Good Morning Africa: Global Trade Africa. Three trade doors are open for African goods, and each one asks the same question first: where was it made? Week of 19 October 2026.
African exporters have rarely had so many preferential doors open at the same time. The African Continental Free Trade Area (AfCFTA) now has a complete rule book for deciding which goods count as African. China has removed tariffs on goods from all 53 African countries it has diplomatic ties with. And in September the United States extended the African Growth and Opportunity Act (AGOA) to the end of 2028.
The common thread is easy to miss. A lower tariff is not something a product receives because it ships from Mombasa, Lagos or Durban. It is something a product earns by proving where it was made. That proof is governed by rules of origin, and the certificate of origin is the document that carries it. Speaking on the AfCFTA Secretariat’s podcast this month, the Secretariat’s rules of origin expert called the certificate the passport that lets qualifying goods claim preferential tariffs. This edition looks at what each door asks for, and the checks worth making before a shipment leaves.
| Trade door | Who it covers | How long | Origin proof it asks for |
|---|---|---|---|
| AfCFTA | Goods traded between State Parties whose tariff concessions are in force | Ongoing agreement; tariff cuts phase in by schedule | AfCFTA certificate of origin, or an origin declaration where allowed |
| China zero tariff | All 53 African countries with diplomatic ties; Kenya is one of 20 non LDCs | Two year preference for non LDCs, to 30 April 2028 | Certificate of origin, plus GACC registration, SPS papers and Chinese labels where they apply |
| AGOA | Eligible sub Saharan African countries | To 31 December 2028 | AGOA origin rules; for apparel, a textile certificate of origin and visa |
| EAC | Trade between EAC Partner States | Customs union rules in force | EAC certificate of origin |
1. Why Origin Is the First Question
Every preferential deal has to guard against the same risk: goods made elsewhere being routed through a member country to pick up a lower tariff. Rules of origin close that gap. They decide the economic nationality of a product, which is not always the country it shipped from, or even the country where it was packed.
In broad terms, a product qualifies in one of two ways. It can be wholly obtained, such as tea grown and picked in Kenya. Or it can be substantially transformed, meaning imported materials were worked enough in the exporting country to become something new. What counts as enough depends on the product: a change of tariff heading, a minimum share of local value, a cap on non originating materials, or a specific process that must happen locally.
The practical consequence is that origin starts on the factory floor, not at the port. By the time a container is booked, the evidence either exists or it does not.
2. AfCFTA: One Rule Book for a Continent
The AfCFTA rules of origin sit in Annex 2 to the Protocol on Trade in Goods, with the product specific rules in Appendix IV. For years a few sectors held up the full set. That is now settled. Trade ministers reached consensus on clothing and textiles and on automotive rules in Cairo in September 2025, and the African Union Assembly adopted the outstanding rules in February 2026. The Trade Law Centre (tralac) now records 100% of the rules of origin as agreed, and the Secretariat’s expert says the harmonised rules cover more than 5,000 products under the Harmonized System.
Three features matter most for traders:
- Cumulation. Materials that originate in one AfCFTA State Party can count as originating when they are processed in another. The Secretariat’s own example is a vehicle assembler in Ghana sourcing components from Egypt, Morocco, South Africa and Kenya, with those parts counting toward the vehicle’s African content.
- Light processing is not enough. Simple assembly, repacking, labelling and similar minimal operations do not turn imported goods into African goods.
- Proof travels with the goods. A certificate of origin is issued by the designated competent authority of the exporting country. Under the AfCFTA Rules of Origin Manual, an origin declaration on the invoice can take its place for approved exporters, or for consignments valued at up to US$5,000. Proof of origin is generally valid for 12 months from issue.
In Kenya, the Customs and Border Control department of the Kenya Revenue Authority (KRA) issues AfCFTA certificates of origin. Exporters register at a KRA Rules of Origin office, in Nairobi, Mombasa, Nakuru, Eldoret or Kisumu, and the originating status of their goods is verified before certificates are issued.
