European Union market from 9.8 percent in 2001 to 10.3 percent in 2002. Competing countries with more humid conditions (especially Turkey) have incurred higher levels of product rejections over the past year. Ironically it could be argued that, at least for dried fruit, the more stringent European Union standards and the greater enforcement of those standards at border points has worked to the competitive advantage of Africa’s leading suppliers.

But what about the impact on Africa’s trade in groundnuts? Africa’s groundnut exports are dominated by South Africa, although several other countries, including Egypt, Sudan, Gambia, and Senegal, have maintained small exports in confectionery nuts. A variety of supply-side constraints have inhibited the competitiveness of many African countries in the international market for this product.<sup>41</sup> In 2002, South Africa had 12 consignments of groundnuts rejected by EU Member States because of aflatoxin. However, of these twelve only three would have met the Codex standard; the remaining nine consignments would have also been rejected on the basis of both the Codex standard and the standards that had previously been applied by the individual Member States. Indeed, most of the rejected consignments had total aflatoxin levels of between 18ppb and 30ppb. These consignments were returned to South Africa (presumably for sale elsewhere) rather than destroyed. Probably a few hundred thousands of dollars of business was affected, although the probable re-routing and further sale of these nuts would have substantially mitigated these losses. Hence, we would suggest that the near-term ‘loss’ of African trade due to the more stringent European Union standards has actually been in the hundreds of thousands rather than the hundreds of millions of dollars.<sup>42</sup> While the case for significant African trade losses is weak, compliance with the European aflatoxin standards continues to be a challenge for selected developing countries. Between 2000 and 2002 there was a three-fold increase (from 92 to 251) in the number of border rejections of nuts, nut products and other snacks. In 2002, some 235 consignments of nuts and dried fruit were rejected specifically on the grounds of excessive levels of aflatoxin. The vast majority of these rejections were of products from three countries, namely Turkey (77 cases involving hazelnuts and dried fruit), Brazil (51 cases of mainly Brazil nuts) and Iran (50 cases of mainly pistachios). Other countries with more than just a few rejections were China (18), South Africa (12), United States (7) and Argentina (5).

Although the data are incomplete, for many months the European Union notifications and alerts database reports the actual test results for levels of aflatoxin. In the vast majority of cases where consignments are rejected, the measured levels of aflatoxin are substantially higher (and sometimes many times over) than the Codex standard and also significantly above the domestic standards of the exporting countries. For example, of the 15 nut and dried fruit consignments rejected in January 2002 only three were above the EU but below the Codex standard. In October 2002, one country source of nuts had 38 individual consignments rejected, 15 of which

> 41 In the 1960s and 1970s, Africa was a major world supplier of groundnuts, with large exporters in Nigeria, Senegal, Malawi and other countries.  For a variety of reasons, not related to aflatoxin, these exports lost their international competitiveness and most production went to serve domestic markets or for use in oil-crushing.  Over the years, research activity and the commercial trade moved away from confectionery-type varieties preferred in world markets and recent attempts to revive confectionery nut exports have encountered major problems due to inadequate seed, basic quality control and price incentives for farmers.

> 42 We have found no evidence that Africa’s limited exports to the European Union of either cereals or tree nuts has been adversely affected since the adoption of the new standards.

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