A clear lesson from previous trade facilitation projects is that improvements ininfrastructure need to be accompanied by policy and procedural reforms and capacitybuilding.

This Component will cover such reforms and capacity building efforts to improve the efficiency, capacity and security of border operations at the border crossings identified in Component 1. These reforms will be supported under three main Sub-components described below. The first two Sub-components will be implemented at national levels, while the third Sub-component will be implemented at the regional level in the three project countries.

Sub-component 2.1. Support for implementation of policy and procedural reforms at the targeted border crossings (US$3.4 million)

This Sub-component will focus on basic rights and obligations for both traders and officials and the consistent application of simple rules at the border.
The Component will support the 3 countries to:

1. (i) implement the COMESA Regulations on the Minimum Standards for the Treatment of Small-Scale Cross-Border Traders (COMESA Regulations) tailored to reflect the specific challenges (including institutional reforms required in specific cases) faced by smallscaletraders at the targeted border crossings. The COMESA Regulations are based on thelanguage and key principles of the Charter for Cross-Border Traders that enshrines a  basic set of rights and obligations for traders and officials and aims to improve behaviorat borders and to promote the gradual formalization of informal cross-border trade.Initially developed to facilitate trade in goods, the current version of the Charter includes both trade in goods and trade in services.12 The project will establish citizen engagement mechanisms, including through a toll-free hotline which will allow traders to report harassment and seek information on regulations and border procedures,
2. (ii) Extend the COMESA Regulations to small-scale trade in services by simplifying and making transparent immigration and health related procedures for crossing borders toprovide or consume services. Particular focus will be placed on streamlining procedures to allow Congolese travelers and air freight fast and smooth access to and clearance at Kamembe airport, and
3. (iii) Implement the COMESA Simplified Trade Regime (STR) which provides for small-scale traders to qualify for duty-free entry for certain goods and for a more simple and reduced set of documentary requirements to cross the border. The COMESA STR is an instrument of facilitating and formalising small-scale trade between countries.

The reforms are essential to make border crossing procedures more transparent and predictable for traders.
This will be of particular importance to small-scale traders, and especially women, who are typically more vulnerable given the asymmetry in power between the official and trader and the current lack of a functioning mechanism for addressing complaints and resolving disputes for small-scale traders. The reforms will contribute to increased safety and less scope for harassment at the border, especially against women, to shorter time to cross the border (thus providing the opportunity to eventually increase the number of journeys in a day, with a corresponding increase in profits and revenue) and to improved control and revenue generation at key border crossings.

Implementation of the COMESA regulations and STR require activities at the country level.
The COMESA regulations need to be tailored to the specific conditions at each border post. Implementation of the STR requires bilateral negotiations at each border post to agree a common list of STR-eligible products and a threshold value under which the STR will be applied. This Component will support these implementation activities at the national level primarily through strengthening Joint Border Committees. It is also important that local traders and officials are familiar with the Regulations and the STR. This will be achieved through training and capacity building as detailed in Sub-component 2.2. These national level activities will be enhanced by efforts at the regional level to ensure effective coordination and consistent training that will be led by COMESA and are included under Sub-component 2.3 below.

The project will support the strengthening of Joint Border Committees (JBCs) on both sides of the border to assist in the implementation and monitoring of these reforms.
To promote greater inter-agency cooperation and communication amongst border agencies, the project will support the establishment of JBCs, where they do not exist, and enhance those that are already established. JBCs have been shown to facilitate procedural reforms as well as greater communication between traders and official counterparts from across the border. Empowered and more inclusive JBCs, which regularly incorporate traders’ representatives through membership of trade related sub committees where appropriate, will be used as the main platform for small-scale (women) traders to: (a) lodge complaints and report abuses, including harassment and other forms of gender-based violence; (b) receive first-hand assistance and legal advice; and (c) provide feedback on reported cases of abuse. JBCs ought to play a major role in reviewing performance measurement data, analyzing it, and recommending corrective action when necessary. The project will support workshops, trainings and other capacity building exercises to illustrate to both traders and officials the benefits of establishing such joint platforms, as well as to progressively build mutual trust between the two groups. In addition, regular joint meetings of JBCs from both sides of the border will be held to share experiences and seek common solutions to the challenges of border management in this region. Experience from other regions has shown the value of such combined meetings of JBCs.

