Second survey of trade-related private sector in … survey of trade-related private sector in Myanmar ... or policies of the Asian Development Bank ... Questionnaire Design and Layout

Project Number: 46191-001 August 2017

Second survey of trade-related private sector in Myanmar

Produced by the ADB Project TA 8707 (REG): Strengthening Trade Facilitation in the Greater Mekong Subregion through Partnerships with the Private Sector

The views expressed in this report are the views of the author(s) and do not necessarily reflect the views or policies of the Asian Development Bank (ADB), or its Board of Directors or the governments they represent. ADB does not guarantee the source, originality, accuracy, completeness or reliability of any statement, information, data, finding, interpretation, advice, opinion, or view presented, nor does it make any representation concerning the same.

____________________________

Project No 46191-001

TA 8707 (REG)

August 2017

SECOND SURVEY OF TRADE-

RELATED PRIVATE SECTOR IN

MYANMAR

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Report produced by:

Chris Page, Team Leader/ ADB Consultant

In association with:

The Union of Myanmar Federation of Chambers

of Commerce & Industry (UMFCCI)

______________________________________________________________

Under the ADB Project ‘Strengthening Trade Facilitation through

Partnerships with the Private Sector’

Disclaimer: This document does not necessarily reflect the views of the Asian Development

Bank. ADB cannot be held responsible for the content.

Project TA 8707 (REG) “Strengthening Trade Facilitation through Partnerships with the Private Sector”

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Table of Contents

LIST OF ACRONYMS .......................................................................................... 4

1. INTRODUCTION ......................................................................................... 5

Background .............................................................................................. 5

Survey Methodology .................................................................................. 5

Questionnaire Design and Layout ................................................................. 6

2. SURVEY RESPONSES .................................................................................. 7

Section 1: General Information ................................................................... 7

Section 2: Customs Clearance ................................................................... 11

Section 3: Information about Regulations and Procedures ............................. 17

Section 4: Customer Service ..................................................................... 26

Section 5: Suggestions ............................................................................. 29

3. FINDINGS & CONCLUSIONS ...................................................................... 31

Findings ................................................................................................. 31

Conclusions ............................................................................................. 31

4. RECOMMENDATIONS ................................................................................ 32

5. ANNEX ................................................................................................... 33


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LIST OF ACRONYMS

ADB Asian Development Bank

BCP Border Crossing Point

CMP Cut-Make-Pack

GMS Greater Mekong Subregion

HS Harmonised System

IT Information Technology

ITSC International Trade Supply Chain

MACCS Myanmar Automated Cargo Clearance System

MCBA Myanmar Customs Brokers Association

MIFFA Myanmar International Freight Forwarders Association

MoC Ministry of Commerce

OGA Other Government Agency

RKC Revised Kyoto Convention

SAD Shipping Agency Department

TA Technical Assistance

UMFCCI Union of Myanmar Federation of Chambers of Commerce & Industry

WCO World Customs Organization

WTO World Trade Organization


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1. INTRODUCTION

Background

This short report summarises the responses to a trade survey questionnaire distributed in Myanmar in July 2017, and collected in August 2017. The survey was

the second of its kind carried out by ADB’s project ‘Strengthening Trade Facilitation through Partnerships with the Private Sector’ (referred to as TA 8707). The first was conducted in 2015.

The purpose of both surveys was to canvass the views of private sector operators (importers, exporters, freight forwarders, customs brokers, transport operators,

and warehouse-keepers) not only about trade facilitation constraints in Myanmar, but also about the possible solutions. The surveys focused largely upon the customs clearance process, and the provision of information about import/ export

regulations and procedures. They also examined the service provided to trade stakeholders by the Myanmar Customs Department. In exploring these areas, a

key objective was to identify ways to establish or improve the measures by which the customs administration communicates and engages with the private sector in respect of international trade.

