WORLD TRADE  
ORGANIZATION  G/SPS/GEN/685 
6 April 2006 
 (06-1629) 
Committee on Sanitary a nd Phytosanitary Measures Original:   English 
  
 
FISH EXPORT FROM LAKE VICTORIA – FROM IMPORT BAN TO CASH EARNER 
 
Communication from Uganda
 
  
 The following communication, received on 30 Marc h 2006, is being circulated at the request 
of the Delegation of Uganda.  
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I. INTRODUCTION 
1. Uganda is situated in East Africa and has a surface area of 241,000 km
2.  Lakes account for 
44,000 km2 of its territory.  The largest of these lakes is Lake Victoria with a surface area of 
31,000 km2 within Uganda's border.  Its total surface area is 68,000 km2 of which 45% is in Uganda, 
49% in Tanzania and 6% in Kenya. 
2. The Uganda fish processing industry, which is composed of priv ate companies, was 
established only recently.  In fact, the first plants began their activities in 1988.  At the time of the 
ban, there were 12 registered companies for fi sh processing and export.  Ten companies were 
operational.  Almost all the companies are situated on the banks of Lake Victoria and Nile perch is 
their main raw material. 
3. Uganda offers a climate conducive for industria l development.  The rapid emergence of the 
industry has benefited both from political stability  and public measures encouraging investment, 
particularly in "non-traditional" sectors.  The total in vestment by private investors in the fish sector in 
Uganda is around US$ 100 million.  The fisheri es industry employs over 700,000 people involved in 
various fishing activities including fishermen, fish mongers, fish transporters and boat builders. 
4. Nile perch is the most important commercial fi sh species in Uganda.  It was introduced into 
Lakes Kyoga and Victoria from Lakes Albert and Turkana during the 1950's and early 1960's.  The 
purpose of the introduction was for the Nile pe rch to feed on small-sized fish, especially 
haplochromine cichlids (Nkejje), which were at that time abundant but not commercially exploited 
and to convert them into a larger fish of hi gher commercial and recrea tional value (Graham 1929). 
5. Nile perch is native to Lake Al bert and unlike the other lakes to which it has been introduced, 
the fauna of Lake Albert has evolved with and are adapted to living with this predator.  Examination 
of commercial fish catch statistics of Lake Albert  for the period 1970-1990 shows that Nile perch has 
been contributing 20% to 25% of th e total fish catches from the lake. 
6. It is possible that if and when the fishery in  the lakes to which Nile perch was introduced 
stabilizes, the percentage contribution of the predator to total fish catches in those lakes could be close 
to that recorded in Lake Albert. G/SPS/GEN/685 
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  Table 1: Estimated total quantity of fish a nd Nile perch landed in Uganda from 1991-2000 
 
Year Total fish landed (tonnes) Nile perch landed (tonnes) 
1991 
1992 1993 
1994 
1995 1996 1997 1998 1999 
2000 219,520 
224,100 276,800 
218,940 
227,000 218,400 218,400 217,100 229,500 
355,800 97,005 
- - 
79,559 
- - - - 
89,203 
83,943 
 
II. FISH EXPORTS 
7. By the 1980's, Ugandan's fish exports were going through the customs posts of Busia to 
Kenya, Mpondwe in Kasese and Arua to the Democra tic Republic of Congo.  However, beginning  in 
the 1990's a few companies started exporting limite d quantities of Nile perch fillets to Europe. 
8. Before 1991, fish processing plants in Kenya were sending insulated trucks with ice and 
refrigerated trucks to fish landing sites in Uganda in order to collect whole fish and transport them 
back to Kenya for processing in Kenyan fish processing establishments.  This practice stopped 
in 1991 when the Uganda Government put a ban on e xports of unprocessed whole fish to Kenya.  The 
Kenyan investors started flocking to Uganda to set up fish processing plants to process fish that was 
previously transported and processed in Kenya. 
Table 2: Nile perch exports from Uganda since 1991 
 
Year Quantity in (tonnes) Value (,000 US$) 
1991 4,751.00 5,308.70 
1992 4,831.00 6,450.50 
1993 6,037.10 8,806.90 
1994 6,563.00 14,768.90 
1995 12,970.90 25,902.80 
1996 16,396.40 39,780.90 
1997 9,839.00 28,800.00 
1998 11,604.00 29,732.70 
1999 13,342.00 36,608.30 
2000 15,876.38 34,363.10 
2001 28,153.39 79,039.10 
2002 26,800.00 87,000.00 
 
