Pakistan-India Trade:

Additional Trade Challenges: Transport, Transit, and Non-Tariff Barriers
The NTMs found to be trade-restrictive included some TBT and SPS
measures. This is because their implementation involved cumbersome procedures,
either because of the involvement of multiple agencies or due to
too many formalities that raise the costs of trading considerably in terms
of both time and money. Some TBT- and SPS-related barriers emerge
from inadequate testing facilities at ports that sometimes lead to delays
and additional costs, because samples have to be sent to distant locations
for testing. In other cases, Indian authorities did not accept pre-shipment
test certificates (including with leather and textile products) from the
exporting country, which again have led to delays and additional costs.
In the case of exporting agricultural products to India, Pakistan notified
that the process of required Pest Risk Analysis (PRA) was complex
and non-transparent. This is unfortunate, given that a detailed examination
of the process of PRA has revealed that the process of obtaining
a PRA is clearly laid out in the Plant Quarantine Order of 2003, and
is available on the Ministry of Agriculture website. The author’s discussions
with authorities in the Plant Quarantine Department in India
reveal that Pakistani exporters have made a request for PRA to be conducted
on very few items—suggesting that Pakistan shies away from
making requests because it is too intimidated by the process, despite the
availability of clear information about the process.
In the case of pre-packaged products such as processed foods,
cosmetics, toiletries, and spices, Rule 32 of the Prevention for Food
Adulteration Act (PFA) pertaining to labeling requirements is complex
and detailed. Similarly, the import permit required for poultry, dairy
products, and meat was reported by traders to be very time-consuming.
Trade also gets restricted due to regulations that lack transparency.
Regulations related to wool and other textiles and jute products have not
been notified to the WTO. This creates information asymmetries for
trading partners. In the case of wool textiles, the regulation also lacks
clarity on the requirement of a “brand owner” certificate. Such regulations
can be applied arbitrarily, as they are open to interpretation.
Only one measure, related to labeling requirements for processed
foods, qualified as a barrier on account of its violation of the principle
of national treatment. The measure requires processed food items to
have a shelf life of at least 60 percent of its original shelf life at the time
of import. There is no such stipulation for domestic goods, for which
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