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KARACHI: The Union of Small and Medium Enterprises (UNISAME) has invited the attention of the Secretary Ministry of Commerce (MINCOM) to the urgent need to amend the registration clause in Strategic Trade Policy Framework (STPF) of Jan 30th 2013 as associations do not have the system of registration and are insisting on enrolling exporters as members contrary to the STPF clause.

The STPF states that the exporters of fresh fruits, vegetables, rice etc will be registered with their respective associations and in case of non existence of such an association mandatory registration of such exporter be made with Trade Development Authority of Pakistan (TDAP).

UNISAME has explained that it is essential to add that in case the association declines to register the exporter then the exporter can get registered with TDAP.

UNISAME urged MINCOM to amend the clause to read as “In case of non existence or refusal of such association mandatory registration of such exporter be made with TDAP.

Therefore in light and spirit of the registration clause in STPF the UNISAME has urged MINCOM to direct TDAP to register SME exporters of miscellaneous goods with them and not subject them to hardships by applying to associations for registration who are compelling them to become members first instead of simply registering them on nominal registration fees.

Secondly MINCOM should accept the membership of the chamber of commerce and industry (CC&I) as valid registration as the CC&I observes the proper procedure and maintains full record of the member along with income tax returns filed with the Federal Board of Revenue. All trade associations are themselves registered with the CC&I and MINCOM must comprehend this fact and not disregard the CC&I. It is pertinent to point out that the certificate of origin for exporters of the CC&I is recognized all over the world then how come the MINCOM is not considering registration with CC&I as valid.

President UNISAME Zulfikar Thaver stated that the MINCOM by virtue of the STPF needs to recognize the fact the exporter of several food items can register with TDAP. Secondly the STPF has made registration mandatory and not membership mandatory. Simple registration and membership are two different things. MINCOM having recognized the difference between the definition of registration and membership needs to advise the trade associations not to treat them as one and same thing and enrol as members those who wish to and simply register those who are seeking registration only on nominal fees if necessary.

The STPF clearly underlines the purpose of registration as monitoring the possibility of abuse and registration is for record purpose only. Thaver said membership of the chamber of commerce should suffice for monitoring and record purpose and there seems to be no need for double membership of the respective chamber of commerce and industry (CC&I) and any other association. The renewal of membership fees of the CC&I is only Rs 2100 which is affordable.

The forum urged the ministry of commerce to take speedy decision as new exporters need to register themselves and trade associations are declining to simply register and insisting on membership.

Associations must be able to stand on their own merit and exporters would seek membership of their respective associations if they consider it useful on the basis of its facilities and guidance provided to its members.

The trade associations can attract membership on merit on the basis of their service and advocacy of the rights and protection they offer to its members and the ministry of commerce does not need to favour trade associations by making their membership compulsory for the traders who are members of their respective CC&I which is the superior body.

Many exporters are exporting multiple items and it is unwise to compel them to become members of several associations and the SME exporters sometimes ship several items in one container and it should not be proper to compel them to become members of all the associations.

The TDAP had announced that an exporter of miscellaneous items could register as member of any one association and that would suffice but the question is that why an exporter is obliged to become a member of any association when already a member of the CC&I which is the parent association.

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