NATIONAL REUSE AND RECYCLERS’ ASSOCIATION

(NARRA)

RESEARCH TO ESTABLISH THE IMPLICATIONS OF THE CURRENT IMPORT

DUTIES ON RECYCLING EQUIPMENT ON THE RECYCLING INDUSTRY IN
GHANA

AS PART OF

AN ADVOCACY ACTION FOR THE ADVOCACY FOR THE ABOLITION OF

IMPORT DUTIES ON EQUIPMENT AND MACHINERY FOR RECYCLING IN
GHANA

SUBMITTED TO

BUSINESS SECTOR ADVOCACY CHALLENGE (BUSAC) FUND

MARCH 2018
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EXECUTIVE SUMMARY

In Ghana, as outlined in the 2010 Environmental Sanitation Policy, the bulk of environmental
sanitation services are to be provided by the private sector, including NGOs and community based
organizations under the supervision of the Metropolitan, Municipal and District Assemblies
(MMDAs). Market-based approaches are widely promoted to enable the delivery of sanitation
products and services. Over the last ten years, much work has been done on understanding the
market dynamics, products, services and costs relating to sanitation, and the private sector’s
interest in the sector has grown significantly.
However, the private sector has not been able to create mass demand for appropriate products and
services for low-income urban centres (LIUCs). Challenges to achieving demand at scale from
LIUCs are multiple and can be attributed to:
i) internal capacity of businesses to grow and operate;
ii) the overall business environment; and
iii) factors relating to the wider market system.
Ghana has waste management difficulties that extend from the national to the district level, and
refuse of all shapes and sizes is a common site in both urban and rural areas. These difficulties are
concentrated and complicated by population pressures in the few heavily populated cities of which
Accra is the most prominent. Ghana has transitioned from a low income country to a lower middle
income country. This phenomenal growth has contributed to municipal waste production that far
outstrips the country’s capacity for containment and processing. The confluence of poor
governance and human factors (such as indiscriminate dumping) has resulted in a city environment
characterized by choked drains, clogged gutters, and garbage piles heaped in the open. The sanitary
infrastructure of Ghana is reflective of the income divisions.
Ghana’s main economic tool for economic transformation is government support and promotion of
the private sector. Advocates of privatization believe that for-profit competitive systems increase
efficiency and better calibrate supply and demand. Supporting waste recycling companies to clear
the piling waste would not only stimulate development of better pollution control technology and
expertise but also enhance the aesthetic view of our city and create jobs for our teeming youth.
Much as the government of Ghana is poised to unleash the energies of the people through creating
an enabling environment such as the one embedded in the one-District-one-factory programme,
the recycling industry is yet to be at the forefront of this laudable programme due to a myriad of
problems. The fact that these recycling machines and equipment are imported makes their situation
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even more precarious as they have to contend with the high import duties at the ports. This is
exacerbated by the high cost of energy and separation.

Based on the key findings and conclusions of the study, it recommended that there is the need to
develop a clear policy to develop the recycling industry to create jobs and clear the mounting
waste through tax waivers on imported machinery at the ports of entry. It is further recommended
that Government should engage more actively with all stakeholders in the recycling sector in the
context of finding new and more suitable tax and administrative levies intervention for the
recycling sector. This will help reduce the fold up of operating businesses in the recycling
industry.

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 ACKNOWLEDGEMENTS

The priceless contribution to this research of the following individuals and organizations is
gratefully acknowledged. In particular, we would like to acknowledge and express our
profound gratitude to the partnership of the Business Sector Advocacy Challenge fund
(BUSAC Fund) in this survey and to the many respondents from our stakeholder groups who
took the time and trouble to share their thought, experiences, insights and materials.

Planning and data collection

Mr. Eric Pappoe (President, NARRA), made a significant contribution to the research planning
processes. He also organized and supervised the role of their staff and members in the data
collection. Field testing of the survey instrument, as well as its distribution, follow-up and
collection, were coordinated by Management and Staff of SMILE.

Data base
Marceline Dzandu advised on the development of the research instrument. Reseth Bimpong of
Christian University College, and Mr. Osumanu Mansur contributed to data collection and
entry process. Kofi Kyeremeh and Charlotte Okyere contributed to data analysis.

Respondents
We hereby acknowledge all key respondents and the various affiliate members of NARRA
who made available their members and facilities for data collection. Special thanks also goes to
officials of the Ministry of Sanitation and Water Resources, Customs, Exercise and Preventive
Service (CEPS) of the Ghana Revenue Authority and the Ghana Statistical Service for the
diverse role they played in the data collection stage of this research

Proof Reading
Comments on earlier drafts of this report by the following people are gratefully acknowledged:
Raymond Ching-Tilung (GHA-BAF Consult) and Festus Owoo.

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 TABLE OF CONTENTS
Executive Summary....................................................................................................................1
Acknowledgements.....................................................................................................................3
Table of Contents........................................................................................................................4
List of Abbreviations and Acronyms..........................................................................................5
Introduction.................................................................................................................................7
Problem Statement.......................................................................................................................8
General Goal...............................................................................................................................9
Limitations..................................................................................................................................10
Literature Review......................................................................................................................11
Tax incentives..............................................................................................................................12
Effect of Tax Incentives on Economic Growth……………………………...............................14
Tax Incentives in Ghana..............................................................................................................16
Exemptions, Zero -Rating and Remissions.................................................................................17
Tax Holidays – Special Economic Zones……………………………………………………... 18
Capital Allowance/Deduction......................................................................................................18
Recycling Potential and Re-Use………………………………………………………………..20
Research Approach and Methodology........................................................................................23
Study Results and Discussion ....................................................................................................25
Distribution of Respondents by Waste Interest…………………………..................................27
Description of Problem confronting NARRA members……………………….........................31
Impact of High Tariffs on recycling industry in Ghana..............................................................33
Difficulty securing foreign Investment Partners.........................................................................35
Existing Investment Incentives for Recyclers in Ghana..............................................................36
Conclusion…………………………...........................................................................................38
Recommendations.......................................................................................................................39

Reference………………………………………………………………………………………40

4
List of Abbreviations and Acronyms
ABP Animal By-Products Regulation
AD Anaerobic Digestion
ADB African Development Bank
AMA Accra Metropolitan Assembly
BCC Behaviour Change Communication
BSE Bovine Spongiform Encephalopathy
BUSAC Business Sector Advocacy Challenges Fund
CCC Communal Container Collection
CCW City and Country Waste
CDC Center for Development Communication
DEFRA Department for Environment, Food and Rural Affairs
DTIE Division of Technology, Industry and Economics
EHSD Environmental Health and Safety Department

EPA Environmental Protection Agency

EPD Environmental Protection Department
ESP Education Strategic Plan
FOEN Federal Office for the Environment
GDA Ga Development Authority
GHG Green House Gas
GLFPSF Ghana Land and Forest Policy Support Facility
HH House to House
IBD Industrial Building Deductions
IEA International Energy Agency
IETC International Environmental Technology Centre
IPCC Intergovernmental Panel on Climate Change
ISEB Information Systems Examinations Board
ISWM Integrated Solid Waste Management
JICA Japan International Cooperation Agency
MDG Millennium Development Goals
MESTI Ministry of Environment, Science, Technology and Innovation
MINT Material-in-transition

