How forum shopping leads to widening regional economic integration in the Global South:

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University of Amsterdam

Graduate School of Social Sciences

How forum shopping leads to widening regional economic integration in the Global South:

the case of Regional Economic Communities shopping in South-East Africa

Name: Benedetta Maria Garofalo Supervisor: Dr. S. Krapohl

Second reader: Dr. R.M. Sanchez Salgado

Date: 10-06-2022

Student number: 11919957 Word count: 13,165

Master thesis Political Science – International Relations specialization




This paper is aimed at understanding whether overlapping memberships to regional integration agreements in the Global South are motivated by forum shopping, and whether this is connected to widening of integration in the region. For this purpose, this paper first studies Tanzania, Zambia and Kenya in a comparative cases design by following their involvement in three prominent regional economic communities (RECs) – the Common Market for Eastern and Southern Africa (COMESA), the Southern African Development Community (SADC) and the East African Community (EAC) – in South-East Africa. Secondly, it analyses the establishment of the Tripartite Free Trade Area (TFTA) and the African Continental Free Trade Area (AfCFTA) in connection to overlapping memberships to RECs and their stagnating integration, to study the connection between widening of integration and overlapping memberships to regional integration agreements. In conclusion, this paper finds that forum shopping motivates states in the Global South to pursue overlapping memberships, and that in turn this overlap spurs widening instead of deepening of integration.




I would like to thank Sebastian for his support, feedback and insights during the writing process. A note of appreciation also goes out to all the family and friends who supported me by providing new and interesting insights, or simply by always

encouraging and motivating me.



Regional Economic Collaborations

AfCFTA African Continental Free Trade Area COMESA Common Market of East and South Africa

EAC East African Community

SADC Southern African Development Community

TFTA Tripartite Free Trade Area

Country characteristics

ESA East and South Africa

LDC Least Developed Country

MDC Middle Developed Country

Stages of integration

CM Common Market

CU Customs Union

FTA Free Trade Area

MU Monetary Union

Other relevant acronyms

AGOA African Growth and Opportunity Act

EPA Economic Partnership Agreement with the European Union GSP Generalised Scheme of Preferences of the European Union GSTP Global System of Trade Preferences of the United Nations

PTA Privileged Trade Agreement

REC Regional Economic Community

RTA Regional Trade Agreement




Abstract ... 2

Introduction ... 7

Theory ... 9

Literature review ... 9

Classical theories of regional integration ... 9

Theoretic framework ... 10

The complexity of regionalism in Africa: overlapping memberships and multilevel agreements 10 Overlapping memberships to RECs ... 12

The puzzle ... 16

Data and methodology ... 17

Methods ... 17

Conceptualization and design ... 17

Data ... 18

Geographical area and case selection ... 18

Suitability to work as most-similar cases ... 21

Data used in analysis ... 22

Analysis part 1: Does forum shopping motivate states to hold multiple memberships to RECs? ... 24

Tanzania ... 24

The COMESA FTA and Tanzania’s withdrawal from COMESA ... 24

The overlapping membership of EAC and SADC ... 25

Extra-regional relations ... 28

Conclusion of Tanzania ... 29

Zambia ... 30

The overlapping membership of SADC and COMESA ... 30

Extra-regional relations ... 34

Conclusion of Zambia ... 35

Kenya ... 36

The overlapping membership of EAC and COMESA ... 36

Extra-regional relations ... 39

Conclusion Kenya ... 40

Analysis part 2: do overlapping memberships widen instead of deepen integration through forum shopping? ... 41

The establishment of the Tripartite Free Trade Area ... 41

The establishment of the TFTA and overlapping memberships ... 43

The establishment of the African Continental Free Trade Area ... 43

The widening of integration in South-East Africa... 45



Conclusion and discussion ... 46

Discussion of limitations ... 46

Conclusion ... 46

Bibliography ... 48

Appendix ... 55

Appendix A: The detailed integration history of SADC, COMESA and EAC ... 55

Appendix B: empirical data for Tanzania ... 57

Appendix C: empirical data for Zambia ... 59

Appendix D: empirical data for Kenya ... 64




When theorizing about regional economic integration, classical integration theorists portray a self- enforcing dynamic movement towards regional integration. This movement is put in motion by growing cross-border transactions and the need for judicialization to resolve disputes arising from increasing cross-border contact (Caporaso & Stone Sweet, 1998; Fligstein & Stone Sweet, 2002; Sandholtz & Stone Sweet, 1998; Stone Sweet, 1999). However, recent studies have shown that these classical theories of regional economic integration are not suited to understand the dynamics of integration elsewhere than Europe, especially regions considered to be part of the Global South (Krapohl, 2019; Murray, 2010;

Onditi, 2021; Sbragia & Soderbaum, 2010). The Global South is used to refer to regions in Africa, South America and Oceania that exist under the wealthy European or North American economic threshold (Dados & Connell, 2012).

