Author: Richard Odum Nyumuah || Farmer & Food System Consultant Email: nyumuah@gmail.com
Ghana’s tree‑crops sector holds immense promise. Cashew, mango, coconut, oil palm, rubber and shea can drive rural jobs, diversify exports and reduce our over‑dependence on cocoa.
That is why many of us welcomed the creation of the Tree Crops Development Authority (TCDA): finally, an institution to help organize these value chains, protect farmers and support value addition.
It is precisely for that reason that the new Tree Crops Conveyance Certificate System (CCS), announced by TCDA, is so troubling. Behind the language of “traceability, transparency and accountability” lies a heavy bureaucratic structure that risks becoming another avenue for hidden levy, rent‑seeking and harassment of the very people this sector is supposed to uplift.
If implemented as designed, the CCS will primarily extract value from farmers and small traders, not deliver it.
Hidden taxation that farmers will ultimately pay
In the announcement, every individual or company licensed by TCDA must obtain a conveyance certificate before transporting tree‑crop commodities within Ghana. On paper, this may sound like a simple administrative requirement.
In reality, any certificate comes with costs: official fees, time spent moving between offices or checkpoints, informal payments, delays that cause spoilage, and the extra margins demanded by middlemen who handle the paperwork.
None of these costs disappear into thin air. Large exporters and powerful traders will simply deduct them from the prices they pay at the farmgate. Smallholder farmers, who already have the weakest bargaining power in the chain, cannot pass them on to anyone. They will bear the new costs in the form of reduced incomes.
The notice talks at length about ensuring that “only licensed operators participate” and about sanctions for those who fail to comply. It is silent on the one question that should matter most in a country concerned about rural poverty: what will be the net impact on farmers’ incomes?
A reform that cannot show clearly how it protects or improves farmgate prices is not a pro‑farmer reform. It is a new layer of levy and taxation by another name.
Copying a flawed cocoa‑haulage model
The structure of this scheme will sound familiar to anyone who follows Ghana’s cocoa sector: movement of a commodity is tightly controlled, certificates are required for transport, checkpoints are manned by multiple agencies, and contracts for haulage and logistics often go to a small group of well-connected firms.
We must be honest about the outcomes of the cocoa model. Cocoa purchasing and haulage companies are large, powerful and wealthy.
Many cocoa farmers, despite decades of production, remain poor and vulnerable. Just travel through the rural Cocoa growing communities and see the state of the houses that cocoa farmers live in.
Over the years, the formal haulage system has become associated with inflated costs, opaque contract awards and limited accountability. It is not unusual to hear that the official haulage charge is several times the true market cost of transport.
Trying to transplant this model into the tree‑crops sector is dangerous for several reasons.
First, these commodities are not cocoa.
Mangoes, cashew, coconuts, shea and rubber have more diverse buyers, a higher share of domestic and regional trade, and in some cases (like mango) are highly perishable. They need flexible and efficient logistics, not heavy‑handed control and checkpoints.
Second, importing the cocoa‑style architecture without the (theoretical) balancing mechanisms—such as a guaranteed producer price and more importantly market—means keeping the burdens while leaving out many of the protections.
In cocoa, we can at least argue that centralized control is linked to a national price‑setting mechanism. In tree crops, no such guarantee exists.
So why adopt the costs and bureaucracy of the cocoa model when farmers are not offered equivalent benefits?
Third, the cocoa experience shows how easily such systems can become vehicles for rent‑sharing, where those closest to the licensing and contract‑awarding process benefit the most, while producers see little change.
Stakeholders in the tree‑crops sector should be wary of walking down that same path.
Bureaucracy over service and efficiency
According to the announcement, the CCS will be enforced through TCDA officers working with the Forestry Commission, Police, Customs and Immigration, stationed at designated checkpoints to verify that all tree crops in transit carry a valid certificate. Failure to comply attracts sanctions under TCDA and other laws.
This architecture raises obvious questions. How many checkpoints will a truck carrying fresh mangoes or cashew nuts have to cross between the farm and the processing plant or port?
How long will vehicles be held at these points while officers “verify” documents? What mechanisms will prevent the familiar pattern of unofficial payments being demanded for a quick passage?
For perishable commodities, the cost of delays is very real: loss of quality, rejection by buyers, and lower prices.
Those losses, once again, fall on farmers and small traders, not on the Authority or checkpoint personnel. A system that increases spoilage and delays without clear added value is not about “traceability”; it is about control for its own sake.