9. Overall, fish and fishery product exports have grown since 1991 (Table 2).  Fish exports have 
grown from a value of US$ 5.3 08 million in 1991 to US$ 39.78  million in 1996, but fell to 
US$ 28.8 million in 1997 due to a fish import ban imposed by the European Communities  over fish quality and safety concerns.  This ban was lifted in Ju ly 1998, but then in 1999 April another ban was 
imposed on fish and fishery products originating from Lake Victoria because of the concern that some 
fishermen were suspected of catching fish using p esticides.  This ban was lifted in October 2000 after 
the Department of Fisheries Resources (DFR) intr oduced a programme of monitoring the levels of  G/SPS/GEN/685 
 Page 3 
 
 
  pesticides and heavy metals in fish, water and se diments from Lake Victoria, and also intensified 
monitoring and surveillance of fishing activities on th e lake.  These repeated fish and fishery import 
bans by the European Communities  on fish origin ating from Uganda disrupted the growth of this 
sector, which in 1996 was Uganda's second largest  foreign exchange earner after coffee (MPED 
1998). 
10. Local companies have been exporting most of th eir fresh or frozen fillets to the European 
Communities;  Japan;  Hong Kong, China;  Singapore;  Australia;  Dubai;  Israel and United States of 
America since 1989.  The current capacity of fillet pr ocessing in Ugandan factories is estimated to be 
at least 400 tonnes of fish per month.  The smalle st unit exports 50 tonnes of fillets per month as 
compared to over 400 tonnes for the big units. 
III. COMPLIANCE WITH OFFICIAL STANDARDS 
11. Fish exports, which had grown tremendously since 1989, suffered from the bans imposed by 
the European Communities in January 1998 and in Ma rch 1999.  The first ban was due to failure by 
fish factories to meet EC quality assurance standards.   As a result of that ban, fish exports dropped 
from US$ 34.6 million in 1996/97 to US$ 31 million in 1997/98. 
12. Early in 1997, European countries, notably Spain and Italy, detected high levels of bacterial 
contamination including Salmonella in fish from La ke Victoria.  The two countries requested the 
European Communities to impose a ban on fish from th e riparian states of Lake Victoria.  Following 
an outbreak of cholera in East Africa, the Eu ropean Communities banned importation of fresh and 
chilled fish and imposed mandatory tests on frozen  fish, fruits and vegetables from East African 
countries. 
13. The second and longest ban was imposed in Marc h 1999 for pesticide residues for which the 
Government left the responsibility to the Depa rtment of Fisheries Resources (DFR) and the 
Competent Authority, i.e. the Uganda National Bureau of Standards (UNBS).  The European 
Communities demanded a comprehensive monitoring programme which would determine levels of 
organochlorine pesticides, organophosphate pesticid es, PCBs, and trace elements in fish, water and 
sediments from the lake.  This ban was officia lly lifted on 4 August 2000 and fish exports to the 
European Communities resumed on a bilateral basis. 
IV. CRISIS IN THE FISH INDUSTRY DUE TO THE BAN 
14. The loss to Uganda in terms of reduced returns as a result of the continued ban from March to 
July 1999 was estimated at US$ 36.9 million.  Loss to the fishermen community on account of reduced prices and less activity of fishing was US$ 1.0 million per month. 
15. Out of the 11 factories which were operational, three were closed and the remaining factories 
were operating at 20% capacity.  Consequently, 60- 70% of the directly employed people were laid 
off.  Around 35,000 people invol ved in various fishing activities including fishermen, fishmongers 
and fish transporters became jobless.  The remainin g indirectly employed people earned less than one 
third of their normal earnings.  Families and depend ants of the directly and indirectly employed 
people were affected. 
16. Other related industries like packaging, trans port and the economy in general were directly 
affected and all people involved suffered direct  consequences because of the EC ban on fish. G/SPS/GEN/685 
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  Table 3: Revenue for Uganda in US Dollars 
Month/Year Revenue, Million US$ 
January, February and March 1999 
April, May, June and July 1999 September 2000 October 2000 
November 2000 
December 2000 January 2001 February 2001  17.0 
2.5 2.0 1.5 
2.1 
2.5 5.0 4.7 
 
Table 4: Export market shares for Euro pean Communities (EC) and Non European 
Communities (Non EC) after the ban was lifted 
Month/Year Product Quantity (Tonnes) Value in Millions, US$ 
September 2000 
 
October 2000 
 
 November 2000   
December 2000 
  January 2001   
February 2001 EC 
Non EC   
EC 
Non EC  EC Non EC 
 
EC Non EC  EC Non EC 
 
EC Non EC : 
: 
 
: 
: 
 
: : 
 
: : 
 
: : 
 
