Non-Tariff Barriers to Trade
Overview
Togo is a WTO member and applies the Technical Barriers to Trade (TBT) Agreement, which promotes transparency, non-discrimination, and the use of international standards. Draft technical regulations must be notified to the WTO, and Togo maintains an Enquiry Point for information requests. In practice, Togo has issued few TBT notifications; a notable example is the 2012 ban on non-biodegradable plastic packaging.
Most technical regulations are developed within the WAEMU regional framework, and Togo participates in African standardization efforts through ARSO. U.S. companies should monitor the WTO ePing platform to track new notifications. Compliance with WAEMU and regional standards generally ensures adherence to Togo’s technical requirements.
Togo’s standards system across sectors is managed by ATN (Agence Togolaise de Normalisation) under the Haute Autorite de la Qualite et de l’Environnement (HAUQE). The system combines voluntary and mandatory standards depending on the sector and risk. Preliminary standards are developed with stakeholder input and may become mandatory for public health, safety, or environmental protection.
Flexible Stakeholder Engagement
- ATN uses “comites miroir” (mirror committees) including government, industry, researchers, importers, and consumer groups to consult stakeholders.
- In 2024, ATN validated three national cement standards (TGN 001–003) for safety and environmental compliance.
- Foreign companies can participate through mirror committees or technical working groups.
Standards Work Plan and Participation
- ATN is actively developing standards for cement, agro-food and other sectors (2024–2025), with partners like the World Bank.
- Togo’s membership in ARSO and correspondent status with ISO provide access to regional and international standard-setting processes.
Implications for U.S. Companies
- Follow WAEMU and ARSO standards to ensure compliance.
- Engage early in mirror committees or technical working groups for input on relevant standards.
- Monitor Togo’s TBT notifications via the WTO ePing platform.
Standards and Technical Regulations
Togo’s standards system combines mandatory government regulations with voluntary stakeholder participation. While U.S. standards are not formally required, internationally recognized standards are often accepted. Togo’s alignment with EU standards reflects strong trade ties with Europe, and participation in international standardization bodies provides opportunities for broader engagement.
Testing, Inspection and Certification
Togo uses a risk-based, sector-specific approach rather than universal testing for all goods. Most products can enter the market without mandatory testing. Regulatory oversight is shared among line ministries, the Togolese Standardization Agency (ATN), and the Togolese Revenue Office (OTR).
Compliance may require adherence to Togo-specific standards or internationally recognized standards such as ISO, IEC, ASTM, or EU norms. For high-risk goods including health, safety or consumer-sensitive products, require mandatory testing and certification before import and sale.
Publication of Technical Regulations
Togo’s regulatory environment is evolving, with ongoing efforts to modernize and align with international standards. All final laws, decrees, and ministerial orders are published in the Journal Officiel de la Republique Togolaise, the official legal reference. For example, the Minister of Health’s Order No. 054 on tobacco control was published on February 10, 2022. New regulations often include an implementation phase to give stakeholders time to comply.
Draft bills and proposed regulations are not consistently released for public comment, and formal public consultation processes are limited. There is no fixed comment period or regulatory schedule. Ministries and agencies may conduct informal consultations with select stakeholders. Regulations are published ad hoc, without a predictable annual timeline.
Given the limited transparency, U.S. companies may find it difficult to anticipate or influence changes. The most effective approach is direct communication with relevant ministries or participation in industry associations that maintain ongoing dialogue with the government.
Contact Information
Agence Togolaise de Normalisation (ATN)
Email: atntogo2020@gmail.com
Website: www.hauqe.tg
Relevant Standards and Trade Organizations
- African Organization for Standardization (ARSO): Togo is a member of ARSO, which facilitates regional standardization efforts across Africa.
- International Organization for Standardization (ISO): Togo is a correspondent member of ISO, participating in international standardization activities.
- Togolese Consumer Association (ATC): ATC monitors the quality of goods and services and represents consumers in national decisions. Tel: +228 900 43713, Email: atctogo@yahoo.fr.
- U.S. Embassy in Lome: The embassy supports U.S. businesses engaging with Togo’s regulatory environment. Email: togocommercial@state.gov.
Use ePing to Review Proposed Technical Regulations and Conformity Assessment Procedures
The ePing SPS&TBT platform (https://epingalert.org/), or “ePing”, provides access to notifications made by World Trade Organization (WTO) Members under the Agreements on Sanitary and Phytosanitary Measures (SPS) and Technical Barriers to Trade (TBT), distributed by the WTO from January 16, 1995, to present. ePing is available to all stakeholders free of charge and is a versatile tool that can be used to:
- Follow and review current and past notifications concerning regulatory actions on products, packaging, labeling, food safety and animal and plant health measures in markets of interest.
- Receive customized e-mail alerts when new notifications are distributed.
- Find information on trade concerns discussed in the WTO SPS and TBT Committees.
Per obligation under the TBT Agreement, each WTO Member operates an Enquiry Point. National TBT Enquiry Points are authorized to accept comments and official communications from other national TBT Enquiry Points, which are NOT part of the WTO or the WTO Secretariat. All comment submissions from U.S. stakeholders, including businesses, trade associations, U.S domiciled standards development organizations and conformity assessment bodies, consumers, or U.S. government agencies on notifications to the WTO TBT Committee should be sent directly to the USA WTO TBT Enquiry Point. Refer to the comment guidance at https://www.nist.gov/notifyus/commenting for further information. This guidance is provided to assist U.S. stakeholders in the preparation and submission of comments in response to notifications of proposed foreign technical regulations and conformity assessment procedures.
For EU CCG: Include reference to article with a video on CE Mark: https://www.trade.gov/ce-marking