The 2017 survey was conducted in association with the Union of Myanmar Federation of Chambers of Commerce & Industry (UMFCCI), specifically because

that organisation has now – with the support of TA 8707 – taken responsibility for convening and managing the International Trade Supply Chain (ITSC) Working Group. This is a potentially influential forum in which public and private sector

trade stakeholders (and/ or their representative bodies) can meet together to identify, discuss, clarify and – where possible – collectively resolve problems in any

area of Myanmar’s international trade supply chain. The ITSC Working Group is tailor-made for addressing the issues raised by this second trade survey, and it is expected that the UMFCCI will make this a top priority after the report is published.

Survey Methodology

The design of the 2017 questionnaire, and the survey process, were identical to

those used in 2015. This was to ensure comparison of similar data (even though it was virtually impossible to reach the same 400 stakeholders who had responded to the first survey).

The 2017 survey questionnaire was once again issued to importers, exporters, freight forwarders, customs brokers, transport operators, and warehouse-keepers.

A deliberate attempt was made to include those operators who regularly use the land border crossing points (BCPs) of Myawaddy (Kayin State, on the border with

Thailand), Muse (Shan State, on the border with China), and Tachileik (Shan State, on the border with Thailand), since these form important links in GMS transport corridors – the main locus of TA 8707, as originally designed.

700 questionnaires were issued, and replies to 277 were received – a response rate of 39.7%, which can probably be regarded as acceptable given firstly that many of

the targeted respondents are dispersed among remote, hard-to-reach areas of Myanmar; and secondly that a very wide cross-section of trade stakeholders, products, and trading markets was covered by the responses received.

Section 2 of this report summarises all of the responses to the survey under headings corresponding to the questions used in the survey questionnaire, and in

exactly the same sequence. Section 3 sets out the main findings, and draws some


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initial conclusions from them; Section 4 makes recommendations for the future.

Questionnaire Design and Layout

Surveys of the trade-related private sector have proved in many countries to be an effective means by which to gauge perceptions of the efficiency of trade across

borders, and to identify broad areas that are in need of improvement. However, because many of these surveys are based on aggregate indicators, they do not always identify specific trade facilitation constraints or bottlenecks; and they rarely

offer solutions.

For the TA 8707 project, therefore, the decision was taken from the outset that any

such surveys should attempt to be more precise; and, as well as asking respondents to identify very specifically what needs to be improved, these surveys would elicit suggestions as to how that might be achieved.

The survey questionnaire was designed accordingly, and can be seen at Annex A. It contains a total of 23 questions, and was designed with a number of principles in

mind:

To be comprehensive enough to cover the main issues, whilst at the same time being short enough so as not to deter those surveyed from answering.

To minimise the need for narrative responses, and to set the majority of questions within a simple semantic differential scale, requiring only a ‘tick box’ response.

To explore perceptions and gauge levels of satisfaction, as well as gathering

concrete information.

To group questions under distinct categories.

Within those categories, to move progressively from questions about the

general to the particular.

To invite suggestions about what might be done to resolve identified

problems.

Respondents were not asked to give their names, and confidentiality of identity – where known – has been preserved through the aggregation of data.


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2. SURVEY RESPONSES

Section 1: General Information

Question 1: What is the nature of your business? (Please tick all that apply)

Importer Exporter Freight

Forwarder

Customs

Broker

Transporter Warehouse

Keeper

103 52 48 123 17 9

Some respondents represented more than one business type, e.g. importer/ exporter, or freight forwarder/ customs broker, hence a total that is larger than the

number of survey responses. All categories were covered, however, and the chart below shows the spread. The high percentage of customs brokers reflects the fact that these operators handle the lion’s share of customs clearance processing in Myanmar, on behalf of importers and exporters. See Questions 8 and 9 for a deeper exploration of this phenomenon.

Question 2: At which ports/ airports/ border crossings do you import/ export your goods? (Please list all)

The respondents were operating at each of the following points of entry/ exit to/ from Myanmar:

Seaports: Asia World Port, Myanmar Industrial Port, Htee Tan Port, Bo Aung Kyaw Wharf, Ahlone International Port, Sule

Wharf, Thilawah Port

Airport: Yangon International Airport

Land border

crossings:

Muse Border, Myawaddy Border, Kaw Thaung Border,

Tachileik Border


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The map below shows the location of these various entry/ exit points.