The weaker link is no longer the rules but the tariff schedules. A rule of origin only helps if the importing country has its AfCFTA tariff concession in force for that product. The February 2026 AU Summit asked trade ministers to bring revised modalities to the February 2027 Assembly, aimed at removing duties on all products traded within Africa. Use is growing: more than 12,000 AfCFTA certificates of origin had been issued and notified by March 2026. That is real progress, and also a reminder of how early the journey still is.
3. China’s Zero Tariff: The Door Is Open, the Paperwork Is Not
Since 1 May 2026, China has applied zero tariffs to goods from all 53 African countries with which it has diplomatic ties, across 100% of tariff lines. The 33 least developed African countries have had this treatment since December 2024. For the 20 other countries, including Kenya, Egypt and Nigeria, it applies as a two year preferential rate, which runs to 30 April 2028, while China works toward a China Africa Economic Partnership for Shared Development agreement to make zero tariffs a long term arrangement.
Zero tariff is not zero paperwork. Guidance published in Kenya when the policy began lists what exporters still need: registration with China’s General Administration of Customs (GACC), sanitary and phytosanitary certification such as KEPHIS phytosanitary certificates for plant products, Chinese language labels carrying the GACC registration number, traceability records, and complete shipping documents including a certificate of origin. For food, GACC registration normally covers both the exporter and the producing facility, and a missing number on the Chinese declaration can hold a consignment even when the duty is zero.
4. AGOA: The US Door Stays Open to 2028
AGOA has had a turbulent two years. It lapsed on 30 September 2025, was restored in February 2026 to the end of 2026, and was then extended again when H.R. 6500 was signed into law on 2 September 2026. The extension carries AGOA’s duty free treatment through 31 December 2028, and it keeps the third country fabric provision, which lets apparel assembled in eligible countries use yarn and fabric from outside the region. The US Senate Finance Committee described the two year extension as giving businesses certainty while it works on a longer term renewal. Kenya’s State Department for Trade adds that the law provides for refunds of eligible duties paid between the 2025 lapse and the new extension, through applications to US Customs and Border Protection within a 90 day period.
Origin rules still decide who benefits. For most goods other than apparel, US Customs and Border Protection requires that the article is the growth, product or manufacture of an eligible country, that any imported materials are substantially transformed there, and that at least 35% of its appraised value comes from local materials and processing, of which up to 15% may be US content. The goods must also be imported directly. Apparel follows its own rules, and those shipments need a textile certificate of origin and the exporting country’s visa stamp on the commercial invoice.
For Kenya the stakes are concrete. The State Department for Trade says more than 70% of Kenya’s textile and apparel exports go to the United States, and the sector supports more than 66,000 direct jobs. Cut flowers, tea, coffee and macadamia nuts also use the programme.
5. The EAC: Origin Closer to Home, and the One Test Deal
Inside the East African Community, the EAC Customs Union (Rules of Origin) Rules, 2015 decide which goods move at the community rate. The logic is familiar: goods wholly produced in a Partner State, or with enough processing there, qualify, and cumulation lets materials from one Partner State processed in another still count as originating. Kenyan exporters apply for EAC certificates through the same KRA Rules of Origin offices.
Origin is only half of what slows goods at an EAC border. The other half is standards and testing. At their second Joint Technical Committee on Trade in Kampala this month, Uganda and Kenya agreed to enforce a one test rule under a mutual recognition agreement: quality tests by accredited Ugandan laboratories are to be accepted in Kenya without a second round. That matters most for milk, fruit and grain, which spoil while they wait. Officials on both sides were frank that past commitments were not always carried out, so traders should watch how the rule works at Malaba and Busia before planning around it.
The same idea is spreading across the continent. At its General Assembly in Mombasa in August, the African Organisation for Standardisation (ARSO) set out its aim of one standard, one test and one certificate accepted everywhere in Africa, while noting that harmonised standards so far cover only 28% of the tariff lines submitted under the AfCFTA.