If not through classical theories, how can we understand the dynamics of regional economic integration in the Global South? The first step is acknowledging the multilayer trade environment in the Global South, which is strongly influenced by a multitude of different trade agreements, such as extra-regional privileged trade agreements (PTAs) and regional integration agreements (RIAs). Overlap between these two different types of agreements is common. In addition to this type of overlap, many states in the Global South also experience overlap in membership to similar regional integration agreements, which is puzzling. States who are members of multiple RIAs in practice commit to simultaneously integrate economically with multiple country groups, which can cause complicated border-crossing situations due to overlapping regulations and loyalty. Though most political economists would agree with this, extensive research on why overlapping memberships to regional integration agreements arise and how they influence regional integration is quite scarce (Davis, 2009; Froese, 2016). As these types of situations are very common in the Global South, it is crucial to broaden our understanding on the topic to expand our knowledge on economic integration dynamics in the Global South.

In order to do so, his paper aims at bringing together two strains of theory: forum shopping theories (Apiko et al., 2019; Busch, 2007), which will provide helpful instruments to understand the motivations of states to become part of overlapping memberships, and widening vs. deepening of integration theories, which will help to capture the overarching trend of widening integration in the Global South (Berglof et al, 2008; Heidbreder, 2014; Patel, 2019). Hence, the main research question this paper aims to answer is:

“How does forum shopping of regional economic communities affect regional integration in the Global South?”

Based on the theory, the expectation is that forum shopping motivates states to become part of multiple regional integration agreements, which consequently causes widening instead of deepening of



integration due to inefficiencies resulting from overlapping regional integration memberships (Afesorgbor & Van Bergeijk, 2014; Chacha, 2014).

One of the regions in the Global South where overlapping memberships to regional integration agreements is widespread, is South-East Africa. In this region, regional integration agreements - referred to as Regional Economic Communities (RECs) - have proliferated, many with the same scope or covering the same geographical area. The prevalence of overlapping memberships in South-East Africa makes the region a very suited candidate to find study cases for a most-similar cases research design.

These cases - Tanzania, Kenya and Zambia - will be studied to assess whether forum shopping motivated overlapping memberships to the Southern African Development Community (SADC), the East African Community (EAC) and the Common Market for Eastern and Southern Africa (COMESA), and whether this observed overlap has spurred widening instead of deepening of integration in the region.

After discussing existing theory and the research methodology, the analysis will consist of two parts.

The first will analyse the motivations for each studied case to be part of multiple RECs, to assess whether forum shopping patterns emerge. The second part will analyse whether the establishment of the Tripartite Free Trade Area and consequently the African Continental Free Trade Area, are connected to overlapping memberships and are signs of widening integration in the region. The paper will end with a conclusive discussion and some recommendations for future research on the topic.




Literature review

Classical theories of regional integration

Classical theories of regional integration are mainly centred around the case of the European Union.

Intergovernmental accounts argue that individual governments of member states are the main actors stirring regional integration (Keohane & Hoffmann, 1991), whilst supranational accounts believe supranational institutions are ultimately the ones that are pushing regional integration (Sbragia, 1993;

Stone Sweet & Brunell, 1998). Supranationalism is inspired by early regional integration thinkers such as Haas (1958), and generally portrays the process of integration as a self-sustaining and -enforcing mechanism (Caporaso & Stone Sweet, 1998; Fligstein & Stone Sweet, 2002; Sandholtz & Stone Sweet, 1998; Stone Sweet, 1999;). According to this literature, the liberalization of cross-border transactions leads to the increase of transaction costs due to augmenting cross-border activity. Increased costs can come from disputes between trading partners and ultimately member states. As Stone Sweet (1999) argues, the disruption of the dyadic relationship between actors creates the need for dispute arbitration by a third party, which would become the role of a supranational legal organ. The legal organ has the power to install normative changes aimed at resolving conflicts disturbing the balance between disputing parties. The resolution of such disputes will predominantly result in further liberalization of cross-border activity, as it would facilitate cross-border collaboration by lowering barriers. This ongoing interaction between market liberalization, supranational polity, and triadic dispute resolution marks the self- sustaining dynamic of reinforcing economic integration in a region with strong predisposition to intra- regional trade flows (Figure 1).

Figure 1: the triad of regional integration

The success of such a self-sustaining dynamic relies on the compliance by involved actors to the ruling of the third party. The defection of rulings can lead to sanctions for the defecting party, which in case of consensual triadic governance will probably be effective and informal, reinforcing the legitimate position of the third party. In case of compulsory triadic governance, where not all actors recognize the

Economic exchange

Dispute resolution mechanisms Judicialization



legitimacy of the third party, non-compliance rules may need to be made formal and costly. As Stone Sweet (1999) argues, reasons for such non-compliance could be that the systematic change the third party is encouraging does not create a beneficial trading environment for both involved parties involved.

Theoretic framework

There are important differences to keep in mind when theorizing about regional integration in the Global North versus South. The intra-regional ties, extra-regional ties and institutionalization are central topics in this theoretical debate. This section will present the theoretical debate underlying the research question.

The complexity of regionalism in Africa: overlapping memberships and multilevel agreements In Africa there has been a multitude of regional integration attempts, which has been characterised by the establishment of regional economic communities (RECs). Members of RECs collaborate to liberalise their markets and advance regional economic integration. Economic integration can be seen as occurring in different steps or integration milestones (Figure 2).