5
MLGRD Ministry of Local Government and Rural Development
MSW Municipal Solid Waste
NARRA National Reuse and Recyclers Association
NESSAP National Environmental Sanitation Strategy and Action Plan
NGO Non-Governmental Organizations
NOAA National Oceanic and Atmospheric Administration
OECD Organization for Economic Co-operation and Development
PAYT Pay-As-You-Throw
PET Polyethylene Terephthalate
PNDC Provisional National Defense Council
SDAP State Development Assessment Provisions
SWM Solid Waste Management
TMA Tema Metropolitan Assembly
UNCSD United Nations Conference on Sustainable Development
UNDP United Nations Development Programme
UNEP United Nations Environment Programme
UNFCCC United Nations Framework Convention on Climate Change
VBFS Volume Based Fee System
WCED World Commission on Environment and Development
WFD Waste Framework Directive
WHO World Health Organization
WMD Waste Management Department
WRAP Worldwide Responsible Accredited Production

6
 INTRODUCTION
Background
Currently described as a lower-level middle income country, Ghana aspires to attain a higher
middle-income status by 2020. It is a consequent that a healthier and wealthier population will tend
to generate more waste and of varied types (domestic, commercial, institutional, industrial and
hazardous). There is, therefore, the need for urgent action based on a clear national strategy
(policies, plans and programmes) to manage this trend, supported by sustainable financing and
active participation of all stakeholders at all levels.

One of the guiding principles of the Revised National Environmental Sanitation Policy of Ghana is
for all waste to be considered as Material In Transition (MINT). This principle is given further
credence in the National Environmental Sanitation Strategy and Action Plan (NESSAP) where the
Materials in Transition (MINT) concept serves as a driver for changing the perception of
Ghanaians on all types of wastes and thus affect our sanitation behaviour. The philosophy of
MINT is that waste is a material resource which is not to be discarded but value added on at
various stages while in transition within the production and consumption cycles. This has the
potential of creating green jobs and reducing Ghana’s Metropolitan, Municipal and District
Assemblies (MMDAs) cost of managing wastes.

At the West African Clean Energy Environment (WACEE) conference, held in Accra from 13-15
September 2016, it was disclosed that a feasibility study on plastic waste by the Centre for
Scientific and Industrial Research (CSIR) in 2015, indicated that GHC1,200,000 can be generated
in the country every a month, if the plastics alone go through various stages towards recycling. The
stages include collection, sorting and sale as raw material plastic waste recycling firms. More
importantly each of these stages will generate thousands of employment for people engaged in the
plastic waste value chain.

This, naturally, should attract various forms of investments into the plastic recycling business in
Ghana. However, current taxes and administrative levies are a major disincentive to recycling firms
and would be investors industry. The effect of this current fiscal regime for plastic recycling in
Ghana, coupled with other relevant costs of doing business in the country combine to deny the
Ghanaian economy of the enormous benefits that could be derived from a thriving plastic waste
recycling industry in the country.
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It is therefore imperative for government to take a critical look at its tax incentives on not only the
plastic waste but also general waste recycling in Ghana as a mechanism to:
1. promote investment in the right machinery needed for the waste collection, reuse and recycling
industry to help achieve government's vison of industrializing Ghana under the one-District-one-
Factory (1D1F) policy.
2. enhance the economic value of waste in general to serve as a disincentive against public littering
and promoting sound environmental consciousness.
3. boost the waste recycling industry as a viable means of curbing the waste menace confronting
the country and turn it around to create jobs for our teeming unemployed youth.

Incidentally, the imposition of heavy import duties on recycling equipment and machinery have
become a major obstacle towards the growth and development of the recycling industry in Ghana.
This situation is further complicated by the tedious bureaucracy involved in applying for tax
exemption in a process that is heavily influenced by cronyism and political considerations.

It is against this background, that NARRA found it imperative to commission this study as part of
the strategy for the prosecution of an advocacy action under the auspices of the Business Sector
Advocacy Challenge (BUSAC) Fund Phase III tax exemptions on the importation of equipment and
machinery designed for recycling purposes in Ghana.
Problem Statement
The current domestic waste generation in Accra is estimated at 2,000 metric tonnes daily of
which about 1,200-1,3000 tonnes is collected (AMA –WMD, 2010). The growing volume of
uncollected solid waste is of grave concern having in mind the accompanying public health
implications.

Changing lifestyles and consumption patterns of the growing urban middle class in particular, is
likely to increase the complexity and composition of the waste stream. However, waste
characterization data specific to African cities is generally not available (UNEP-DTIE, 2012).
The limited data means gaps between waste management policy and legislation and actual waste
management practices are widening. This is further compounded by capacity constraints and lack of
waste management facilities for various waste streams across the country. Access to major
investments and the acquisition of the required technical know-how needed to resolve the capacity
constraints remain a tall order.

This implies that most of the waste generated is either disposed of straightaway at the landfill
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site, which is a threat to the lifespan of the facility or discreetly dumped into available and
unprotected open space across the metropolis. Also lack of recycling activity means fractions of
the waste which could serve as a source of raw materials are left to remain in the waste stream.

There is ample anecdotal evidence to suggest that the absence of any tax incentive on the
importation of equipment and machinery used in the waste collection and recycling industry in
Ghana is a major barrier to the development of a viable waste collection, reuse and recycling
business. The high tariffs on such equipment and machinery are making the cost of doing business
in this recycling industry very expensive and unattractive to investors as industrial actors are unable
to invest in the required machinery and technology.

General Goal
The general goal of this research is to compile a body of evidence that will be useful to the
implementation team for the advocacy action by NARRA, to ensure that they are able to show
evidence of how the current tax regime in constricting the growth of recycling in Ghana and how
the introduction of appropriate import tax exemptions would open up the sector. In pursuance of
this goal, this research aimed at achieving the following specific objectives:
1. To describe the state of the reuse and recycling industry in Ghana
2. Highlight the socio-economic potential of the reuse and recycling industry in Ghana
3. Examine the challenges confronting the reuse and recycling industry in Ghana
4. To examine the various taxes paid by reuse and recycling firms in Ghana
5. To make recommendations on how NARRA can proceed with this advocacy in order to
achieve the expected outcome.

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 Limitations
A number of material and time constraints narrowed what the researchers were able to
accomplish in this study.
Time, Resources, Limited Logistical Support: Due to limited time, available resources and logistical
support, a more thorough waste stream analysis - including a moisture content and calorific
content analysis – could not be conducted. These analyses require the use of sophisticated
scientific equipment (i.e. waste shredders, solar dryers, high temperature ovens, incubators,
desiccators, bomb calorimeters, hygrometers, etc.), which the research team did not have at their
disposal. In addition, the drying process for each sample analysis can take up to nine days --
an impossibility, given the time restrictions that were an unfortunate but necessary condition of
this first study. Given these constraints, the study was limited to an analysis of waste
composition by weight. The research team’s calculations are based on the wet weight of material.
Also, past waste composition studies have demonstrated seasonal differences. It is possible that
one location's waste composition might differ f r om an ot h e r l o c at i o n 's w a st e composition;
however, the researchers were unable to account for seasonal variability in their analyses due to
time restrictions.
In addition, lack of proper technology limited the research team’s ability to properly separate out
inert materials from bulk waste. Therefore, no separate category for inert weight is included in
this analysis. Inert material was mixed into organic weight at source. However, the calculated
value for total “compostables” (including both organics and inert material) should be given
greater credence, as this is more important for determining suitability for municipal composting
programs. Conversely, this limitation has the potential to overestimate the value for
“combustibles,” since organics are combustible material, whereas inerts are not defined as
“combustibles.”
Sample Size and Compliance Issues: Lack of compliance from participants during the study
reduced the number of overall samples we were able to obtain. House ID #1 was not utilizing the
provided waste bin and was reassigned for the final two remaining pick-ups. In addition, we
were unable to determine if all houses were utilizing the bin for all of their accrued waste
throughout the term of the study. There may therefore have been additional waste generated
from the selected households during this time that was not accounted for in our study.
In addition, obtaining a larger sample size for our study would have been ideal. However, due
to time restraints and limited logistical support as mentioned above, twenty houses was the
maximum sample size the research team could realistically include in order to properly manage
the study.