: : 958 
731 
 
783 
983 
 
981 994 
 
852 
1,123 
 
155 215 
 
586 392 1.9 
1.41 
 
1.4 
2.0 
 
4.0 2.0 
 
2.5 1.2 
 
3.0 2.0 
 
3.3 1.4 
 
V. EUROPEAN COMMUNITIES MISSIONS OF VETERINARY INSPECTORS TO 
UGANDA 
17. The European Communities missions of veterinary  inspectors have so far carried out four 
inspections to assess the health control and monito ring of production conditions to comply with EC 
Directive 91/493. 
18. The following inspections were carried out: 
• In March 1997 and December 1997 for overall hygiene standards; 
• In November 1998 for harmonization of Uganda following which Uganda was put on List II 
and Tanzania on List I; 
• In August 1999 for guarantees regarding absen ce of pesticide residues in fish;  and 
• In October 2000 for harmonization and guarantees regarding pesticide residues.  G/SPS/GEN/685 
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  VI. PROBLEMS FACED BY THE FISH INDUSTRY 
Structure of Competent Authority 
19. There was a problem with the structure of th e Competent Authority identified by European 
Communities, Dutch Authorities and Council of Mini sters in the meeting in Dar-es-Salaam in 
June 1999.  Furthermore, there was lack of a clear line of command since two bodies, namely UNBS 
under the Ministry of Tourism, Trade and Industry , and fish inspection services in the DFR under the 
Ministry of Agriculture, Animal Industry and Fisheries (MAAIF) were involved. 
Inspection 
20. The inspectors of DFR could not perform their duties.  They did not have clear guidelines and 
standard operating practices in particular with rega rd to inspecting batches of fish being landed, 
hygiene conditions at landing sites, sampling procedure records of their own activities and documents 
required for traceability of origin and transportation of fish. 
Laboratories 
21. Non-availability of a suitable laboratory for pes ticide residue analysis was a key concern.  A 
Government Chemist had been put in charge of perfo rming pesticide residue analysis in fish products, 
however, the performance and capacity were cons idered totally inadequate by the European 
Communities inspection team. 
Legislation 
22. The Fish and Crocodile Act had not been upgraded to meet the present requirements of the 
fishery industry. 
Decentralization 
23. District Fisheries Officers (DFOs) were not answerable to DFR and hence not following the 
instructions regarding hygiene and handling of fi sh as required by European Communities regulations. 
Landing Sites 
24. Most public landing sites had not been upgraded  and their facilities did not meet minimum 
EC requirements. 
Fish Handling 
25. Fish was generally unhygienically  handled throughout the chain. 
VII. IMPACT OF UNIDO'S SUPPORT 
26. UNIDO received funding from NORAD to support the Food Co mponent under Phase 1 of the 
Uganda Integrated Programme (UIP). 
27. The focus was put on the fish sub-sector to addr ess the ban imposed on Uganda's fish exports 
to the European Communities and its related ec onomic consequences.  UNIDO's support contributed 
greatly to the lifting of the EC ban, hence, the r esumption of exports to th e European Communities.  
UNIDO provided technical assistance in preparing responses to the EC Commission regarding guarantees put in place by Uganda to meet the EC requirements. G/SPS/GEN/685 
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  28. As a result of the achievement in the fish s ub-sector, Norway has approved additional funding 
to support the Food Component under Phase 2 of UI P to strengthen the fish inspection systems and 
replicate the so-called "fish model" in selected priority sub sectors including honey, fruits and vegetables, dairy and meat.  
Fish Inspection Services 
29. The fish inspection services have been stre amlined and the capacity of the Competent 
Authority (DFR) strengthened through training of inspectors, provision of equipment and introduction 
of a fish inspection manual.  Achievements in th is sub-sector will be used as a model for other sub-
sectors sensitive to the public health of consumer s and/or having export potential.  The inspection 
system will be used in development of the Food Control System. 
30. As a result of strengthening the fish inspecti on services, Ugandan fish got access to the US 
market, which demanded approved HACCP systems from the fish factories. 
31. Laboratories were provided with equipment and technical support.  UNBS Microbiology 
Laboratory having been fully equipped introduc ed a Quality Management System which was 
internationally accredited by the South African  National Accreditation System (SANAS) in 
April 2001.  Chemiphar (U) Ltd., a private labor atory, which benefited from UNIDO support, was 
approved by the EC inspectors for pesticide residue  analysis.  The Government Chemist Analytical 
Laboratory is still undergoing upgrading.  Availab ility of internationally recognized laboratory 
services locally in Uganda will greatly facilitate e xports of products and also reduce the costs of 
laboratory analysis abroad. 
Fish Processing Pilot Enterprises 
32. The enterprises have been able to implemen t ISO 9000 Quality Management Systems and the 
principles of HACCP.  All enterprises have been  certified to ISO 9001:2000.  Implementation of 
HACCP made it possible to export fish to the US ma rket.  In addition, the enterprises have improved 
in quality management through introduction of the un iform "Code of Practice".  Experiences in these 
pilot enterprises will also act as a model for other sub-sectors. 
33. UNIDO proposed hygienic fish handling practices on the lake and at landing sites in 
conformity with the EC quality/safety requirement s.  Two pilot boats were  constructed and handed 
over to the Uganda Fish Processors and Export ers Association (UFPEA) to conduct trials for 
assessment of the socio-economic and technical im pact.  Based on the results, the most suitable 
designs will be disseminated to the 20 local boat bui lders already trained in boat building and design 
by UNIDO, the whole fishing fleet and regulatory authorities to facilitate adoption. 
Economy of Uganda 
34. With the resumption of fish exports to th e European Communities, the increased revenue 
from exports strengthened Uganda's shilling.  Factor ies resumed operations at full capacity.  Laid off 
staff during the ban have been recruited.  The fish er folk is back to earn a livelihood.  More fish 
processing factories have been opened. 
35. Uganda was harmonized and promoted to List  I status with effect from 15 October 2001 
which made it possible to export to any EC member S 
36. tate without restriction.  This resulte d in increased revenue from fish exports. 
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