Figure 2: integration milestones (source: Belassa, 1964)

The proliferation of RECs in Africa has led to states becoming part of multiple RECs, resulting in many overlapping memberships of RECs with similar scopes and addressing similar geographic areas (UNECA, 2019). RECs environment is increasingly more complex due to all different interests that drive the strategic choices of member states, such as the simultaneous existence of other types of trade agreements or the levels of integration of the RECs. All these economic collaboration agreements form a complex multi-level web of trade agreements that states need to navigate to pursue their interests.

Figure 3 portrays this multilevel environment and shows how overlap in agreements and membership can take different forms and shapes.

Free trade area

Removal of internal trade barriers, such as tariffs on internally produced goods

Customs Union

Introduction of common external tariff (CET)

Common Market

Free internal movement of labour and capital

Economic Union

Coordination of national macro- economic policies

Complete Economic Integration

Unification of all economic policies



Figure 3: the multilevel environment of states in the Global South

Privileged trade agreements and frameworks

Extra-regional privileged trade agreements (PTAs) between regional members and external parties can have disrupting effects for the integration progress of a REC. In the case of Africa, privileged trade agreements can be found in the context of either improving African states’ access to world markets or bi- or multilateral agreements with a strong ‘development aid’ undertone. There are special trade regulations applying to LDCs (least developed countries) under the Global System of Trade Preferences (GSTP) framework of the UN, allowing countries or regions to benefit from a tailored preferential trade status. For example, countries considered LDCs face no trade barriers when exporting products to the European single market under the European Generalised Scheme of Preferences (GSP) framework, based on the GSTP. Depending on the development status of a country, they are entitled to different forms of GSP: standard GSP, GSP + and the Everything But Arms (EBA) initiative (Damler & Igler, 2021).

Next to the GSTP framework, states and regions have developed other frameworks for privileged trade relations with the developing world, such as the EU’s economic partnership agreements (EPAs) or the USA’ African Growth and Opportunity Act (AGOA). EPAs are trade agreements of the European Union with countries and regions in Africa, the Pacific and the Caribbean region (European Commission, 2022). They focus on the reciprocal liberalization of market transactions between the European single market and EPA members (European Commission, 2022). In practice these agreements have been criticised for reinforcing unequal trade relations between the European Union and their trade partners.

According to critics, many economies using EPAs are not competitive enough in global terms to open

State 1

State 2

State 3



up their markets to rich European countries in the way they are required to under EPA regulations (Ilorah

& Ngwakwe, 2015).

The negotiations concerning EPAs in sub-Saharan Africa have highlighted the structural complications that exist within RECs due to members’ disunified position against extra-regional actors. For example, bilateral PTAs of the EU with members of a regional community can interfere with negotiations around EPAs between the EU and the REC as a whole. When single members of RECs already enjoy PTAs with the European Union, they are less incentivised to establish EPAs between their RECs and the European Union (Krapohl & Van Huut, 2020). Moreover, in the case of intra-regional competition for export to the European market, members may want to hold on to their personal preferential trade status with the EU instead of increasing competition by helping other REC members to enter the European market through an EPA (Krapohl & Van Huut, 2020). This would even create a motivation to work against good trade relationships between their REC and the EU.

Overlapping memberships to RECs

Adding complexity to understanding dynamics of regional collaboration, is that single member states are increasingly part of multiple regional communities. Scholars distinguish between two dimensions of membership overlap: mandate overlap and geographic overlap (Nolte, 2018). In the case of the former, there are multiple regional communities concerning the same policy area, whilst the latter refers to multiple regional communities active in the same region and having the same members. There are situations with both types of overlap, resulting in members of regional communities simultaneously being part of different RECs that try to cover the same policy areas in the same geographical area. The overall consensus is that overlapping memberships in the context of regional integration agreements stand in the way of successful integration, due to inefficient harmonization of economic policy (Bertelsmann Stiftung, 2020). However, few have tried to understand the causal mechanism linking overlapping memberships to the unfolding of regional integration in the Global South.

This is where two terms borrowed from European integration theories come in handy: widening versus deepening integration (Berglof et al., 2008; Patel, 2019). Widening integration refers to the expansion of policy and/or actors involved in the integration project, whilst deepening refers to the thickening of collaboration and the increase of supranational governance (Heidbreder, 2014). According to Heidbreder (2014), widening and deepening mutually reinforce one another, since widening increases the heterogeneity in an integration project and therefore the demands for deeper integration to solve coordination problems, as was the case when eastern European countries joined the EU project.

From integration dynamics in Europe to those observed in the Global South

As regional integration dynamics in the Global South differ compared to Europe, it is not realistic to assume that the process and outcomes of integration will be comparable. When theorizing on regionalization dynamics in the Global South, one must consider deviating intra- and extra-regional



relationships between states in respect to the European Union. As a consequence, the European based self-sustaining dynamic discussed by Stone Sweet (1999) (Figure 1) differs substantially in the Global South. Two reasons for this are especially noteworthy.

Firstly, where cross-border economic exchange tends to be attractive for neighbouring states in Europe, neighbouring states in the Global South are less likely to be convenient markets for each other. Reasons for the non-complementarity of the economies can vary, examples are weak diversification of export products or the non-excludability of tradeable commodities. Therefore, for many states the benefits of integration are mostly generated through the interaction of the region with extra-regional partners (e.g.

easier access to global markets) and not increased intra-regional trade per se (Krapohl, 2019).

