal frameworks and agencies like parliamentary counsel of Ministry of Justice and Constitutional Affairs in effectively regulating local good quality and safety. Laws have stalled, mandates unclear, standards setting slow and inadequate, consumer awareness lacking - all constraining purchase power to drive quality demands,” the report notes.

It adds: “Until laws and institutional roles are strengthened, standards development and consumer knowledge accelerated, enforcement capacity enhanced, and infrastructure upgraded, regulation of domestic manufactured goods will stay ineffective.”
In April, the acting executive director of UNBS, Mr Daniel Makayi, reported to the State Minister in-charge of Trade, Gen Wilson Mbadi, that the body was both underfunded and understaffed, operating at less than 50 percent capacity.
For example, there are only 36 staff out of the approved staffing of 123 staff for the Department of Standards, which means several requests for certification for testing of goods were not reviewed and acted upon.

However, away from systemic challenges, the trend of substandard goods has been exacerbated by blatant inefficiency. The AG notes: “Even where specific policies, laws, and regulations are relevant and, or appropriate, their enforcement is often weak. Some of the existing laws do not provide deterrent penalties, which increases the likelihood of non-compliance, among other causes.

There have been reports that UNBS is not doing enough to inspect manufacturing houses, but staff focus more on scouting shops and confiscating people’s goods.

In its annual report for the financial year ending June 2023, UNBS reported an increase in substandard goods, where approximately 5,707 metric tonnes of substandard products were seized, and 377 manufacturing facilities were sealed off for producing non-conforming products.
Most seizures were made in the central region, followed by the western region, while the northern and eastern regions registered the least seizures.

The year before, the Bureau seized and disposed of substandard goods worth Shs4.7 billion, including foodstuffs, cosmetics, and alcoholic beverages, among others.
In the same year, Kenya banned the importation of maize from Uganda after the Agriculture and Food Authority (AFA) found that maize from Uganda contained carcinogenic substances termed as aflatoxins.

In its third National Development Plan, Uganda is betting on manufacturing as one of the major pillars to drive development and uplift households out of poverty. Local manufacturing was planned to drive the import substitution agenda and improve terms of trade.
The expected results include an increased share of manufactured exports to total exports, growth in the industrial sector contribution to GDP, and an increased share of the labour force employed in the industrial sector. But standards have proved a major obstacle, with local goods denied market abroad.
Ugandan eggs, milk, and agricultural produce have been the most rejected due to poor standards. In May 2023, at least 62 trucks transporting maize grain into South Sudan were impounded by South Sudan’s National Bureau of Standards due to similar concerns.

The Auditor General reported that the UNBS did not meet its targets of developing 2,200 standards between 2020 and 2024, only developing 1,662.
The Bureau’s inefficiency is also reflected in the lengthy periods of development that stretch to 28 months as compared to the recommended 18 months. This leaves some goods without a sort of measurement to determine whether they are of quality or not.

“Based on the audit findings, the existing standards do not adequately provide for the manufacture of quality and safe products in Uganda. While UNBS has set targets to increase the standards inventory by 15 percent each year, the actual rate of new standards development has declined over the past four years - falling short of goals. Completion of new standards is also taking 10 months longer than the 18-month target,” the Auditor General reports.

The legal regime has also created a clash in mandate between different government agencies. For example, while the UNBS is charged with standardisation and ensuring the quality of all consumer goods manufactured in the country, the National Drug Authority (NDA) is also charged with ensuring the quality of drugs imported or produced in the country.
The UNBS and NDA specifically disagreed on the regulation of cosmetics, drugs and medical devices.
The clash has often led to reduced efficiency and effectiveness of the involved entities due to confusion about which entity should handle a particular concern and increased costs for businesses and manufacturers.

According to the Auditor General’s report, 67.7 percent of consumers lack awareness regarding crucial quality aspects, hindering their ability to make informed purchasing decisions and to drive demand for higher-quality domestic goods.
With a majority of end-users unaware of standards, their capacity to influence market improvements through consumption habits is restricted.

Another gap highlighted is UNBS' inability to calibrate measurement equipment, which forces companies to seek calibration services out of the country.
Delays in certification of products are also another sticking issue, with some applications taking more than 200 days compared to the audits for its certification applications, revealing outliers of more than 200 days, surpassing the recommended 30 days for this procedure consistently over the four years under study.
“The delays by UNBS in certifying company products have led to losses in the form of missed business opportunities for some Ugandan companies. With lengthy approval processes, companies are missing chances to grow, expand into new markets, and contribute to Uganda's economic development.

Additionally, there is a risk that international trade partners may perceive Uganda’s quality control and standards processes as unreliable, thereby undermining the reputation of Ugandan goods and services in foreign markets.
Its laboratories are also underwhelming and lack most-required equipment to determine the safety of foods, beverages, and cosmetics.
“The insufficient testing capabilities at UNBS laboratories mean there is a possibility that unsafe and defective products easily infiltrate consumer markets undetected. Without modern equipment for a comprehensive assessment of gases, GMOs, radioactivity and other threats in goods like food, beverages, and cosmetics, significant public health dangers and non-compliant commodities will ultimately reach Ugandan citizens through the observed gaps. Additionally, the insufficiency in the equipment also affects the turnaround time for tests hence affecting service delivery,” Auditor General’s report reads.
The Auditor General also faulted the UNBS for random inspections that leave out high-risk products and locations, as it lacks a market surveillance prioritisation plan or risk analysis reports to inform their market inspection work plans.