6. Kenya’s Import Side: Origin on Every Consignment
Origin is not only an export question. Since 1 October 2025, KRA has required that consignments imported into Kenya are accompanied by a certificate of origin issued by a competent authority in the country of export, under Section 44A of the Tax Procedures Act as amended by the Finance Act, 2025. KRA lists exceptions, including personal effects, used goods such as used motor vehicles, samples of no commercial value and some postal and courier parcels, and in exceptional cases it may accept other export documents to confirm origin, subject to verification. For importers, the supplier’s origin paperwork belongs on the checklist before the goods are paid for, not after the vessel sails.
7. Five Checks Before You Claim a Preference
- Classify first. Confirm the HS code of the finished product. The product specific rule, and the tariff you could save, both follow the code.
- Read the rule for that code. Check whether it asks for a change of tariff heading, a value threshold or a specific process, and whether cumulation can help you meet it.
- Map your inputs. List every material with its origin and value, and keep supplier declarations where materials come from another member state.
- Get the right proof from the right authority. AfCFTA, EAC, AGOA and China claims each rely on their own documents. Make sure each one is issued or declared in time and matches the invoice and packing list.
- Keep the file. Customs can verify origin after clearance, so keep production, costing and supplier records for as long as the importing country requires.
8. What to Watch
- 26 October 2026: KRA’s own RECTS seals stop operating for dry cargo and motor vehicles, and tracking moves to devices from KRA approved vendors. It is not an origin rule, but it belongs on the same documents checklist for transit cargo.
- The one test rule in practice: whether Ugandan test certificates are accepted at Malaba and Busia without retesting.
- February 2027: revised AfCFTA tariff modalities due at the AU Assembly.
- 30 April 2028: the end of China’s two year preference for non LDCs, unless replaced by the partnership agreement.
- 31 December 2028: AGOA’s new end date, and any progress on a longer renewal.
Closing Perspective
Trade preferences are only worth what a business can prove. The doors opened by the AfCFTA, China and AGOA are real, but none of them opens on its own. The exporters who benefit will be the ones who treat origin as part of production planning, keep clean records, and get their certificates right the first time.
Sources and Further Reading
- MyDailyNewsOnline, “AfCFTA Rules of Origin Unlock New Opportunities for African Businesses and Industrialisation” (AfCFTA Secretariat podcast), 15 October 2026.
- tralac, AfCFTA legal texts and policy documents: rules of origin, 2026; D&D Customs Law, “AfCFTA: state of negotiations and remaining regulatory gaps”, 5 October 2026.
- AfCFTA Secretariat, Rules of Origin Manual.
- Kenya Revenue Authority, AfCFTA frequently asked questions; Requirement for mandatory certificate of origin on imports into Kenya, 23 September 2025; public notice on the full roll out of electronic cargo tracking, October 2026.
- Xinhua via gov.cn, “China implements historic zero tariffs for all African nations with diplomatic ties”, 1 May 2026; Ministry of Foreign Affairs of China, Ambassador Guo Haiyan on the zero tariff policy, May 2026.
- The Star (Kenya), “Big opportunity for Kenya’s exports as China’s zero tariff offer kicks off”, 2 May 2026.
- US Senate Committee on Finance, “Crapo, Wyden Applaud Extension of Africa and Haiti Trade Programs”, 3 September 2026; text of H.R. 6500 and the AGOA text as amended on 2 September 2026.
- State Department for Trade, Kenya, August 2026 newsletter on the AGOA extension.
- US Customs and Border Protection, African Growth and Opportunity Act.
- East African Community, EAC Customs Union (Rules of Origin) Rules, 2015.
- Explorer Uganda, “Uganda and Kenya Agree on ‘One Test’ Rule to Stop Food Spoiling at Borders”, 13 October 2026.
- The Star (Kenya), “Africa urged to stop disjointed standards from blocking trade”, 27 August 2026.
Editorial note: This briefing reflects publicly available material reviewed as at 18 October 2026. It is general trade and logistics information, not legal, customs or tax advice. Rules and schedules change; confirm the latest official notices before acting on any point.
Sidoman provides customs brokerage, freight forwarding, warehousing and cross border transport across East Africa and beyond. To talk through your next shipment, message us on WhatsApp at +254 722 375 423 or visit sidoman.com.
Sidoman, Mombasa

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