Yangon Ports

Yangon International

Airport

Tachileik BCP

Muse BCP

Myawaddy

BCP

Kaw Thaung

BCP


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Question 3: Which are the main countries from which/ to which you import/ export?

27 countries were mentioned. These are highlighted in blue on the world map below.

The continents of Africa and Europe, and the Middle East region, were also listed.

Question 4: What type of goods do you usually import/ export?

A very wide range of products was listed. These are set out in the box below, under

their (simplified) section headings in the Harmonised System (HS)1:

Live Animals & Animal Products

Agricultural Products, Frozen Fish, Fish Food, Animal Feed Supplement, Frozen Prawns

Vegetable Products

Beans & Pulses, Betel Nuts, Sesame Seeds, Rice, Broken Rice, Tamarind, Roasted Sesame

Powder, Wheat, Coffee Beans, Cashew Nuts, Fresh Chilli, Onion, Garlic, Fruits, Sugar, Malt,

Corn, Palm Oil, Raw Foodstuffs

Prepared Foodstuffs

Foodstuffs, Ice Cream, Beverages, Wines

Mineral Products

Raw Materials, Lubricants, Gasoline, Diesel, Engine Oil, Octane

Products of Chemical or Allied Industries

Cosmetics, Detergent Powder, Soap, Fertilizers, Paints, Raw Chemicals, Medicines, Vet

Medicines, Liquid Carbon Dioxide

Plastics & Rubber

Rubber, Plastic Sheets, Plastic Resin, PVC Products

Raw Hides & Skins, Leather, Furs

Shoes, Leather Bags, Ladies Handbags, Cow Hides, Goat Hides

Wood & Articles of Wood

Teak, Plywood, Broomsticks, Furniture

1 The Harmonised Commodity Description and Coding System of tariff nomenclature.


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Paper & Paperboard

Packing Materials, Paper, Mail Parcel Bags

Textiles & Textile Articles

Textiles, Garments, Clothes, CMP (Raw Materials), Blankets

Stone, Plaster, Cement, Glass & Glassware

Construction Materials, Cement

Base metals & metal articles

Metal, Iron Rods, Galvanised Iron Plain Sheets, Steel Structure, Aluminium Composite,

Metal Pipes, Silicon Steel, Mild Steel, Iron, Nickel, Cables

Machinery & Electrical Equipment

Heavy Machinery, Machinery, Electronic Goods, Refrigerators, Computer Accessories,

Telecom Accessories, Excavators, Air Conditioners, Pumps/Motors/Valves, Generators,

Printers & Ink, Security Goods

Vehicles, Planes & Transport Equipment

Vehicles, Automobiles, Car Spare Parts, Motor Cycles, Tyres, Cycle Tyres

Optical & Medical Apparatus

Medical Equipment, Lab Equipment

Miscellaneous & Manufactured Articles

Consumer Products, Personal Effects, Kitchenware, Household Wares, Donated Goods


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Section 2: Customs Clearance

Question 5: Is the customs clearance process efficient?

Compared with 2015, a greater percentage of those surveyed viewed the customs clearance process as being ‘mostly’ and ‘nearly always’ efficient. This may reflect

the fact that, in the interim, customs clearance has been partially automated with the introduction of the Myanmar Automated Cargo Clearance System (MACCS).

That said, 23.5% of respondents considered the process to be efficient only

‘sometimes’, 7% considered it to be ‘rarely’ efficient, and 3% ‘hardly ever’ efficient. Whilst these figures also represent a fair improvement on the 2015 responses, they

leave no room for complacency, and should still be a matter of concern to the Myanmar Customs Department.

2017

2015


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Question 6: Is the customs clearance process clear, understandable and predictable?

The responses to this question show a marked improvement on those for the group surveyed in 2015. Almost 65% of the 2017 respondents considered that the

customs clearance process is mostly or nearly always clear, understandable and predictable.

This is undeniably a good achievement by the Customs Department, but there is

still an opportunity for it to explore with traders how these features could be further improved: responses in the ‘sometimes’, ‘rarely’, and ‘hardly ever’ categories still amount to over 35% of the total.