Sub-component 2.2. Training and capacity building for traders and officials to support greater integrity and ethical behavior in trade processes (US$2.3 million)The project will support customized training to strengthen capacities of border agents and of traders/traders associations.
Building on the functional review of border agencies, to be financed under Sub-component 3.1, this Sub-component will provide a comprehensive program of training for officials at the border, including on border  management procedures, rules and regulations, basic customer management, conflict resolution and gender awareness-raising. The aim will be to enhance technical capacities and skills of agents working at the border, supporting improved governance, reduced levels of harassment and more efficient control and processing of goods and people. Training courses will also cover the key principles and mechanisms of the COMESA Regulations, including the extension to trade in services, and include sessions on the COMESA STR. The project will also support traders and traders associations by providing support on trade procedures, improving relations between traders and border officials, and access to market information and finance, among other things. Traders will also be trained how to use relevant mechanisms to resolve disputes with officials and other  traders and how to use available reporting tools to register instances of harassment. Where possible training of officials will be undertaken jointly with small-scale traders to build empathy and understanding. Gender sensitivity and the particular needs of women will play a critical role in the trainings. These training activities will be coordinated with support for dissemination and application of STR and Trade Information Desks implemented as part of Sub-component 2.3.

Sub-component 2.3. Support for regional coordination of the policy and procedural reforms at the targeted border crossings and regional training for traders and officials (US$3.8 million)

As part of the regional trade promotion, a number of activities under Component 2 will be implemented by COMESA Secretariat, based in Lusaka, Zambia.
COMESA is the largest and most populous regional free trade area in Africa, and has identified the importance of trade initiatives at regional level to support small-scale trade. In particular, COMESA introduced the STR with the aim of facilitating small-scale trade at selected border posts in a number of member countries. Similarly, the organization adopted in 2014 the Regulations on Minimum Standards for the Treatment of Small-Scale Cross-Border Traders to promote behavioral change among both traders and officials.

The Sub-component will provide support for dissemination and application of the COMESA Regulations and the STR through the Trade Information Desks (TIDs).
COMESA will play a key role in ensuring regional coordination and communication regarding implementation of the COMESA STR and the COMESA Regulations, including the extension of the Regulations to trade in services. The COMESA Secretariat will build on on-going efforts at the national level and coordinate these activities at the regional level and support coordinated implementation at the local level through the Trade Information Desks that will be established or reinforced at each border. The Trade Information Desks will provide on-the-spot information to traders on the COMESA Regulations and the STR, support the clearance process (e.g. by helping filling the required forms), seek to resolve disputes between traders and officials as well as collect relevant data and statistics. Indeed the presence of COMESA officials and traders’ representatives, and their familiarity with the behavioral challenges faced by small-scale traders, will provide for an environment where complaints/abuses are more likely to be reported.

Extensive communication campaigns will be put in place at the regional level by the COMESA Secretariat to support the dissemination and implementation of the STR.

In addition, the project will support COMESA to provide regional training for peer learning.
Training sessions will be held at regional level for those who will then provide training within each of the three countries to traders and officials. The overall purpose of this exercise will be to ensure regional consistency on themes and subjects covered in the national trainings – regional training materials to be used in those sessions will be prepared beforehand as a result of border visits and local consultations. These regional trainings will be combined with a dialogue at the capital city level to formalize and institutionalize cross-border collaboration platforms, for information-sharing, troubleshooting and joint provision of security to traders and others. This will strengthen the already good (but ad hoc) interaction across countries of border officials.

In short, the Sub-component 2.3 will provide support for strengthening of TIDs, dissemination of the COMESA STR and the COMESA Regulations, and regional peer learning training program through one package of  procurement of international consulting services. This will be implemented in close collaboration with the main implementation agencies in each of the recipient countries..