Consequently, instead of being motivated to improve intraregional ties, members of the same integration communities experience competition for attracting privileged extra-regional trade flows that weaken the incentive to collaborate on a regional level (Krapohl, 2019). Intraregional competition for extra-regional privileged trade relations becomes problematic when it disrupts integration, when for example it disincentivizes member states to harmonize their trade policies. Countries within the region who a priori benefitted from advantageous trade agreements through special trade conditions, such as decreased tariffs, may not want to share or curtail their individual privileges for the sake of regional harmonization.

Consequently, this may cause defection or obstruction of further regional integration from this member state, whose dominant strategy is not to cooperate anymore (Krapohl, 2019). On the contrary, some member states may find the benefits from regional integration, such as the stabilization of trade and easy access to global markets, to exceed benefits from extra-regional trade relations. This would cause big attitudinal differences within such a regional integration community.

Secondly, judicialization through supranational dispute resolution mechanisms in Europe tends to be effective through legitimacy of institutions that are able to resolve disputes, whilst many regions in the Global South lack these. Especially as countries are in competition for external capital flows and common pool resources, the distributional implications described by Mattli & Stone Sweet (2012) of weak intra-regional cooperation could be very disrupting and the root of disputes. As distributional conflicts reflect unequal power relations within a region, proposed solutions by scholars include theories on transparent information, non-coercion and institution-rich environments. For example, one could argue that due to the highly institutionalized environment of the EU and the vast regulation of transparency, relative unequal power and information asymmetry is fought through transparency. On the contrary, regions in the Global South with weaker institutions may not profit equally from an information rich or non-coercive political environment, which slows down the advancement of regional norms (Krapohl et al., 2010). As a consequence, legitimate policy needed for fuelling regional integration is advanced at a slow pace and is likely to cause stagnation of the integration progress.



Theorizing the effect of forum shopping on regional integration in the Global South

The differences in integration dynamics in the Europe compared to the Global South also create different expectations in respect to widening and deepening of integration. Instead of widening leading to deepening, the expectation proposed in this paper is that widening will lead to more widening, influenced by forum shopping which motivates overlap in REC memberships (see Figure 4).

Figure 4: widening of integration in the Global South

Forum shopping is a term which has been widely studied in the public law context and has started to find its way into international relations theories. It refers to actors choosing the best institutional framework (a.k.a. ‘forum’) as dispute settlement mechanisms (DSM), based on their perception as to which forum will solve the dispute in their favour, and where the ruling will bring most future legal advantages (Apiko et al., 2019; Busch, 2007). Studies on overlapping memberships to international trade agreements tend to be focussed on the consequences of overlap in the context of international law and Dispute Settlement Mechanisms (DSM).

Some scholars, such as Davis (2009) and Froese (2016), extrapolated forum shopping principles to theorize on the connection between forum shopping and overlapping regional integration agreements.

According to Davis (2009), overlapping memberships affect multiple elements of the trade politics environment, which are: the selection of the trade institutions countries can refer to, the negotiations of commitments and the enforcement of these commitments. In the context of RECs, states could navigate the rules of their overlapping RECs with the scope of validating political goals by choosing through which REC their objectives would be achieved the fastest (Nolte, 2018). For example, in the case of the Common Market for East and South Africa (COMESA), the East African Community (EAC) and the Southern African Development Community (SADC), scholars have pointed to the large possibility of forum shopping, especially due to the similarity of scope and judicial instruments available in each REC (Kayihura, 2010). This would mean that states with multiple overlapping memberships would choose to apply the rules of the REC that suits them best in every specific situation. For instance, if a state would prefer to implement the FTA rules of REC -1 instead of REC -2, a state could validate this by referring to the institutions of REC -1, even though in practice this would mean to breach rules of REC -2 (Figure 5).

Forum shopping

Overlapping memberships

Widening of integration Coordination problems



Figure 5: visualization of forum shopping in RECs

According to Davis (2009), states consider the degree and/or timing of liberalization within a forum important when deciding to which forum they want to refer to. For example, she argues that those states who want to limit the scope of liberalization, may prefer sticking to regional or bilateral fora. Those meaning to slow down the pace of liberalization may prefer multilateral or bigger fora, as the vast number of actors involved in such agreements often slow down the stages of development and implementation of policy (Davis, 2009). Other arguments point to how being part of multiple trade liberalization agreements gives members the possibility to use each membership as leverage in other agreements, as members can threaten to leave the agreement and use other competing institutional frameworks to achieve their goals (Davis, 2009). To summarize, the possibilities arising from ‘REC shopping’, could motivate states to enter multiple regional integration agreements.