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 LITERATURE REVIEW
Tax reforms are meant to ensure that the three main objectives of a good tax system are met.
These objectives include :
1.Raising tax revenue for funding government operations without excessive government
borrowing,
2. Ensuring to equitable distribution of income in a nation and
3. Encouraging or discouraging specific activities.
However, implementing tax reforms to meet these goals of an ideal tax system have remained a
challenge. There have been debates on whether and to what extent the government should use the
tax system for policy goals other than raising tax revenue. Raising tax revenue is a key objective
of Ghana’s tax system and therefore, the government must strike a balance between the ever
increasing competing development needs and the desire to encourage investments through low
tax regimes. It is the consideration of the latter that has seen the government of Ghana, like other
countries, implement tax incentives on the assumption that taxation is an appropriate policy
instrument in attracting investments (IEA,2012)
From the view of economists, a tax is a compulsory contribution of resources from the private to
the public sector or government levied on a basis of predetermined criteria and without reference
to any specific benefits received by the tax payer Governments levy different types of taxes at
varying tax rates to distribute the tax burden among persons involved in taxable activities or to
redistribute resources within the society. In addition, taxes are levied by the government to
influence the macroeconomic performance of the economy through its fiscal policy – more
specifically the taxation policies and to adjust patterns of consumption or employment within an
economy, by making certain transactions more or less attractive (Goode, 1984). Taxation is
necessary because it is neither feasible nor desirable for governments to finance their projects
solely through charging for services (Goode, 1984). Taxes are justified as they fund activities
that are necessary and benefit the majority of the population and social development -Taxes are
the price of civilization (Holmes, 1904). Not everyone in the society agrees with the principle
that governments must levy taxes. An anarchist in Russia, Emma Goldman wrote that the State
itself is the greatest criminal, breaking every written and natural law, stealing in the form of
taxes. This view is held by some political philosophies who view taxation as theft or extortion
because payment of tax is compulsory and enforced by the legal system. The view that
11 | P a g e
 democracy legitimizes taxation is rejected by those people who argue that all forms of
government policies or laws are oppressive and therefore, taxation is viewed as producing the
same result as theft, the difference between government and thievery being mostly a matter of
legality (Williams, 2008). While the morality of taxation is sometimes questioned, most
arguments about taxation revolve around the degree and method of taxation and associated
government spending, not taxation itself.

Tax Incentives

UNCTAD defines tax incentives as any incentives that reduce the tax burden of any party in
order to induce them to invest in particular projects or sectors. They are exceptions to the general
tax regime and may include, reduced tax rates on profits, tax holidays, accounting rules that
allow accelerated depreciation and loss carry forwards for tax purposes, and reduced tariffs on
imported equipment, components, and raw materials, or increased tariffs to protect the domestic
market. KRA defines tax incentive as a provision that grants any person or activity favorable
conditions that deviate from the normal provisions of the tax legislation. Tax expenditures refer
to revenue losses that a government incurs by providing tax exemptions, deductions or
allowances, tax credits, preferential tax rates or deferral of tax payments legally to any party in
the economy (Gruber, 2005). The budget deficit of a government is a form of a negative saving
and a reduction in the deficit can positively influence the net national savings more than any
feasible changes in tax policies and encourage savings within an economy which will then
stimulate investments (Goode, 1984)

Countries offering tax incentives may benefit through non economic gains from industrialization,
creation of jobs, transfer of technology and training and an increase in tax revenues if the entities
will exist in the long run and pay taxes (Gray, 1987). Some researchers have also concluded that
investment decisions are fairly sensitive to tax incentives and therefore they suggest that the tax
policy is a powerful tool in determining investments flow (Gruber, 2005). These benefits are
meant to contribute to higher economic and employment growth rates and reduce poverty levels.

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 Economic Growth
Economic growth refers to an increase in the capacity of the economy to produce goods and
services compared from one period to another. It can be measured in nominal terms, where it is
not adjusted for inflation, or in real terms, where it is adjusted for inflation. The growth of an
economy is thought of not only as an increase in productive capacity but also as an improvement
in the quality of life to the people of that economy and it is associated with technological
improvements. Gross Domestic Product (GDP) refers to the monetary value of all the finished
goods and services produced within a country's borders in a specific time period. It includes all
of private and public consumption, government outlays, investments and exports less imports
that occur within a defined territory and is measured annually. GDP is commonly used as an
economic indicator of the overall health of an economy, as well as to measure the standards of
living in a country (Lipsey & Chrystal, 2007).
Fiscal policies are concerned with government spending and taxation policies. The burden of
resource mobilization to finance essential public development projects must be focused on how
the government will raise adequate revenues for its development efforts. In the long-run, the
government can only rely on the efficient and equitable collection of taxes as a more sustainable
way to raise revenue to meet its development goals (Todaro & Smith, 2003). The key question
however remains whether by offering huge tax incentives governments in developing nations
have been able to increase investments to the extent of increasing economic growth rates and
improving the welfare of its citizens. Studies in both developed and developing nations suggest
that tax incentives are an inefficient and expensive way of encouraging investments. Most
studies show that the most important determinants of FDI in developing countries consists of
long term considerations affecting profitability , market size and market potential (Irish, 1978).
Therefore, for the government to be effective in its role of providing quality public goods or
services to its citizens and also fund its development projects which are key determinants of
investment location decisions, it has to implement policies that will enable it raise adequate
revenues to meet its budgetary requirements. The Ghanaian government mainly raises its
revenues through taxation and over the years it has been increasingly difficult for the Ghana
Revenue Authority (GRA) to meet its revenue targets. Failure by the institution to raise more
revenue and meet budgetary targets implies that budget deficits will continue to be experienced
unless proper policies are put in place to seal all revenue loopholes.