The suggestions made in response to Question 19 are likely to be useful in this respect.

2017

2015


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Question 7: How often are you satisfied with the speed of customs clearance?

Once again, satisfaction levels amongst this survey group have improved in all

categories since 2015.

Nevertheless, the Customs Department might wish to discuss with traders whether

and how satisfaction levels can be further increased: 35% of correspondents are satisfied ‘sometimes’, ‘rarely’, or ‘never’, which is still a long way from being ideal.

Some of the suggestions made in Section 5 of the survey are likely to be useful to

Customs in this respect.

2017

2015


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Question 8: How satisfied are you with the service you receive from your customs broker?

Satisfaction levels amongst the 2017 survey group are a lot higher than those indicated in 2015. It is to be hoped that the new programme of training for

customs brokers, introduced by the Customs Department in July 2017, will bring about improvements in broker performance that will eventually flow through to greater satisfaction still: there is clearly work to be done when over 25% of

correspondents are only ‘partly satisfied’. See also the responses to Question 9, below.

2017

2015


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Question 9: Please say what aspects of your customs broker’s performance could be improved.

Although not everyone who responded to the questionnaire answered this particular question, there were a number of replies which provide a very clear

indication of where the areas for improvement are felt to be:

Customs brokers

need to be skilful on the MACCS system (11 responses)

need to explain better the official requirements regarding the cargo and relevant documents for clearance (10 responses)

should give proper advice (policy, time, tax and so on) to the clients for

import/ export (9 responses)

need to know HS Code (7 responses)

need to know more about the official requirements of respective

departments (3 responses)

are weak in advance preparation before declaration (3 responses)

should know more about rules and regulations for import/ export of cargo (1 response)

These responses indicate deficiencies in basic knowledge requirements. Given the prime role of customs brokers in the management of the customs clearance

process in Myanmar, it is particularly important that they are addressed.

Question 10: Please list the 3 most common causes of problems with customs

clearance.

The responses are set out below, in five broad categories, and with the types of response given from highest to lowest numbers. The results speak for themselves,

and although there are a number of customs-related problems that need to be addressed, there are others – beyond the control of the Customs Department –

which are also causing concern.

Once again, dissatisfaction with customs brokers is a feature.

Clearance Process

Capacity building is required for junior customs officials (10 responses)

Need to assign skilful staff (3 responses)

Waiting for senior customs officials' signature. No delegation at port when the official goes out on duty (38 responses)

Customs should accept the transaction value for customs valuation purposes (16 responses)

Delay in Customs valuation (3 responses)

Customs officials should provide the HS code quickly (15 responses)

Many steps in paperwork (3 responses)

Less transparency in the orders and notifications (7 responses)


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Need to cooperate among departments (15 responses)

Recommendation request process from OGAs is slow (3 responses)

To control corruption (10 responses)

Refund process takes time (3 responses)

Customs officials should not examine the containers categorised by

selectivity 2 as per MACCS (3 responses)

Customs Brokers

There are not enough skilful Customs Brokers (25 responses)

Brokers are not familiar with the MACCS system (3 responses)

Myanmar Automated Cargo Clearance System (MACCS)

MACCS system errors (27 responses)

Poor internet connection (6 responses)

Online system at Myawaddy Border Post is not good (14 responses)

MACCS system is in place but there is a manual process for files at ports

(10 responses)

Poor server and processing errors (5 responses)

Port Procedures

Difficult to contact the shipping lines (3 responses)

Mistakes by the shipping lines when they send emails to Customs (3 responses)

Always have to pay washing fee of the empty container to the shipping line (3 responses)

The consignee has to take responsibility for container damage (1 response)

Logistics, Infrastructure & Facilities

Traffic jams (10 responses)

Trucks do not arrive at the port in time (5 responses)

Port facilities are poor (18 responses)

Transportation of heavy duty trucks is limited (14 responses)

Not enough inspection space at ports (5 responses)

Electricity black-outs (12 responses)

There is not enough space for vehicle parking at ports (5 responses)

Waiting for queuing trucks (3 responses)

Delay in and out for containers at port (3 responses)


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Section 3: Information about Regulations and Procedures

Question 11: What are your main sources of information about import/ export

regulations and procedures?

