08 September 2010

Yesterday we received the registration certificate from RDB! The process was not difficult, just not clearly documented. Even as we were completing the registration, additional documents (which I fortunately had with me) were requested. Nonetheless, by 4:00pm we had received the certificate and submitted the investment application (which also had additional requirements that were not documented in the regulations).

It’s now Wednesday morning, and I’m back at RDB. Our investment application was approved, and the next step is to pay $500 for the investment certificate. I noticed the language in the investment acceptance letter regarding importation of raw materials was different from the language in the investment code, so I inquired. The investment code states,



An investor who imports machinery and raw materials shall be exempted from import duties.

Pretty clear, right? Well, what I learned is that there is an international definition of “raw materials.” And there is an exemption list that applies specifically to industries in Rwanda. Having just reviewed the list with the RDB Investment Director, none of our “raw materials” (peanut paste, milk powder, and vitamin/mineral mix) are on the current list. It is possible to request new items to be added, but the process can take “not less than six months.” To further complicate matters, Rwanda has recently joined the East African Community and, accordingly, important portions of the Rwanda invest code (which RDB sent us and upon which we based much of our information) has changed, although the written code has not been updated. So, I was told this morning, “We know that’s what the code says, but now this is the what we’re doing.”

What difference does this make, you ask? The import duty would be anywhere from 10-25% on each raw material. That would significantly increase our cost of production and, most importantly, result in FEWER CHILDREN being served. So, I’m working with RDB to figure out a way forward that would enable us to produce MANA in a cost-effective, competitive manner. I’m sure we’ll get it figured out, and I’m glad we discovered this now and not when we were trying to clear a shipment of raw materials! I have a meeting set up with Clare Akamanzi, the Chief Operating Officer of RDB for tomorrow morning to discuss all this and chart a course to move things forward.

In the meantime, I’ll pay the $500 for the investment certificate and get number plates for the truck

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