“The UNBS currently stores surveillance-related data in multiple disconnected spreadsheets, paper files, and individual computer drives. This makes it extremely difficult and labour-intensive for the market surveillance team to comprehensively compile, analyse, and extract insights from the various data sources outlined in the procedures. Without a single centralised and searchable platform to store test results, consumer complaints, former inspection records, and notifications, the team does not have the data readily available to conduct robust risk assessments and prioritisation. The data exists in silos, leading to random rather than risk-based planning,” the report notes. 

UNBS RESPONSE

Current situation

"The standards agency's mandate is to facilitate trade and industrial development, as well as protecting consumers. With the increased productivity of Ugandans involved in value-addition, more small-scale industries have grown. The demand for UNBS services have increased over the years by 80 percent and thus need for consumer protection. This requires UNBS to recruit more staff (currently operating below 50 percent of it's human resource structure requirements) and therefore the need for increased mobility of staff to undertake standardization work and budget facilitation to meet increased demand. Therefore the demand for and impact of UNBS work is high and the Bureau's capacity should be enhanced to match the emerging demands and needs. 

Section (2) subsection (1) (f) of the UNBS Act cap 210 mandates the UNBS to enforce standards in the protection of the public against harmful, dangerous, and substandard products, while Section 20 of the Act prohibits the manufacture, sale, distribution or holding for the purpose of selling any product that does not meet compulsory Uganda standards.
We urge all the local manufacturers, including the Micro Small, and Medium Enterprises (MSMEs) to apply and get UNBS certification and quality mark. We will not negotiate on the issue of substandard goods on the market. They are harmful to public health and safety and also affect the competitiveness of Uganda's products on the local, regional, and international market. We urge all Ugandans to support UNBS and collaborate in ensuring we have safe products on the market."

What is being done now
1. Decentralisation. We have set up regional testing laboratories to enable industries, especially start-ups, MSMEs, businesses, and the general 
public to access testing services without necessarily coming to Kampala where our main laboratories are currently located.
In Gulu, northern Uganda, the labs focus on testing vegetable oil seeds and the oil products, which are mainly grown in the region, in addition to other agricultural and other value-added products.
In Mbarara, western Uganda, the labs focus on dairy and dairy products, which are mainly produced in the region, in addition to other agricultural and other value-added products.
In Mbale, eastern Uganda, the labs focus on cereal and cereal products, fruits and vegetables, which are mainly grown in the region, in addition to other agricultural and other value-added products.
These regional labs are designed to assist the farmers and producers in those regions to access testing services that will help them increase value-addition, thereby stimulating industrial development, at the same time safeguarding consumers.

2. PVOC: The Inspection and Clearance
of Imports Regulation 2022, requires that goods covered by compulsory standards must be inspected in their country of origin before they are allowed on the market under the Pre-Export Verification of Conformity to Standards Programme (PVoC). All importers are advised to embrace the PVOC programme. The programme was put in place to protect the health and safety of consumers by substantially reducing the importation of substandard products into Uganda. Under this programme, all goods that fall under the compulsory Uganda standards are inspected in the country of origin or export and are issued with a Certificate of Conformity (COC) for general goods or Certificate of Roadworthiness (CRW) for used motor vehicles after passing the inspection.

3. Compulsory certification for all local products: The UNBS Certification Regulation 2021, requires all locally manufactured goods covered by compulsory standards to be certified and issued with the UNBS Distinctive Mark before they are allowed on the market. The list of goods covered by compulsory standards is available on the UNBS website: www.unbs.go.ug.

4. Digital Conformity Marking (DCM); to support the fight against substand ard products, UNBS introduced the Digital Conformity Marking (DCM) programme. This programme provides a track-and-trace mechanism for consumers, supermarkets, and other retail outlets to distinguish between gen- uinely certified and substandard commodities. The programme introduced technology that allows the public to use their phones to verify if a product is genuinely certified by UNBS. Business operators like supermarket owners, wholesalers, and retailers have a responsibility to ensure all products on their shelves are certified and safe for consumers.

The DCM programme involves issuing Digital Conformity Marks/Stamps to certified commodities, providing consumers with proof that the prod- ucts meet applicable standards and are safe for consumption
These stamps contain information such as product details, the standard under which it is assessed, certification
date, batch number, manufacturer's name, and more. Supermarket owners, consumers, and the public can use the Kakasa App to scan these stamps and verify product certification
Currently, the DCM programme is being piloted among three commodity categories of construction materials, electrical commodities, and cosmetics. Each digital conformity mark costs Shs21 and is expected to lower business costs, particularly for MSMEs, as manufacturers can order a number of marks matching their production volume.

5. UNBS focus is on the growth of the cottage industry/SMES:
To date, UNBS has witnessed growth in the certification of products by MSMES, with more than 45 percent of the total number of applications received annually for UNBS certification being by MSMES.
We are looking at increasing this MSME certification growth to over 80 percent in the next two to three years and this will improve the competitiveness of Uganda products on the domestic, regional, and continental market, spur economic growth, and consumer safety.

UNBS is working closely with key government programmes like the Parish Development Model, (PDM), Emyooga, the Private Sector Foundation Uganda, Uganda Small Scale Enterprises, and other development partners to build capacity and increase awareness on the benefits of certification to MSMEs across all value chains countrywide focusing on sectors like grain, pulses, bakery honey, beverages, oils, fresh fruits, fish, construction materials, among others.

6. Increased public awareness and consumer education to promote a quality culture among the population. Through this, the public can start demanding quality products and the perpetrators of substandard products will have no market."

Statement by Sylvia Kirabo, the head of public relations and marketing, and spokesperson of UNBS