Membership overlap in south and east Africa

Afesorgbor and Van Bergeijk (2014) found that overlap in regional economic integration schemes is not per definition bad, as there is a big difference between complementary and competing schemes. In case of SADC, COMESA and EAC, the authors warn that overlap is however likely to cause difficulties and inefficiencies in the integration dynamics of the RECs, as they are not complementary but in competition with each other. Among the reasons mentioned are the shifting commitments of states holding multiple memberships and the differences in the rules of origin (RoO) of goods. The latter is referred to as

“inconsistent red tape” (Afesorgbor & van Bergeijk, 2014, p. 523) by the authors, which is a way the authors refer to the confusion arising around which goods to concede preferential treatment to. As Chacha (2014) states, overlapping RoOs are likely to complicate customs clearance for products entering or leaving states who hold double memberships. Chacha (2014) explicitly mentions the SADC- COMESA overlap example, to show how each respective RoO framework creates impossible customs situations for members of both RECs. As states become members of multiple agreements, they should implement different customs rules simultaneously, which is impossible. This therefore results in

State X


Trade partner Y

Trade partner Z



commitments not being fully fulfilled. According to COMESA sources, overlapping memberships inside COMESA are a serious problem once customs unions start to overlap (Mangeni, 2014) . By definition of a customs union, it is impossible to be part of multiple, since custom unions require the harmonization of external tariffs. Therefore, if country A is part of REC CU-1 and REC CU-2, it can never adhere to the CU rules of both RECs, with the exception of cases where CU rules would be identical. This however would mean that in practice the CU have merged and there is only one big CU left where members of all communities can profit from, despite which community they originally are part of.

The puzzle

As the literature showed, the dynamics of regional integration in the Global South are quite complex and differ substantially from those observed in the Global North. Regional integration agreements in the Global South have been proliferating, and with them also privileged trade agreements and other trade advancing frameworks. This proliferation has resulted in an increasing number of states being members of multiple regional integration agreements. Previous research showed that when states hold overlapping memberships to RIAs that are too similar in scope and/or geographical coverage, this impedes the integration progress of these agreements. The forum shopping literature showed that holding multiple memberships could enable states to shift their loyalty in the direction that suits them best in that particular moment, by choosing to which legal framework to adhere. Therefore, forum shopping would comprise a good reason for states to seek multiple memberships.

Following the theory, multiple memberships could slow down or even stagnate regional integration, as states try to profit from multiple memberships simultaneously through privileged trade. As a consequence, RECs would be incentivized to widen their integration projects to structure trade between those trade partners who seem to be willing to breach REC rules to maintain privileged trade relations and solve ongoing coordination problems. Therefore, the proposed hypotheses are:

Hypothesis 1: States use multiple memberships to RECs to benefit from overlap by applying trade rules that benefit them best in each particular trade relationship they hold.

Hypothesis 2: RECs dealing with members that have overlapping memberships to regional agreements are found to widen instead of deepen their integration.



Data and methodology


Conceptualization and design

The concepts used are operationalized as follows. Firstly, regional integration is operationalized by using memberships to regional economic communities (RECs). When speaking of deepening regional integration it is meant that RECs move to a higher level of integration (or also integration milestone) as described in Figure 2, so for instance from a FTA the REC becomes a CU. Widening regional integration means that the number of actors contributing to the integration project increase, in this case for example the number of members participating to an FTA agreement in a REC. Widening or deepening movements will also be referred to as integration events. Overlap in memberships refers to the overlap in memberships to RECs.

The research method applied in this paper is a comparative case study with a most-similar cases design.

The analysis consists of two parts. The first part analyses the motivations countries have to join multiple RECs. It focuses on whether states indeed join multiple RECs to navigate them in such way to obtain or maintain trade relations in their best interest, as described in the theoretic framework. It is structured following the integration milestones of RECs. This means that for each case, the motivations for supporting or hindering the achievement of new integration milestones will be analysed through qualitative as well as quantitative data. This includes statements made by relevant stakeholders, such as politicians or industry representatives, and empirical trade data in support of these statements. Trade data is also used to understand which trade partners are of main importance to the case, or which trade interests are in place due to the trade relations and/or consistency of trade of the case. Examples of questions that are posed:

- What was the role Case 1 played in the integration event of REC A?

- How did integration events affect intra- and extra-regional trade relations of Case 1?

- How did overlap between REC A and B affect trade relations of Case 1?

- What comprises the motivation for Case 1 to stay or leave REC A after Event X?

The second part is more explorative in nature, and addresses whether this forum shopping behaviour results in a widening instead or deepening of regional integration. This part of the analysis will be conducted by analysing the establishment of two major new integration projects that affected the region of the cases, to understand whether these contributed to widening or deepening of integration in the region. This will enable to conclude the role of forum shopping in the direction of integration and make final remarks on the subject.




Geographical area and case selection

This paper focusses on south-east Africa, because this region knows three1 big interconnected regional economic communities incorporating 26 African countries: the Southern African Development Community (SADC), the Common Market for Eastern and Southern Africa (COMESA) and the East African Community (EAC). The reason for selecting the region of southern and eastern Africa is that the SADC-COMESA-EAC area is a typical example of regional integration in the Global South, where overlapping memberships and other forms of privileged trade agreements are extremely common. Figure 6 shows the overlap in memberships as of the year 2022.