The chart below shows very clearly where traders obtain their information about

import and export regulations and procedures. As in 2015, the Customs Department’s website, and other customs publications, are principal sources. It is also plain to see that many of the respondents in the 2017 group also rely upon

customs brokers for this type of information – again reflecting the significant role played by these operators in Myanmar.

It remains important to ensure that customs brokers and trade associations – another significant source of information – know enough about current import/ export regulations and procedures to be able to effectively satisfy trader demand.

2017

2015


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Question 12: How complete is that information?

Whilst there are some modest improvements in the perceptions of this survey

group, compared to 2015, it should be borne in mind that information about regulations and procedures which is ‘mainly complete’ is still unsatisfactory. And

even fewer (1.5%) respondents this time felt that the information that they obtain is entirely complete. There remains a huge challenge for those responsible for providing information about import/ export regulations and procedures:

importation and exportation of goods to/ from Myanmar will never be efficient whilst those involved do not have the full picture in relation to official

requirements; mistakes will inevitably be made, delays will occur, official sanctions may be unfairly imposed, and duty and taxes could be under-declared.

2017

2015


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Question 13: How accurate is that information?

Precisely the same points apply to the responses to this question, and there are

negligible improvements compared with 2015. Only 4% of respondents felt that the information they obtain about import and export regulations and procedures is

entirely accurate. Over 40% felt that this information is only partly accurate, or not at all; and 54% said that the information is ‘mainly’ accurate. Quite clearly, ‘mainly’ is nowhere near good enough where issues such as the HS classification,

origin, or valuation of goods is concerned.

2017

2015


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Question 14: How up-to-date is that information?

Once again, the responses are similar to those for Questions 12 and 13. Only 4%

of respondents felt that the information that they obtain about import and export regulations and procedures is entirely up-to-date. Over 52% felt that this

information is only partly up-to-date, or not at all; and around 44% said that the information is mainly up-to-date.

2017

2015


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Question 15: How easy is it to obtain information about import/ export regulations and procedures?

The responses from the 2017 survey group indicate a moderate improvement compared to 2015, with a significant majority of respondents – over 80% –

indicating that they found the process moderately easy, easy, or very easy. This should encourage those who are responsible for information provision, since they can concentrate on completeness, accuracy, and currency, with less attention given

to the medium by which the information is conveyed.

2017

2015


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Question 16: How easy is it to understand that information?

Once again, a very large majority – over 80% – found that understanding

information about import/ export regulations and procedures is moderately easy, easy, or very easy. This does not mean that improvements cannot be made, but it

remains clear that the main focus needs to be on ensuring the completeness, accuracy, and currency of the information conveyed.

2017

2015


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Question 17: Does Customs provide adequate information when regulations and procedures are changed, or introduced?

The provision of complete, comprehensive, and accurate information about new regulations and procedures, preferably in advance, is the sine qua non of effective

trade facilitation. Only 13% of respondents said that this type of information is nearly always adequate, with others assigning lower marks. This remains an area which demands attention, despite some modest improvements in perceptions since

2015.

2017

2015


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Question 18: Are you able to obtain advance rulings from Customs about regulations and procedures?

A meagre 6.5% of respondents said that they are nearly always able to obtain advance rulings from the Customs Department. 28% said that this is rarely or

hardly ever possible. Although this survey shows improvements by comparison with 2015, the continuing deficiency in this area of service provision is a significant trade facilitation constraint – and a large gap in compliance with the World Trade

Organization’s Trade Facilitation Agreement – since it inhibits the ability of importers and exporters to make commercial judgements based upon, for example,

the HS classification or valuation of their goods, or licensing requirements.

2017

2015


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Question 19: Please make one suggestion that would improve your experience with obtaining information about regulations and procedures

There were many constructive and practical suggestions in response to this question, and the list is set out below, in order of popularity. The first two items

clearly mirror the responses to Question 14.