In any case, the major buyers of these commodities have traceability systems based on which most of them are certified to international standards such as ISO.
What value is this new traceability system adding to the value chain?
Many of the benefits TCDA claims—traceability, control of illegal trade, better data for planning—can be achieved through lighter, smarter tools: waybills (could be digitalized that can be generated on a phone; cooperative‑level registers; voluntary registration of transporters and traders linked to real services (training, finance, market information); and targeted enforcement against clearly defined offences like smuggling, under‑declaration and theft.
I must be quick to add that under the current practice, these commodities are currently transported to the major processing facilities are accompanied by waybills and the system has been running seamlessly.
When simpler options exist that cost less and achieve the same objectives, insisting on a heavy, paper‑based, checkpoint‑driven system is impossible to justify—unless the unspoken objective is to create a lucrative bureaucracy, not an efficient service.
Misaligned incentives along the value chain
If the CCS proceeds as described, the incentive structure becomes warped.
Actors who stand to gain are those with access to licences, stamps, and enforcement power: officials who process certificates, private agents contracted to “assist” with documentation, and companies that build their business model around navigating checkpoints. Their income grows with the complexity of the system.
Actors who lose are those who actually produce and move the crops: farmers, small transporters, local aggregators.
Their incomes shrink as they absorb fees, delays and spoilage, and as competition shrinks because only those who can navigate the bureaucracy remain in the game.
A healthy value chain rewards those who add real value—through production, quality improvement, processing and efficient logistics. A bad one rewards gatekeepers.
The CCS, in its current form, risks strengthening gatekeeping at the expense of productive work.
Designed without voice, offered without safeguards
A reform that directly affects the livelihoods of hundreds of thousands of producers should be built on broad consultation.
Yet there is little evidence that farmer‑based organizations, women’s groups, small transporter associations or local traders have been meaningfully involved in designing this system.
If you have ever observed such stakeholder involvement workshops, it is obvious that most of the stakeholders represented are ambushed into accepting proposals.
The public notice emphasizes sanctions, enforcement and the responsibilities of value‑chain actors. It says very little about safeguards for those actors, such as:
• Clear ceilings on certificate fees and related charges.
• Guaranteed maximum waiting times at checkpoints.
• Accessible and independent grievance mechanisms for farmers and small traders.
• Transparent reporting on how any revenues from the system will be reinvested directly into farmer services—such as extension, infrastructure or price information.
Without these protections, the CCS looks less like a service and more like a top‑down imposition. Communities are being asked to trust that the system will be fair, while given no formal tools to hold it accountable.
A better path: pro‑farmer, pro‑competition governance
Objecting to the CCS in its current form does not mean rejecting regulation or traceability. On the contrary, the tree‑crops sector needs rules that are fair, clear and enforced. But regulation must be designed around the interests of primary producers and genuine value‑adding actors, not around revenue extraction and bureaucratic control.
Stakeholders should press for a different approach built on these three principles:
• Service before sanction. Any registration or certification system should first and foremost offer tangible benefits to those who comply—access to market information, technical support, finance, and infrastructure—not just the threat of punishment.
• Light, digital and transparent tools. Where traceability is needed, use digital records and simple, low‑cost systems that minimize human discretion at checkpoints and make data available for independent scrutiny. The current system that is being implemented by the major processes can be studied. If it is suitable, there is not need for any additions, just expand it through social marketing, communication and education. Don’t fix what is not broken.
• Farmer representation and revenue accountability. Farmers and their organizations must have formal seats at the table where such systems are designed and overseen, and any fees collected must be transparently reported and largely reinvested in services that increase farm productivity and incomes.
A call to resist—and to redesign
For these reasons, we should not accept the Tree Crops Conveyance Certificate System in its present form.
Farmer organizations, processors, local traders, transport associations, civil‑society groups and concerned citizens have both the right and the responsibility to demand better.
We should insist that TCDA pauses the roll‑out, publishes a full impact assessment on farm incomes and trade costs, and opens a genuine, time‑bound consultation with all categories of value‑chain actors.
Any revised system must be demonstrably pro‑farmer, pro‑competition and pro‑efficiency.
Ghana’s tree‑crops sector deserves a regulatory framework that unlocks its potential, not another bureaucratic maze that makes a few intermediaries rich while keeping farmers poor.
The CCS, as currently designed, risks repeating the worst features of the cocoa haulage experience. We still have time to choose a different path.