Figure 6: overlapping memberships within the SADC-COMESA-EAC geographical space in 2022

Selection of cases

This paper will focus on specific states as cases. These states have been selected to reflect as much as possible states that navigate the multilayer trade environment in the area, which translates to having a

1The same geographical area where SADC, EAC and COMESA are present, is also home to additional regional agreements, some complementary to existing ones whilst other in competition with them. Examples are the Southern African Customs Union (SACU), the Indian Ocean Commission (IOC) and the Intergovernmental Authority on Development (IGAD). For the sake of clarity, this paper will not include these smaller agreements in the discussion, but it is important to note them to understand the complex dynamics the high density of agreements causes in the area.





Burundi Malawi



Tanzania Zambia


Kenya Rwanda Uganda

South-Sudan Angola




Mozambique Namibia South Africa

Djibouti Egypt Eritrea


Libya Sudan





history of overlapping agreements, showing active involvement and movement between agreements and being eligible for and making use of multiple extra-regional privileged trade paths.

The most closely corresponding states to these criteria are the Republic of Kenya (from now on Kenya), the United Republic of Tanzania (from now on Tanzania) and the Republic of Zambia (from now on Zambia), of which involvement with the previously discussed RECs will be discussed in the following section.


In 1992 Tanzania was part of the nine founding states of the SADC (SADC, 2012). In 1994 it became part of COMESA, and in 1999 it co-founded EAC with the Republic of Uganda and Kenya (COMESA, 2022; EAC, 2022). However, in 2001 Tanzania withdrew its membership to COMESA. As a result, Tanzania remained only part of SADC and EAC. Tanzania participated to the negotiations for the establishment of the EAC EPA, but did not sign it when in 2014 the negotiations were concluded (Pichon, 2018). Moreover, the country is not part of the SADC EPA group either, but initially participated to negotiations too. Tanzania is entitled to various privileged trade arrangements since 1989 under the UN GSTP framework as an LDC. In 2000 it established privileged trade relations with the USA under the AGOA framework, and in 2001 it started using the EBA GSP framework to have access to the EU market (EAC, 2022; World Trade Organization, 2022). Furthermore, Tanzania formed various privileged trade agreements2 with other states, within the framework of GSTP.


Zambia co-founded the SADC in 1992 and the COMESA PTA in 1981, and it remained member of both communities since then (SADC, 2012; COMESA, 2022). Zambia, as Tanzania, does not belong to the SADC-EPA group and therefore does not enjoy privileged trade with the EU through an EPA (European Commission, 2016). However, as it classifies as a LDC country it still enjoys privileged trade with the EU through the EBA-GSP framework since 2000 (Delegation of the European Union to Zambia and COMESA, 2021). Being part of COMESA, Zambia also benefits since 2001 from the TIFA (Trade and Investment Framework Agreement) that the USA agreed to with COMESA (COMESA - US, 2001).

Zambia is also eligible for the AGOA, which permits privileged trade with the USA too since 2000. As to the bilateral privileged trade agreements enjoyed by Zambia, they are exactly the same as Tanzania and have also been established in the same years (World Trade Organization, 2022).


Kenya started as co-founder of the COMESA PTA in 1981 (COMESA Secretariat, 2018). In 1999 it co- founded EAC with Tanzania and Uganda (EAC, 2022). Kenya remained member of both COMESA and EAC throughout the years. Next to these regional economic integration agreements, Kenya benefits

2Korea, Morocco, Iceland, Turkey, Chinese Taipei, Tajikistan, Kyrgyz, India, the Russian Federation, China, Chile and Thailand (World Trade Organization, 2022).



from various privileged trade paths with regions or states outside its own region (World Trade Organization, 2022). Trading with Europe, it is excluded from the highest form of reduced duty under the Everything But Arms (EBA) GSP, because Kenya is not considered a LDC but a lower middle- income country (LMC) (The World Bank, 2022). This is an important difference between Kenya and the other cases used in this study, who are considered LDCs. However, Kenya is still entitled to special treatment under the normal GSTP framework, which provides privileged trade paths too (GSP Hub, 2022). The exclusion of Kenya from the EBA makes the country very keen for the EAC-EPA to come into force to assure its access to the European market (Pichon, 2018). Moreover, Kenya has enjoyed trade privileged with the USA since 2020 under the AGOA framework (, 2022). Lastly, next to the US, the EU and its regional partners, Kenya has a variety of bilateral privileged trade agreements3 in place. See Figure 7 for a summarized history of the RECs and the involvement of Tanzania, Zambia and Kenya (see Appendix A for a detailed overview of the history of SADC, COMESA and EAC).

3Turkey, Russia, Armenia, Kazakhstan and Kyrgyz (World Trade Organization, 2022).



Figure 7: overview of history of RECs and Tanzania, Zambia and Kenya

Suitability to work as most-similar cases

To check the compatibility of these cases to be used on a comparative basis, economic indicators (balance of trade per capita, GDP per capita, FDI in % of GDP and net development aid per capita) are chosen to compare economic development and trade patterns. As Figure 8.1 – 8.4 show, especially Kenya and Tanzania show very similar patterns. Zambia diverges somewhat regarding its balance of trade compared to Kenya and Tanzania, which opposite to Tanzania and Kenya remains mostly positive.

Furthermore, it shows some outliers in its FDI inflow and net development aid in the first half of the

’90. These spikes in FDI and development aid can be explained by considering the political situation around 1990 in Zambia, where Zambia experienced political turmoil due to massive civil uprising



against the one-party state led by Kaunda at the time (Schler, 2018). Besides these explainable differences, these indicators confirm that the cases are suited to use in a comparative case design.