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 Effect of Tax Incentives on Economic Growth
There is often interest in assessing the economic impact of an economic policy which may be
viewed in terms of business output, value added, wealth, personal income or employment. Any
of these measures can be an indicator of the improvements in the economic well-being of
residents, which is usually the goal of economic development efforts. The net economic impact
is usually viewed as the expansion or contraction of an area's economy (Weisbrod, 1997)

Gruber (2005) stated that most countries have perennial budget deficit issues because they adopt
ex-ante Balanced Budget Requirements (BBRs) rather than ex-post BBRs and Ghana is no
exception to this situation. Ex ante BBRs requires legislature to pass budgets that are balanced at
the beginning of each fiscal year while ex post BBRs require governments to balance their
budgets by the end of each fiscal year a situation which may ensure that the government takes
measures to collect sufficient revenues to meet its expenditure requirements and spur economic

growth. McEachem (1988), states that there is no relationship between budget deficits and the
measures of economic performance. He observes that the budget deficit is the result of fiscal
policies implemented by the government from either automatic economic stabilizers for example
through taxation during recession when output and employment declines or policies aimed at
increasing aggregate spending. However, Begg et al (2005) observes that budget deficits may be
a poor measure of the government’s fiscal policy because deficits can occur due to other reasons
other than fiscal policy for example a decrease in the demand for investments will reduce output
and incomes causing a decline in tax revenues.

Morisset & Pirnia (1999) observed that the relative little importance of tax policy does not mean
that it does not have an impact on FDI. A good example is Ireland and many other tax havens
whose tax policies have been generally recognized as a key factor in their success to attract
international investors to those countries. Therefore, taxation policies do affect the decisions of
some investors in choosing a suitable location for their investments. Foreign investors have many
alternative methods of structuring and financing their investments and arranging their
transactions between related parties located in different countries to ensure maximum returns on
their investments. These alternatives have important tax implications which show that tax
considerations influence the choices that firms make. The impact of tax rates on investment

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 decisions is generally higher on export-oriented companies than those seeking the domestic
market or location-specific advantages hence a more positive response to tax incentives (Goode,
1984).

For many decades, Ghana has been unable to balance its budget and therefore, meet its financial
requirements to fund its development projects. Some people blame the deficit on the growth in
spending by the government, as is the case of conservatives in the U.S., while others counter that
an insufficiently progressive tax system is failing to raise adequate revenues needed for valuable
government projects, as it is the case with the liberals in the U.S. Karl Marx also observed that
progressive tax systems alone are very inefficient in an economy. The persistent budget deficits
could therefore, be due to a clash between those opposing a raise in taxes and those opposing a
cut in government expenditures or it could be something deeper, a structural problem with the
very nature of the budgeting process (Gruber, 2005).

A study conducted on The Tax Policy for Investment by the working group of the MENA-OECD
Investment Program (2007), established that there are a wide range of incentives in MENA
countries. The question however, remains why most developing countries including Ghana still
offer a wide range of expensive tax incentives while they are faced with huge budget deficits and
slow economic growth rates. Governments offer tax incentives to investors simply to attract
more FDI hence increasing investments in the country to increase GDP and employment rates
(TJN–Africa, 2011). Studies indicate that many investors prefer transparency, simplicity and
efficiency in the business environment, political and economic stability and certainty in
application of tax law and in tax administration. Tax incentives are not very effective in
attracting investment and they proposed that the best practice is to discourage the use of
incentives in favor of reduced corporate tax rates on a broad base and if tax incentives must be
offered, then there is need to review the design and assess its effectiveness (OECD, 2007)

While many parties prefer minimum taxes and where possible lobby the government to remove
taxes, the government is placed in a tight position on how to balance between the demands of its

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citizens and interested investors and the budgetary income demands. As inflation and the cost
of living rises, the only sure way to improve the economic conditions is by reducing
significantly the cost of production in an economy and encouraging economies of scale. This
can only be achieved through government expenditure on development projects that will spur
economic growth for example infrastructural and technological enhancements and the citizens
must be willing to pay for these expenditures. Lipsey & Chrystal (2007) stated that
governments spend money to achieve their objectives and it must either borrow or tax.
Borrowing is a temporary measure and interest must be paid. If too much is borrowed the
government debt will get to unmanageable levels (Ghana is currently edging close to the
ceiling debt level of Ghana Shillings1.2 Trillion) and at one point government spending must
be paid out of taxes, borrowing only postpones the need to tax. This shows the urgent need for
the government to seal any revenue loopholes in the economy if it has to implement its
development projects and achieve the Ghana Vision 2030 goals.

Tax Incentives in Ghana

Tax incentives in Ghana can be grouped into either investment promotion incentives or export
promotion incentives. Investment Promotion Incentives include Investment Deduction
Allowance which was Introduced in 1991 to encourage investment in physical capital such as
industrial buildings, machinery and equipment, Industrial Building Allowances which was
Introduced in 1974 with the objective of encouraging investment in buildings used for
industrial purposes like hotels and manufacturing plants., Mining Deductions Allowance which
was Introduced to encourage investors to venture into the mining industry which is very
capital intensive and Farm Works Deductions which was Introduced in 1985 to encourage
investment in the agricultural sector. Export promotion incentives program has three main
schemes which include the Export Processing Zones (EPZ’s), Manufacture under Bond (MUB)
and the Tax Remissions and Exemption Office (TREO). The objective of EPZ’s is to generate
and encourage economic activity and foreign direct investments while MUB and TREO
regimes were meant to encourage investors to manufacture for export within the country.

16
OTHER TAX INSTRUMENTS THAT CAN BE USED TO STIMULATE GROWTH IN
THE RECYCLING INDUSTRY IN GHANA

Tax Holidays
Also tax holidays are indefinite for cocoa farming; 3-10 years depending on sector; 10 years for
free zones with eight percent corporate tax thereafter, tariff exemption, 100 percent, 100 percent
duty exemption for production equipment as well as carry forward losses for all companies
except mining and insurance. While insurance companies can carry forward losses indefinitely,
mining companies are allowed to carry forward losses but restricted to only capital allowances
granted for the year.

Exemptions, Zero -Rating and Remissions

Tax exemption refers to a case where a good or service is not chargeable to tax under the
law while zero rating refers to a case where the tax rate applicable for the good or service is zero.
There are various exemption and zero rating regimes in Kenya. Certain goods, services, bodies
and individuals have the tax exemption or zero rated status under the VAT Act. The ITA also
exempts certain classes of incomes or incomes of specific bodies from corporation tax. A
party either individual or institution can also apply to the National Treasury for tax exemption
or tax remission on specific circumstances and the Minister has the power to grant such
requests if there is adequate justification. However the current constitution provides that all
persons should pay taxes and the Government seeks to scrap these provisions. Companies
that import raw materials and manufacture goods for export can also get tax remission
status for the exports under the Tax Remission Exemption Office (TREO) arrangement. These
companies already have a tax advantage since the materials imported usually do not attract
any customs duty or value added tax except industrial sugar which is taxed at a low rate of
10% as customs duty. The disadvantages of giving tax exemptions, remissions and zero rated
status for exports is that it results in substantial leakage of untaxed goods into the domestic
market thus eroding the tax base.

17
Tax Holidays – Special Economic Zones
SEZs are designated areas in a country that possess special economic regulations that
are different from other areas in the same country. The regulations tend to contain measures
that are conducive to foreign direct investment including tax incentives and the opportunity to
pay lower tariffs. In Ghana companies operating in Free Zones enjoy a tax holiday and a
reduced corporate tax rate for the next 10 years (ITA, 2010). Tax holidays have many
disadvantages if not designed and controlled properly. First, it attracts short term projects
because once the period for the tax holiday is over, businesses soon wind up and move out to
invest elsewhere (Blackwell, 2009). It also encourages tax avoidance by allowing businesses to
move from high tax regions to low tax regions – tax avoidance is not illegal but it certainly is
unjust and administration costs to ensure compliance with all laws and accurate reporting may
be high (Irish, 1978).

