Specifications… Complexities in the Guise of Digital Transformation

Habibullah Abdul Wahab*

The Sudanese Standards and Metrology Organization (SSMO) has issued a new protocol, No. (11) for the year 2025, specifically for its accredited international inspection companies. This protocol will come into effect at the beginning of the new year and includes the following:

Paragraph (4): “Inspection companies must submit inspection and analysis certificates to the SSMO for review and verification of the completion of conformity procedures before shipment. International inspection companies must also notify the supplier not to ship the goods before receiving the final conformity certificate from the SSMO.” This is known as Pre-Shipment Inspection (PSI).

Paragraph (6) states:

“International inspection companies will supervise the shipping procedures for goods after the issuance of the conformity certificate, attaching an inspection report that must include the general condition of the goods.” The message, preamble information, and batch numbers should be included, along with any other required documents.

Before analyzing the specifics of this new protocol, we must familiarize the reader with some fundamental rules and concepts governing the inspection of goods (in the case of imports) by international inspection companies accredited by the authority in the country of origin. These concepts include:

In the case of importing wheat, flour, sugar, asphalt, cement, and fertilizers, for example, the inspection and analysis process is carried out on a sample taken from the entire shipment or from different packages if the shipment is fragmented in terms of time and location. This is done using a scientifically recognized method, known as Shipment Inspection. The results are then approved by the authority if they meet the acceptable limits of the specification or quality, also known as AQL (Acceptable Quality Limits). This is a common and accepted method, and it is also suitable in terms of time and cost. All international inspection companies have followed it for years and continue to do so. This method does not require inspecting the goods piece by piece, as is the case with the Piece by Piece Inspection method (a costly and time-consuming method used for high-risk goods). However, it is important to understand that the specifications, according to the first method, require certain analyses that usually take 10 days from the date of sample collection, especially in the case of food products, in addition to the period of the conformity procedures themselves before the technical conformity committee. The process, which can sometimes take a week or 10 days if it includes weekends, means that the goods will be in the seller’s (exporter’s) possession for at least 20 days before shipment, as stipulated in the protocol. This is because shipment is contingent upon the issuance of the final certificate of conformity.

At the same time, it is crucial to understand that the validity of analysis and inspection certificates issued by inspection companies is limited to the time and place of issuance. These companies are not responsible for any modifications or changes that may occur to the goods, intentionally or unintentionally, during the waiting period, as there are no guarantees to prevent such alterations.

Based on the simplified explanation we have provided, we can conclude that this protocol contains numerous practical risks and problems, including:

A major disaster could occur if we realize that goods other than those inspected and analyzed might be shipped. This is a possibility to some extent, and it would constitute a clear violation of the principle of ensuring the quality and safety of goods and protecting the consumer. This serious transgression is likely, especially since there are no guarantees to prevent it except for the good intentions of the shipper or exporter, which is obviously unreliable in import operations, particularly for high-value shipments. Furthermore, the risk increases the longer the shipment remains in the seller’s (exporter/shipper’s) possession. However, the risk here is not limited to violating quality standards and limits, but extends to the loss of the transaction’s capital.

In addition to all this, it’s important to understand that the importer will bear the costs of storing and insuring the goods in the country of origin during the waiting period. These costs are unavoidable, given that the goods slated for shipment are already contracted for and are considered the importer’s property, even though they are not in their possession. Furthermore, the shipping delay is at the importer’s own request, in accordance with the new protocol.

One of the complications arising from this new protocol is that the authority has not stipulated a pre-shipment timeframe, leaving the door open for the importer. If they adapt to the storage and insurance costs, they may wait longer for any arrangements they deem appropriate, potentially exceeding the 20-day period. This opens the door to potential compromises in product quality and safety standards, risks that the importer may not even be aware of. Disruptions and delays in the supply (import) timeline are not unlikely, as the new protocol practically imposes a 35-day delay that necessarily begins after the contract is signed between the two parties. This delay is calculated as follows: (10 days to complete inspection procedures + 10 days for final conformity procedures + 15 days for shipping arrangements). Furthermore, the importer will have to wait for notification from the inspection company regarding the issuance of the final conformity certificate.

Before the importer or the shipper, according to the delivery terms (FOB or CFR), proceeds with final shipping arrangements, as stipulated in paragraph (4), the shipping arrangement period becomes unavoidable. This is because, generally, no vessel or container is always readily available. Consequently, the supply of imported goods in the local market, whether finished products or raw materials, will be negatively impacted by this delay. As a result, prices will rise, and ultimately, the burden of all this will fall on the helpless citizen/consumer.

On the other hand, although the Authority requested international inspection companies in paragraph (6) to monitor the shipping process to ensure the conformity of the batch numbers affixed to the shipment during the inspection phase and then issue a detailed report along with the standard shipping documents, this procedure is essentially meaningless. It comes after the issuance of the Final Conformity Certificate (CoC), and moreover, the shipping monitoring process itself is conducted under the guise of general observation. This is in addition to new financial burdens (monitoring expenses) borne by the importer and ultimately passed on to the consumer.

Perhaps the pressing question here is: how did the Authority operate before the announcement of the new protocol? What protocol were the international inspection companies themselves following, and what were its shortcomings? To answer this question, and based on our experience, we can say that the previous protocol relies on conducting inspections and analyses during the loading process (At Time of Loading). The inspection itself is carried out using the Shipment Inspection method, which is the same as the new protocol. However, the key difference between the two methods is that the previous protocol links the inspection results to the bill of lading, which contains all the details of the shipped goods, and that the inspection and loading processes are carried out simultaneously. This ensures that the goods shipped are the same as those inspected. Therefore, we can conclude that the previous protocol achieved a high degree of confidence in the specifications of the shipped goods. However, a drawback of the previous protocol is that some analysis results are issued during the voyage, which may increase the possibility that these results do not conform to the approved specifications, which is a real possibility. Nevertheless, the deviation rate from the acceptable limits of the AQL standard is the same in both methods because the inspection method in both protocols is the same: Shipment Inspection.

In conclusion, the PSI (Pre-Shipment Inspection) system is an older protocol followed by several countries worldwide, similar to the previous At Time of Loading (ATW) protocol. However, it is not without its flaws and significant shortcomings, especially when the shipment involves foodstuffs.

In our specific case, we can confirm that the new protocol offers no advantage over the previous one, except insofar as it introduces new complications and obstacles. These include unjustified delays in the supply period and new costs directly related to storage, insurance, and additional inspection expenses, all of which become part of the product’s cost. The current situation and the circumstances surrounding the country compel us to avoid complications as much as possible; otherwise, we will be like the proverbial on “trying to fix it, only made it worse.”

*An International Trade Expert

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