Almost everything on the list is achievable at low cost and with minimum effort, but the fact that many of the same items were identified in 2015 suggests that

there has been insufficient progress. The trade-related private sector should put pressure on the relevant government departments to do better.

Relevant departments should share up-to-date information in a timely manner (even 3 months in advance), by letter or email (83 responses)

Up-to-date information database for reference in the Customs and other agencies’ websites (71 responses)

More transparency (15 responses)

Make awareness to all concerned parties through associations (e.g. MCBA), open dialogue to exchange ideas, real situations, challenges and gaps, in advance before any changes (14 responses)

To conduct training courses or seminars for sharing information (12 responses)

To set up a call centre to provide information in a timely manner (10 responses)

To set up mobile application regarding Customs. It should be changed from the manual system to the computerised networking system (9 responses)

More information in the media (TV, newspapers) (8 responses)

Clear guidelines/information pamphlets regarding Customs procedures (8 responses)

Awareness campaigns (7 responses)

To send copy of Customs notifications (or) policies changes to the

agencies, otherwise, to announce in the white board at Myawaddy border post (7 responses)

To distribute Customs newsletter regularly (5 responses)

Nowadays, we can't log in to the Customs website, we can only see the Customs information from Facebook (3 responses)


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Section 4: Customer Service

Question 20: How helpful are Customs officials when you need information about

customs regulations and procedures?

Over 96% of the responses indicated that customs officials are moderately helpful,

or better, when asked for information about official requirements. Compared with 2015, there has been a distinct shift towards ‘helpful’ and ‘very helpful’. All of this reflects very well on the Customs Department and, whilst the effort to improve

overall levels of helpfulness needs to be sustained, this is not a priority area in comparison with others surveyed.

2017

2015


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Question 21: How well do Customs officials understand your requirements when you request information about customs regulations and procedures?

Compared with 2015, there has been very little movement in this area. Whilst more than 80% of respondents felt that the Customs Department’s officials – or, at

any rate, those approached for information – understand trade requirements either quite well or very well, the feeling remains that nearly 18% of officials understand requirements not very well or not at all well. At nearly one in five staff, this is

clearly far too many, and is bound to have a negative impact on trade facilitation. The issue requires attention, and the trade-related private sector should maintain

pressure for this to happen.

2017

2015


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Question 22: How useful would it be if Customs were to organise regular meetings to provide briefings on regulations and procedures?

The 2017 results are virtually identical to those of 2015. Over 80% of respondents considered the organisation of regular meetings and briefings either useful or very

useful, so there would appear to be little doubt of the value of introducing, or further developing, such arrangements. These should be used as a vehicle for addressing some of the concerns raised under Questions 12 et seq.

2017

2015


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Section 5: Suggestions

In this section, respondents were invited to offer any suggestions for ways in which

trade facilitation could be improved in Myanmar. Their responses are set out in the table below, in seven broad categories. Many of these suggestions are constructive,

concrete, practical, and relatively easy to implement.

It is interesting that, in addition to the suggestions made in 2015, this survey group cites poor coordination and cooperation between the government

departments responsible for international trade – notably the Myanmar Customs Department and the Ministry of Commerce – as a significant constraint.

International Trade Procedures Customs Clearance Process

To facilitate the tax payers quickly and

to cease the illegal trade and truck

traffic strictly (12 responses)

To ease the requirement for

recommendation from relevant

ministries for licence applications (10

responses)

To increase the number of items not

requiring licences by the Ministry of

Commerce (MoC) (10 responses)

Reduce delays in the process at MoC

border trade offices (8 responses)

To allow applying for licences for all

items at border posts (8 responses)

Quicker process for purchase order to be

in place (7 responses)

To reduce the penalty fees (7 responses)

To help and support the traders who

face challenges (3 responses)

To set a clear policy which reflects the

current situation (3 responses)

To reduce red tape (3 responses)

To be in place the correct method and

concrete regulations for improving trade

facilitation (1 response)

To speed up the clearance process at

ports (20 responses)

To use IT rather than manual system (9

responses)

To provide service by the officials in a

timely manner (7 responses)

To implement according to the rules and

regulations (6 responses)