Capital Allowances / Deductions

The law, under the income Tax Act provides for various capital allowances. These incentives
are mainly intended to encourage investments in the country and since the year 2010,
the government even sought to encourage investments outside the main cities by giving higher
incentives to businesses setting up businesses in such areas. Though the main goal is to
increase investment and improve economic standards, the system is prone to abuse and
requires constant monitoring to ensure its efficiency.

Investment Deduction
This is given to companies upon construction of a building and on the purchase and
installation of new machinery used for the purposes of manufacture or for the following
ancillary purposes: generation, transformation and distribution of electricity; clean-up and
disposal of effluents and other waste products; reduction of environmental damage; water
supply or disposal; and workshop machinery for the maintenance of the machinery.
Currently companies claim ID at 100% and those who invest outside the three cities in Ghana
claim at 150%. (ITA, 2010)

18
Industrial Building Deductions
The ITA (2010) provides for IBD deductions at a rate of 2.5% or 10% for hotels. The cost
includes capital expenditure incurred on the construction of an industrial building used
for business and any civil works or structures if they relate or contribute to the use of the
building including: roads and parking areas; railway lines and related structures, water,
industrial effluent and sewage works; communications and electrical posts and pylons, other
electricity supply works; and security walls and fencing.

Farm Work Deductions

The owner or tenant of agricultural land is allowed 33.3% capital expenditure on the
construction of farm works for three years. Expenditure considered includes costs the on a
farm-house and any asset used for the purpose of husbandry (ITA, 2010).

Shipping Investment Deductions

A resident person who is a ship-owner is allowed 40% in the first year and 10% in subsequent
years for capital expenditure incurred on the purchase of a new and unused power driven ship of
more than 495 tons gross; or on the purchase, and subsequent refitting of a used power-
driven ship of more than 495 tons, used for business (ITA, 2010).

Tax Credits and Double Taxation Treaties

The ITA, 2010 provides for deduction of foreign tax payable in respect of income derived by a
person resident in Ghana as a credit against tax chargeable in respect of that income if Ghana
has a double taxation agreement with that foreign country. Currently Ghana has double taxation
treaties with many countries including United Kingdom, South Africa and India. However,
most double taxation treaties are structured in a manner that gives more advantage to the
developed countries as compared to developing countries like Ghana in terms of tax revenue
due to exemptions on the basis of source versus the residence principle (Irish, 1978). The World
Bank, IFC and the OECD have however come out to assist developing countries in capacity
building to enhance their negotiation abilities and effectiveness and they have also issued
guidelines on how double taxation agreements are to be drawn to assist in developing
agreements that are fairly balanced.

19
Reduced Corporate Tax Rates
This refers to a case where the law allows a party to apply a tax rate lower than the normal
stipulated rate. In Kenya, the corporate tax rate is 30% for resident and 37.5% for non – resident
branches or permanent establishments. EPZs however, in the past have been taxed at 25% for
the 10 year period succeeding the tax holiday period (CAP 470/517 laws of Kenya). Private
companies listing on the CMA also enjoy reduced corporate tax rates. Companies listing at
least 20%, 30% and 40% of the issued share capital are taxed at 27% for three years, 25%
for five years and 20% for five years respectively (ITA, 2010). Although meant to encourage
listing of companies on the stock markets, this incentive tends to be biased against other
companies operating in the same market.

Recycling Potential and Re-Use

Source separation of solid waste ensures that wastes are kept clean for recovery purposes.
The plastic compositions in this study were 11.01% and 10.68% for the low and middle
income groups respectively whiles paper was 3.15% and 4.51% respectively. The separation
efficiency of over 60% for the plastic and papers components shows that about 60% of
the papers and plastics if not contaminated can be potentially diverted from the waste stream
through re-cycling and re-use. The respective compositions of glass and metals was
2.57% and 4.63% for the middle income group whiles the low income recorded 0.89%
and 0.96% of glass and metals respectively. Despite the lower compositions, the
separation efficiency of over 69% means significant recovery could be made if
uncontaminated.
The recovered plastics could be re-used or recycled to produce materials like chairs,
rubber sheets etc. This is significant to the lifespan of the landfill because of the bulky
volume of plastics. Papers in all forms when cleanly recovered could be used to produce
toilet rolls as well as other paper products (Mensah, 2010). Metals are used by companies as
raw materials whiles glass are sold to construction companies (Asase and Oduro-Kwarteng,
2010). This shows the significance of an effective source separation programme to enhance
the recycling potential of recyclables and in the end help divert waste from landfills thereby
increasing their lifespan.

20
 Recycling
Recycling is the process of making new materials out of previously used ones which have
been considered as waste (US EPA, 2010). It is the process of collecting and sorting
desired waste materials to be processed as raw material for the production of new items.
Whiles re-using entails the multiple usage of an old product, recycling focuses on producing a
new product. Examples of materials that can be recycled are plastic, glass, paper, batteries,
and aluminium among others. Recycling requires collective action in order to achieve the
numerous benefits it presents which means all stakeholders including polluters should be
involved to make it a success.
Among the numerous benefits derived from recycling are:
a. Landfill spaces are saved because waste which might have ended up in landfills is
diverted.
b. Pollution is reduced and natural resources are conserved because virgin materials are
not used to manufacture new products which ensure environmental sustainability
also an MDG.
c. Energy and manufacturing costs are reduced.
d. Recycling helps in reducing GHGs which contribute to climate change.
Development researchers (e.g., Smith et al., 2001; WRAP, 2006) have begun to
comprehensively quantify the significant benefits of recycling for indirect
reductions of GHG emissions from the waste sector.

e. Jobs are created helping to reduce poverty in accordance with MDGs.

As beneficial as waste recycling might be in the social and environmental context, it could also
have negative impacts which include poor health and living conditions as well as exploitation of
waste pickers (Furedy, 1992).The rate of recycling in Africa is difficult to determine because
there are few official statistics on solid waste recycling for the continent (UNEP-IETC, 1998).
According to Yhdego (1995), heavy dependence on imported goods means that there is a non-
existent local market for recyclables in most African cities. However, efforts are being made to
create local markets for recyclables in Africa. For example, in South Africa, there is a demand
for recycled materials as a result of the sizeable tin mining and processing industry which has led
to the institution of a deposit system used to encourage the return of bottles and tin and
aluminium cans (UNEP, 2012).

21
Waste recycling is often undertaken as a survival strategy when the urban poor are unable to
obtain formal employment and when non-waste resources are scarce or unaffordable (Cointreau
and de Kadt, 1991). About 15-35% of solid wastes generated in cities in low and middle income
countries are being recovered as a result of informal recycling activities (UN-Habitat, 2010).
Linkages have been established between the recycling activities of the informal sector and the
Millennium Development Goals (MDGs) and the recycling activities of the informal sector
according to development researchers (Coad, 2006; Langenhoven & Dyssel, 2007; Medina,
2006).
These linkages are evident in the creation of jobs through informal waste recycling which serves
as a source of income for those involved thus reducing poverty which is featured prominently in
the MDGs. Recycling also means less virgin materials are taken for the manufacture of goods
which ensures environmental sustainability.
Kaseva et al., (2002), however argue that there is the need for the solid waste
management strategies in developing countries like Ghana to be redesigned to include a
separate collection and processing system for waste recycling that can work parallel with the
conventional systems already in operation as a result of success stories of recycling
programmes that have been recorded elsewhere in the world

Re-Use
Solid waste re-use involves reusing a product repeatedly without the need for re-processing.
In this case a material which would have been disposed of after slight usage stays in the system
and saves landfill space.
Simelane and Mohee (2012), point out that devising better management options through reuse
of waste in Africa will help the continent to achieve the Millennium Development Goal
(MDG) number 7: to ensure environmental sustainability. Waste re-use has limitations with
respect to sanitation and public health; however its proper integration into a well-designed
solid waste management programme will be beneficial in the areas of waste reduction, material
conservation, cost savings and environmental protection (Diaz, 2012).