Figure 8 (8.1-8.4): indicators of comparison suitability (data source: UN Comtrade, 2022; The World Bank, 2022)

Moreover, what makes the cases also very suited for the purpose of this research, is that they cover the three possible membership overlaps in the region: Tanzania (EAC – SADC), Zambia (COMESA – SADC) and Kenya (EAC – COMESA). As a result, these states provide convenient cases for studying the effect of overlapping memberships on regional integration in a most similar-cases comparative design. The period in time I will be using for the analysis is 1992, marking the establishment of SADC, until 2021, which is year of the establishment of the African Continental FTA started to be used.

Data used in analysis

The qualitative data used in the analysis consists mostly of statements of politicians or other relevant stakeholders. Most sources used are newspapers where these stakeholders are interviewed or quoted. A second type of source used concerns reports or conference nota from the RECs or other involved parties such as the EU.

As to quantitative data, most data concerns trade and tariffs data. Trade data comprises data on import and export, varying from in data per country, per region or per product(type). For the data on tariffs, effectively applied tariffs (AHS tariffs) instead of MFN tariffs will be used. This means that rates reflect

1991 1996 2001 2006 2011 2016

-300 -250 -200 -150 -100 -50 0 50 100 150 200


Figure 8.1: balance of trade per capita in US$

Kenya Tanzania Zambia

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 0

500 1000 1500 2000 2500


Figure 8.3: gross domestic product per capita in US$

Kenya Tanzania Zambia

1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 -2

0 2 4 6 8 10 12


Figure 8.2: foreign direct investment as % of GDP

Kenya Tanzania Zambia

1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 0

50 100 150 200 250


Figure 8.4: development aid per capita in US$

Kenya Tanzania Zambia



the lowest import tariff rate available in a specific trade situation. This includes preferential import tariffs which members of the same REC charge on each other (WITS, 2022). The three main data sources used to retrieve data are the World Integrated Trade Solution (WITS) database of the World Bank (WITS, 2022). In the remainder of the paper, every mentioning or visualization through graphs or tables of numeric trade data will done by using data retrieved from the WITS database, unless otherwise noted.

Examples of other consulted databases are the Observatory of Economic Complexity (OEC) databank and the World Trade Organization Preferential Trade Arrangements database (PTA).



Analysis part 1: Does forum shopping motivate states to hold multiple memberships to RECs?

In this chapter, I will analyse per case whether their membership to multiple RECs is motivated by the possibility to do forum shopping between these memberships.


The COMESA FTA and Tanzania’s withdrawal from COMESA

Trade partners

Studies have shown that Tanzania, as well as many other member states, would have benefitted economically from the COMESA FTA in the long run after some readjustments in the short term (Karingi et al., 2010). However, Tanzania decided to back out of the agreement in 1999, just before the coming into force of the COMESA FTA. The minister of Industry and Commerce (Iddi Simba)said the choice was motivated by the newly established EAC and the already existing SADC membership covering all the countries Tanzania had an interest in trading with (World Investment News, 2000).

According to him, staying in COMESA made no further sense, since the remaining members of COMESA did not have any interesting trade relations with Tanzania (World Investment News, 2000).

The data on intra-COMESA trade supports this, as in 1999 Tanzania’s trade with COMESA members that were not Kenya and Uganda comprised only 1.69% of Tanzania’s total exports, and 3.05% of its total imports. Kenya and Uganda together comprised 6.11% of Tanzania’s total exports and 5.95% of its total imports alone.

In 1999, president Mkapa also expressed his opposition to COMESA’s short-term abolition of tariffs due to the FTA implementation, emphasizing that Tanzania relied on import tariffs from neighbouring countries that used Tanzania as transit state (Suleiman, 2019). Therefore, the abolishment of all import tariffs would harm Tanzania’s economy, especially since not all COMESA members were at the same stage of development (Jacob, 1999; “Tanzania stands by COMESA withdrawal”, 1999)

Tanzania’s reluctance of advancing extra-regional trade liberalization through COMESA

Minister Simba discussed how adhering to all liberal market principles in general, including opening up trade borders to the global markets, worried him. However, data shows how Tanzania relied on extra- regional markets. At the time, on a global scale, India (15%), the UK (22.25%) and Germany (9.17%) were Tanzania’s top three export countries, with Kenya (5.79%) as first African country following at the 6th place. The European Union as a whole comprised 53% of Tanzania’s total exports (OEC, 2022).

Therefore, Tanzania’s individual access to the European single market through EBA benefitted the country a lot, especially as EBA was a unilateral type of liberalization instead of a reciprocal one. This enabled Tanzania to keep protecting its internal market, but simultaneously accessing the European



market without barriers. This shows that Tanzania had no real motivation to seek extra-regional privileged trade through COMESA, as it already provided for its PTAs by itself.

The overlapping membership of EAC and SADC

On a global level, the majority of Tanzania’s import and export partners between 2000-2015 remained non-African, indicating that overall, integration through EAC and SADC did not strengthen intra- regional ties between Tanzania and southern or eastern African trade partners much. African states that however remained important trading partners were especially Kenya and South Africa, but also Uganda and the DRC (Figure 9).