To reduce MACCS server errors (5

responses)

To assess the value of goods quickly (5

responses)

It is better to examine the cargo by x-

ray rather than physical check (3

responses)

To introduce WCO's Express

Consignment Procedures (1 response)

Customs Administration Inter-Agency Cooperation

To delegate authority to the staff for

signature if the manager is not

available (27 responses)

To open the Customs procedures

courses for brokers very often (21

responses)

To open the Customs Brokers course

at the border posts (10 responses)

To change the mind-set of Customs

officials as positive way (4 responses)

More cooperation and taking

responsibility among

ministries/departments (207 responses)

To cooperate Ministry of Commerce and

Myanmar Customs Department (36

responses)

Ministries/departments should use same

rules and regulations in the border posts

(16 responses)


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Need skilful human resources (3

responses)

To change Customs rotation system to

be effective (1 response)

To comply with the RKC (1 response)

Availability of Information about Rules,

Regulations & Procedures Logistics

To inform the new rules and

regulations regarding trade facilitation

(7 responses)

To upgrade the infrastructure such as

transportation in the border posts (13

responses)

To provide 24-hour electricity supply

(10 responses)

Need to solve the bottlenecks at the

ports (9 responses)

Container depots need to be better

organised (3 responses)

Other

To abolish the Shipping Agency Department (SAD) (8 responses)


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3. FINDINGS & CONCLUSIONS

Findings

The survey responses come from 277 representatives of the main trade-related private sector actors in Myanmar. These businesses handle importations and exportations to and from more than 40 foreign countries, across 6 continents. They

regularly use 11 ports and border crossings around Myanmar, and the international airport in Yangon. The goods that they are dealing with cover a very wide range, from

raw materials to finished products, in most sectors of the economy.

It is therefore safe to say that, as with the first survey in 2015, the responses are representative. They should be taken seriously by the public sector and, whilst there

have been improvements in many areas since 2015, much remains to be done. In particular, the failure of government departments to provide prompt, complete,

accurate, and up-to-date information about import/ export regulations, and procedures continues to present a significant barrier to trade. This problem should be addressed with a much greater degree of seriousness, not least because failure to do

so will leave Myanmar well short in terms of compliance with the WTO Trade Facilitation Agreement – a goal to which the government has already committed itself.

There is also considerable dissatisfaction with the customs clearance process, much of which relates not to the introduction of MACCS, which appears gradually to be improving matters, but instead to the administrative and procedural system that

surrounds it.

Finally, many of the respondents complained about poor coordination and cooperation

between the government departments responsible for international trade, notably the Myanmar Customs Department and the Ministry of Commerce.

Conclusions

The survey results are the authentic voice of a representative cross-section of the trade-related private sector in Myanmar, based on their day-to-day experiences. Their

views are of considerably greater value than an external assessment, and much harder to dismiss. The responses therefore provide an excellent foundation for bringing together the trade-related private sector, and the government departments

responsible for international trade, in a joint effort to improve trade facilitation in Myanmar; and, in doing so, to base their decisions on informed views.

The good news is that, as a result of work by ADB’s TA 8707 project during the past two years, the perfect arrangement now exists by which many of these issues can be discussed and worked upon. The ITSC Working Group, convened by the UMFCCI, has

been established as a forum in which public and private sector trade stakeholders (and/ or their representative bodies) can meet together to identify, discuss, clarify

and – where possible – collectively resolve problems in any area of Myanmar’s international trade supply chain.

Taken together with the concrete, practical, and generally constructive suggestions that have been made in the responses to this survey, there is an excellent basis on which to make further progress. And many of the issues identified are neither difficult

nor costly to resolve. All that is required is a reasonable degree of effort and commitment.

As always, though, someone has to take the first steps ….


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4. RECOMMENDATIONS

This report will be shared by the author with those who contributed, largely through distribution by the various trade associations involved: UMFCCI, the Myanmar

Customs Brokers Association (MCBA), and the Myanmar International Freight Forwarders Association (MIFFA). It will also be shared with selected TA 8707 project

counterparts, including the Myanmar Customs Department and Ministry of Commerce.