22
 RESEARCH APPROACH AND METHODOLOGY
Introduction
This chapter discusses the research methodology adopted in the study. It explains the
methodology that was used in selecting the population, sampling data, collecting data,
and gathering, coding, classifying and analyzing the data as well as reporting the results of the
study. The researcher aimed at applying methods, tools and techniques that were relevant and
reliable to ensure that the data obtained was relevant and accurate for the study.

Research Design
Both the diagnostic and explanatory approaches were adopted for the study. The diagnostic
approach shows the association between the variables while the explanatory approach studies
the causal relationship between the variables (Kothari, 2004). The descriptive approach
provided the foundation to the study by clearly giving an in-depth profile and understanding on
the two issues of tax incentives and economic growth while the explanatory approach was
adopted to estimate how and to what extend tax incentives offered in Ghana affect economic
growth. The study adopted the archival research strategy because government records and
documents where used as the main source of data (Saunders et al, 2009)

Data Collection
Secondary compiled data was used for the study. Outcome from these search were
punctuated with indepth interviews of key respondent, Focus Group Discussion and random
survey using semi-structured questionnaire The data was collected from the Export
Processing Zone Authority, Ghana Bureau of Statistics, World Economic Forum database,
World Bank Database and the Ghana Revenue Authority. Data was mainly obtained from
past published statistics, financial and economic reports and budget reports. Data collected was
checked for reliability, validity and measurability to ensure that it was feasible to draw valid
conclusions from the data (Saunders et al, 2009).

23
Institutions Interviewed
Primary data was obtained at various stages of this research from the following institutions:
 Ministry of Sanitation and Water Resources
 Customs, Excise and Preventive Service (CEPS) of the Ghana Revenue Authority
 Ministry of Local Government and Rural Development
 Ghana Statistical Service

Data Analysis
Data collected was simplified, organized and tabulated to make it easier to understand
and analyze the data. The data was then analyzed using the Statistical package for social
sciences (SPSS) Version 16.0.

24
 RESULTS OF THE STUDY AND DISCUSSIONS

This chapter discusses the perspectives of NARRA members on tax exemptions and the core
objectives of the research. Furthermore it examines government's role to actualize the
expectations of NARRA to create the requisite enabling environment for recycling.

Sex Distribution of Respondents

For the purpose of this segment of the research, a total of one hundred and sixty eight (168)
NARRA members were randomly selected from within the Accra and Tema Metropolis of the
Greater Accra region. An analysis of the sex distribution of the selected respondent is depicted in
the chart below:

Figure 1: Sex Distribution of Respondents

Source: Field Data, 2018

From the chart above, it can be seen that a majority (61%) of the members of NARRA are males
as against the 39% female. The scavenging nature of the operations of members of NARRA
appears to be an important factor that makes the business more suited to the male sex than their
female counterpart coupled with the high level of physical energy demands and the rigorous
operations make this job more suited to the male sex that.

25
It is significant to add that, information obtained from focus discussions revealed that, the
females involved are said to be equally competent as their male counterparts and do not feel
intimidated by the facts that they have ventured into to a perceived male dominated industry.

Analysis of Educational Background of Respondents

The chart below depicts a pictorial representation of the educational attainment of NARRA
members as reflected in the sample of respondents selected for this study.
Figure 2: Educational Background of Respondents

Source: Field Data, 2018

A total of 70% of NARRA members interviewed for this study have attained not less than basic
education (31%basic school and Middle School Leavers and 39% West Africa Senior Secondary
Certificate, Ordinary “O” and Advanced “A” Level General Certificate of Education holders).
14% of the respondents, among NARRA, hold under graduate diplomas whiles 4% and 1% hold
first degree and post graduate degrees respectively. The chart above shows that only 11% of
NARRA members interviewed have not received any formal education. This implies that a total
of 89% of the respondents from NARRA have received formal education and could be useful in
mobilizing useful literature to support this advocacy when the need arises.

26
Distribution of Respondents by Waste Interest
A close look at the distribution of respondents as segregated by the type of waste they were
interested in revealed that over half (51%) of the respondents specialized in plastic waste
collection for either reuse or recycling purposes. 33% operated as scrap metal collectors whiles
6% and 3% also specialized in paper waste and construction demolishing (CD) waste. The
remaining 7% of the sampled population were into other forms of waste such palm kennel shells,
glass and textiles.
Figure 3: Distribution of Respondents by Waste Interest

Source: Field Data, 2018

A further probe into reasons for opting for their specializations revealed that availability of
materials, anticipated profit margins and the availability of ready markets for the materials
collected were the leading factors in influencing which materials to collect. Example those who
are into Construction Demolishing (CD) waste said it was because the market was available
whiles those who went into plastic waste also indicated that both the product (flexible and PET
plastic waste) were in abundance in the system just as the market for such waste. Relatively
fewer people are into scrap metal because they indicated that it was physically demanding and
scrap metal is not as readily available as plastics even though it is more rewarding.

27
Analysis of Employment Potential within the Re-Use and Recycling Industry
This research also revealed that 13% of respondents currently employ up to five (5) persons 38%
of the respondents employ between ten (10) and fifteen (15) persons, whiles 26% employ
between fifteen (15) and twenty (20) employees.

Figure 4: Employment Potential within the Re-Use and Recycling Industry

Source: Field Data, 2018

In view of the rising unemployment in our societies coupled with the waste management
challenges facing the Ghana, this industry offers viable alternatives for young entrepreneurs to
develop businesses in this industry and create additional employment that further opens up the
economy.

Analysis of Operational Costs

It is significant to note that, this study also revealed that collection and separation of waste (32%)
and maintenance cost of equipment (21%) together account for more than half (53%) of the
operational cost of NARRA members.

28
Figure 5: Operational Costs Distribution

Source: Field Data, 2018

The above chart also indicate that cost of compaction and haulage take up another 20% of the
operational costs of NARRA members whiles administrative cost taken up the least share in
terms of costs distribution of operations among NARRA members.

The above cost distribution implies that if a feasible mechanism could be developed and strictly
enforced to facilitate source separation of waste, across the country, then it could save NARRA
members nearly a third (32%) of their operational cost. Consequently, this could greatly improve
the business viability of the operations of NARRA members who could invest this resultant
savings accruing from the source separation of waste into investment in improved and modern
equipment to further improve the business outlook of the reuse and recycling industry in Ghana.

29
Profitability of the Business of NARRA members
This study also sought to assess the profitability of the businesses of NARRA members which is
depicted in the chart below:
Figure 6: Net Weekly Profit Accrued

Source: Field Data, 2018

Analysis of the data obtained from the field revealed that 35% of NARRA members make a net
weekly profit of GH₵1,000.00 and GH₵2,000.00. Only 18% of NARRA members sampled for
this survey earned less than GH₵1,000.00 a week, whiles another 16% of the members earned a
weekly net profit of more than GH₵5,000.00.

In view of the relatively high unemployment rate (12.9%) in Ghana as reported by the Ghana
Statistical Services (2013) and coupled with the fact that about 28% of the national population
are estimated to be living below the poverty line (General News, Ghana web of Monday, 25
March 2013) the reuse and recycling industry, if properly supported with the right legislation
and infrastructures could provide viable income generation alternatives and sustainable means of
livelihood to the teeming unemployed youth of Ghana.

30
Description of Problems Confronting NARRA Members
The research also revealed that NARRA members are confronted with a myriad of problems that
are effectively combining to impede the growth and development of the reuse and recycling
industry in Ghana. The chart below captures the ranking of these problems as cited by NARRA
members sampled for this research.

Figure 7: Ranking of Challenges Confronting NARRA members

Source: Field Data, 2018

As shown in the chart above, nearly half (49%) of NARRA members mentioned high import
tariffs on recycling equipment and machinery as the most crippling challenge facing their
operation. 24% mentioned the cost of recycling equipment and their spare parts as another major
challenge that they are confronted. For this population, the fact that these recycling machines and
equipment are not manufactured locally makes their situation even more precarious as they have
to contend with the high import duties at the ports.

Further challenges mentioned by NARRA include high cost of energy and the cost of separating
the waste. Other challenges such as the absence of tax incentives such as tax holidays, tax

31
refund, tax exemptions and reduced corporate tax were also cited by not less than 3% of the
population.
SOME TARIFFS AFFECTING THE RECYCLING INDUSTRY IN GHANA
ECOWAS Common External Tariff
The adoption and implementation of the ECOWAS Common External Tariffs (CET), albeit
commendable as it standardizes taxes across the sub region, has resulted in a net increase in
import duties on certain commodities. This new tariff is further undermining the business
viability of NARRA members. The new additions and increments in import duties which now
stand at 35% have been opposed by trade associations namely, Ghana Union of Traders
Association (GUTA), Council of Indigenous Business Associations (CIBA), Environmental
Service Providers Association (ESPA) and Importers and Exporters Association of Ghana. This
situation has triggered strike actions to oppose these additional taxes and increments as
businesses are already slapped with substantial number of levies and charges at the ports, amidst
the harsh economic conditions. In any case, the implementation of the CET is inevitable since it
is a regional policy decision. Government’s approach to the implementation of the CET was out
of proper context: to avoid any confusion, the government ought to have better engaged the
appropriate trade unions, namely Importers and Exporters Association in comprehensive policy
discussions.

Hostile Tax Environment

According to the DB Report 2018 businesses make 31tax payments a year, spend 224 hours a
year filing, preparing and paying taxes amounting to 33.2% of profits. These numbers, standing
alone, may not adequately portray the tax burden on local businesses. But going a little further by
undertaking a global and regional comparative analysis explains Ghana’s ranking of 120 out of
190 economies in the ease of “paying taxes” of the DB Report; falling from 108, from the
previous year. All these are suffered silently by NARRA members who have indicated the
readiness to use this advocacy action to change the current tax situation for the better.

32
Increase in Capital Gains Tax
An increase in Capital Gains Tax (from 15% to 25%) and Withholding Taxes (from 5% to 7.5
%) could affect the working capital of businesses, especially Small and Medium enterprises. The
increments in the rates of these taxes practically affect the prices of goods and services. This,
obviously, will cause a declension in outputs and force them to either lay off workers, partially or
completely shut down. Furthermore, businesses operating under tax concessions in Ghana will
now have to pay Corporate Tax at the minimal rate of 1% under the new law; this will likely
deter new businesses from setting up in critical sectors such as agro-processing and recycling.
Multiplicity of Taxes
The multiplicity of taxes discourages entrepreneurs from setting up new businesses and already
established businesses could be motivated to evade some taxes and other required charges,
namely utility tariffs. Current taxes such as the Corporate Tax, ECOWAS Common External
Tariff, VAT, Petroleum Levy, Energy Levy, Rent Tax and Capital Gains Tax are all factors that
are combining very effectively to undermine the growth and development of the recycling
industry in Ghana.
IMPACT OF HIGH IMPORT TARIFFS ON THE RECYCLING INDUSTRY IN GHANA
Analysis of the outcome of Focus Group Discussion (FGD) sessions with members of NARRA
revealed the following adverse effects of the current tariff regime on imported recycling
equipment and machinery on NARRA members in particular and the nation as a whole. These
adverse effects are summarized and discussed under the following headings:
 High level of indebtedness
 Constricted sector growth rate
 Low morale
 Difficulty in securing viable foreign investment partners
 Reliance on outmoded equipment and machinery
 Low contribution to the national economy
 Minimal contribution to national sanitation efforts
 Low return or profits on investments
 Inability to expand business operations and hence resulting in low employment
generation
 unattractive remuneration of staff

33
 High Level of Indebtedness
The current multiplicity of tariffs that recyclers have to contend with in Ghana is said to have
accounted for heavy levels of indebtedness among NARRA members. During the FGD, NARRA
members where unanimous on the fact that nearly all of them are running at heavy indebtedness
largely as a result of a combination of factors that include the high cost of recycling machinery
(ranging between USD30,000 to USD750,000) which are also not manufactured locally coupled
with the high import duties. 60% (6 out of the 10 recyclers) who participated in the FGDs
indicated that they have had the occasion of paying heavy demurrage charges or abandon their
imported recycling machinery because they could not mobilize adequate funds to clear the
machines. This situation is described as being more precarious in the face of the fact that many
NARRA members received loans at interests ranging from 22% to 35% for the procurement of
these machinery.

Constricted Sector Growth Rate

NARRA members also hold the view that the multiplicity of tariffs together with the high rates
of same have grossly worked to constrict the growth of the recycling industry in Ghana. Even
though statistics were not readily available to measure the veracity of this claim among NARRA
members, significant anecdotes were pointed out to show how the sector is not growing or
expanding at its optimal rate; over the last five (5) years, eighteen (18) NARRA members have
had to fold up due to a combination of factors such as inability to clear their equipment at the
port, high electricity bills, inability to pay salaries and, staff income tax (PAYE) and Social
Security and National Insurance Trust (SSNIT) contribution of employees. It was also pointed
out that the near absence of recycling firms operating outside the major cities in the country such
as Accra, Tema and Takoradi goes to further show how the unattractive the sector has become,
mainly as a result of the multiplicity of the tariffs in the national economy, as a whole.

Low Morale
NARRA members also highlighted low morale among entrepreneurs operating in Ghana’s
recycling industry. It came out during the FGD that many of the entrepreneurs feel stuck in the
industry because they have already made significant investments into their firms and it will not
be prudent to abandon ship to start all over again. 70% (7 out of 10 participants) of participants

34
in the FGD who are all entrepreneurs indicated that they are actively seeking for buyers to sell
their plants to and pay of their debts and then invest whatever may be left into other businesses
that may yield better returns on investment for them.