It is recommended that:

1. The UMFCCI immediately distributes copies of the report amongst its members.

2. The UMFCCI convenes a meeting of the ITSC Working Group, within one month, specifically to discuss the survey responses. All relevant public and private

sector stakeholders should be invited to that meeting.

3. The UMFCCI publishes the report on its website, and encourages other trade-related associations to do likewise.

4. ADB should publish the report on the GMS website, and in doing so encourage other organisations, both in Myanmar and elsewhere in the GMS, to use the

information to support their own work in the sector.


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5. ANNEX

Annex A: Trade Survey Questionnaire

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ANNEX A

TRADE SURVEY QUESTIONNAIRE

Please take a few minutes of your time to complete this questionnaire. The information gained from the

analysis of the responses will be used by the International Trade Supply Chain (ITSC) Working Group,

coordinated by the UMFCCI, as the basis for devising ways of improving trade facilitation in Myanmar.

All of the results will be aggregated in such a way that individuals cannot be identified.

Please answer questions either by putting a tick in the relevant box, or by writing a short response, as

appropriate in each case.

Section 1: General information about your business

Importer Exporter Freight

Forwarder

Customs

Broker

Transporter Warehouse

Keeper

Q1. What is the

nature of your

business? (Please tick

all that apply)

Q2. At which ports/

airports/ border

crossings do you

import/ export your

goods? (Please list all)

Q3. Which are the

main countries from

which/ to which you

import/ export?

Q4. What type of

goods do you usually

import/ export?

Section 2: Customs clearance

Nearly Always Mostly Sometimes Rarely Hardly Ever

Q5. Is the customs clearance

process efficient?

Q6. Is the customs clearance

process clear,

understandable and

predictable?

Q7. How often are you

satisfied with the speed of

customs clearance?

-35-

Very Satisfied Mostly Satisfied Partly

Satisfied

Dissatisfied

Q8. (Importers/ exporters

only) How satisfied are you

with the service you receive

from your customs broker?

Q9. (Importers/ exporters

only) Please say what

aspects of your customs

roker’s perfor a e ould be improved.

Q10. Please list the 3 most

common causes of problems

with customs clearance.

Section 3: Information about regulations and procedures

Customs

website

Other customs

publications

(magazines,

journals,

brochures, etc)

Customs broker Trade

association

Others (please

specify)

Q11. What are your main

sources of information about

import/ export regulations

and procedures?

Entirely Mainly Only partly Not at all

Q12. How complete is that

information?

Q13. How accurate is that

information?

Q14. How up-to-date is that

information?

Very Easy Easy Moderately

Easy

Difficult Very Difficult

Q15. How easy is it to obtain

information about import/

export regulations and

procedures?

-36-

Very Easy Easy Moderately

Easy

Difficult Very Difficult

Q16. How easy is it to

understand that

information?

Nearly Always Mostly Sometimes Rarely Hardly Ever

Q17. Does Customs provide

adequate information when

regulations and procedures

are changed, or introduced?

Q18. Are you able to obtain

advance rulings from

Customs about regulations

and procedures?

Q19. Please make one

suggestion that would

improve your experience

with obtaining information

about regulations and

procedures.

Section 4: Customer service

Very Helpful Helpful Moderately

Helpful

Unhelpful Very Unhelpful

Q20. How helpful are

Customs officials when you

need information about

customs regulations and

procedures?

Very Well Quite Well Not Very Well Hardly At All

Q21. How well do Customs

officials understand your

requirements when you

request information about

customs regulations and

procedures?

-37-

Very Useful Useful Moderately

Useful

Not Particularly

Useful

Useless

Q22. How useful would it be

if Customs were to organise

regular meetings to provide

briefings on regulations and

procedures?

Section 5: Your suggestions

In the box below, please offer any suggestions for ways in which trade facilitation could be improved in Myanmar.

Thank you very much for completing this questionnaire!

Documents

Second survey of trade-related private sector in … survey of trade-related private sector in Myanmar ... or policies of the Asian Development Bank ... Questionnaire Design and Layout