Difficulty in Securing Viable Foreign Investment Partners

This research also identified the multiplicity and high tariff rates in Ghana as another factor that
NARRA members cited as impeding their efforts at securing strategic investment partners for
their businesses. It was unanimously agreed during the FGDs that many prospective investment
partners decline to invest into the recycling industry in Ghana, categorically because they say the
current tariff regime in Ghana is unfriendly to a young industry like recycling, in Ghana. In the
words of Mr. Nicholas Ayim (A Plastic Recycler and member of NARRA:
“Why will any sensible foreign throw his/her hard earned cash into recycling in Ghana when
nationals who are operating in the industry are being stifled by the fundamentals of the
economy?”
Another leading member of NARRA, Osman Mohammed Mansur also added that:
“Some of us who as still operating in the recycling industry in Ghana are caught between the
devil and the deep blue sea. We can only rely on our faith hence a good number of us in this
group are either pastors or Imams. Faith is what is keeping some of us in this recycling
industry”
Reliance on Out-Moded Equipment and Machinery
It was also evident that most NARRA members are unable to afford modern recycling
machinery mainly to the high cost of such equipment. Basic recycling machinery such as:
 Compactors
 Washers and Dryers
 Shredders and Rollers
 Package Injectors and Blower
 Pelletizer

Range from USD 30,000 to USD 750,000 on the market. This price range is of limits for most
recyclers who resort to used or second hand machinery, mainly imported from China and the
United Arab Emirates. The high and multiplicity of tariffs is accused as being responsible for
perpetuating a vicious cycle of decline in the recycling industry in the country.

35
Low Contribution to the National Economy
The recycling industry, so far, is not contributing significantly to the national economy in term of
employment numbers and Gross Domestic Product because government has not targeted the
industry with specific fiscal policies that will open up the sector to investors. The current tariff
regime on recycling implies that government will continue to invest huge some of revenue in
waste collection and disposal at landfill sites that remain unengineered. If the recycling industry,
in Ghana, were to be properly targeted with appropriate tax incentives, many more investors
would have come into the sector and not only save government from the massive financial
injections that it makes through the Local Government Agencies and the newly created Ministry
of Sanitation and Water Resources to collect and dump waste.

Minimal Contribution to National Sanitation Efforts

Another damage that the current tariff regime is doing to the national physical environment is
how is working to prevent the recycling industry from expanding to contribute more significantly
to the national sanitation efforts. Most recyclers in Ghana are operating at less than 10% their
capacity now and hence their impact is not really felt on the national sanitation strategy. If the
multiplicity of the current taxes where to be re-aligned to allow for some financial respite for
recyclers, then they can expand the production capacities by investing in ultra-modern
technologies which will expand the output exponentially and thereby absorbing more of the
waste from the physical environment to add value through recycling.

EXISTING INVESTMENT INCENTIVES FOR RECYCLERS IN GHANA

1% Tax on Income for 1st 7 years

The research also revealed that whereas there is a reduced tax on income of 1% for the first 7
years of establishment of waste processing business, this is defeated by such tariffs as imposed
on energy, VAT, National Health Insurance Levy and rent. When put together, these taxes go
beyond 25% of income which according to a majority (69%) of NARRA members is very
harmful for the industry.

36
Exemptions
Industrial plant, machinery or equipment and parts thereof are exempted from customs import
duty under the HS Codes chapter 82, 84, 85 and 98. An enterprise whose plant, machinery or
equipment and parts are not zero rated under the Customs, Excise and Preventive Service
Management Act, 1993 may submit an application for exemption from import duties and related
charges on the plant, machinery or equipment or parts of the plant, machinery or equipment to
the Centre.

Unfortunately, all NARRA members interviewed for this research intimated besides the fact that
the procedure for utilizing this exemption is not well-defined, it also appears to be
operationalized to favour cronies and political allies. None (0%) of All NARRA members
interviewed said that even though they have tried severally to access the exemption, none of
them has ever been successful.

37
 CONCLUSIONS AND RECOMMENDATIONS

CONCLUSIONS
It is important that government adopts a creative approach to raising the necessary funds to run
its affairs. The obvious over dependence on a limited tax-base and multiple tariffs and levies is
clearly becoming unacceptable. If this trend is allowed to continue any further, Ghana risks
losing key corporate tax payers as some companies will evidently relocate to neighboring
countries with better business environments; as has been the case in recent past. As the 2018 DB
Report points out, the use of technology and it derivatives to streamline business regulation is
arguably non-existent in Africa, including Ghana. Reforms in this regard are urgently needed.
The use of electronic means for filling, paying and complying with tax regulations should be
incorporated in all polices. The World Bank says, “Online procedures account for 0.5 days in the
total time calculation" when starting a business in Ghana. In a recent letter addressed to the
Registrar General Department regarding the regulatory framework that governs the processes of
starting a business in Ghana, NARRA spelt out some policy measures the Government should
institute in order to optimize the process for business registration. These measures include,
enabling online business registration throughout the process, developing a Public Education
Toolkit to educate stakeholders on Online Services, building a solid human resource for the
administration of online services among others. All these measures will practically widen the tax
base for effective revenue mobilization.

The tax regime remains quite unfavorable to the business environment. Evidently, Government is
better off undertaking a structural reform of the tax regime. Changing the structure of the Tax
Payer Basket is more palpable than ever. In order to maximize revenue influx, Government
ultimately benefits for investing in the necessary infrastructure that widens the tax-base. Indeed,
this will go a long way to address Government budget deficit; which appears to be its
justification for the increment in rates of existing taxes and the introduction of new ones. If the
trend persists, Ghana risks losing existing tax payers to other economies with favourable
business environments.

38
 RECOMMENDATIONS

The following recommendations have been made as a result of the research findings and relevant
conclusions to serve as a basis for evidence based dialogue.
1. There is need for the government to prioritize the tax incentive schemes for recycling in
the country by scrapping the statutory administrative charges ranging between 2.5%–3.45% of
the value of goods imported. These charges apply regardless of any import duty exemptions.
Examples of the administrative charges are as follows:
• Processing fee – 1% of CIF;
• Inspection fee – 1% of CIF;
• Network charge (GcNet) – 0.45% of FOB;
• ECOWAS levy – 0.5% of CIF; and
• EDIF levy – 0.5% of CIF. various taxes on recycling and granting exemptions for the
importation of equipment and machinery for recycling meant for use in the country.

2. The Ministry of Sanitation and Water Resources should support this advocacy by NARRA in
advocating for a conducive business environment that will permit the growth of recycling
businesses in Ghana.

3. The Ministry of Sanitation and Water Resources should support NARRA to engage
government initiate stakeholder consultation on how the current tariff regime can be adjusted
and/or re-aligned to serve as a catalyst for the attraction of investment into the recycling industry
in Ghana.

4. The need to introduce policies that allow for the progressive formalization of the large
informal sector using simplified and technology-powered regulatory systems in terms of tax
compliance will allow government to relax its burden on infant industries such as the recycling
industry in the country to allow for faster expansion of the national economy.

39
5. The government should take concrete steps to implement its campaign promise to provide
incentives for the recycling industry (Imani 2018) to stimulate sustained growth.

6.Government should engage more actively with all stakeholders in the recycling sector in the
context of finding new and more suitable tax and administrative levies for the recycling sector.
This will help reduce the fold up of operating businesses in the recycling industry.

40
 REFERENCES

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