Figure 9: Overview of Tanzania's REC trade partners (yellow = important trade partners)

The first and second step of EAC liberalization: the EAC CU in 2005 and CM in 2010

Mr. Simba had stated that Kenya was one of Tanzania’s main trade partners and mentioned pressure from its Kenyan counterparts to take Kenya’s interest into consideration too (World Investment News, 2000). Data shows that Kenya stayed Tanzania’s biggest trade partner in Africa over the years. In 2000, 40.3% of Tanzania’s total exports to Kenya consisted of tea worth 14.7 million US$, for which Kenya required an average import duty of 15% (OEC, 2022; WTO, 2022). Export to its second biggest EAC partner, Uganda, consisted for roughly 45% of electronic transformers and devices, which held an import duty of on average 11.7% in Uganda (OEC, 2022; WTO, 2022). This shows one of many reasons why Tanzania had interest in lowering trade barriers with these countries, which eventually led to the establishment of EAC.


EAC Comoros


Burundi Malawi



Tanzania Zambia


Kenya Rwanda Uganda

South-Sudan Angola




Mozambique Namibia South Africa



Looking at Tanzania's trade relationship with EAC countries after the introduction of the CU, shows that imports increased very slightly from Uganda next to already growing imports from Kenya. As to Tanzania’s exports to EAC countries, they show a slight increase to Rwanda after the establishment of the CM in 2010. Nevertheless, except for the clear Tanzania - Kenya relationship, trade with the rest of EAC does not seem to increase much (see Figures 10.1 and 10.2).

The Tanzania – Kenya relationship

As to Kenya specifically, following EAC rules, tariffs imposed by Tanzania on Kenya diminished substantially after 2005 and reached 0% from 2009 onwards. Figures 11.1 and 11.2 show that Tanzania’s overall exports and imports from and to Kenya increase after the establishment of the CU. A spike of imports and exports also arises in 2013, which could be bound to the signed protocol to create a monetary union and therefore strengthen integration even further.

Despite Tanzania and Kenya being historic trading partners, the two also embodied each other’s greatest competitor on a lot of fronts. To start, Tanzania’s Dar es Salaam port functioned as one of two main gateways for the other landlocked EAC members and competed with Kenya’s Mombasa port (Williamson, et al., 2012). For instance, in 2009, 9% of the port’s transit cargo was Rwandan, and 11%

Burundian. Total traffic coming through the Sar es Salaam port grew from 6285,1k tons in 2005 to

0 100000 200000 300000 400000 500000 600000 700000 800000 900000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

In 1000 US$

Figure 10.1: Imports of Tanzania from EAC members

Burundi Kenya Rwanda Uganda

0 100000 200000 300000 400000 500000 600000 700000 800000 900000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015

In1000 US$

Figure 10.2: Exports from Tanzania to EAC members

Burundi Kenya Rwanda Uganda

0 100000 200000 300000 400000 500000 600000 700000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

In 1000 US$

Figure 11.1: top eight exports from Tanzania to Kenya

All Products Capital goods Consumer goods Intermediate goods Raw materials

0 100000 200000 300000 400000 500000 600000 700000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

In 1000 US$

Figure 11.2: top eight imports of Tanzania from Kenya

All Products Capital goods Consumer goods Intermediate goods Raw materials



9110k tons in 2010 (Williamson, et al., 2012). However, the port was known for having more logistical problems and higher prices compared to the Kenyan Mombasa port (NEPAD, Regional Integration and Trade Department, 2014). Despite competition amongst the ports, improving infrastructure in Tanzania would have benefitted all EAC members, as trade was bound to grow and trade hubs such as the ports would become increasingly important. Not surprisingly, in 2006 president Kibaki (Kenya) and president Kikwete emphasized the need to reinforce collaboration in EAC for the purpose of improving infrastructure in the region to facilitate mobility of goods and persons (UNOCHA Services, 2006). For Tanzania, staying in EAC would provide the resources to improve infrastructure and grow as trade hub.

Tanzania’s love – hate relationship with Kenya and their dominating position within EAC made intra- EAC relations tense sometimes (Cooksey, 2016). The competition between the two countries pushed division within EAC, especially as Kenya was very keen in accelerating the integration process whilst Tanzania was more reluctant. This division came as far as Kenya, Uganda and Rwanda founding the Coalition of the Willing, created to fast-track integration among each other. Tanzanian president Kikwete (president from 2005-2015) strongly opposed to this development, as EAC members should have formed a united front and stayed at each other’s pace according to him. However, EAC members expressed concerns about Tanzania being more devoted to SADC than to EAC, which president Kikwete denied (Cooksey, 2016).

The first step of SADC liberalization: the SADC FTA

SADC established an FTA in 2008, and Tanzania joined that agreement under special conditions to be allowed to keep protective barriers on some fragile industries, such as its textile industry (SADC, 2003).

Literature on SADC integration mentions how integration goals were overly ambitious and therefore impossible to implement in such short amount of time (Mapuva & Muyengwa-Mapuva, 2014).

However, this did not seem to bother Tanzania as Mr. Kikwete hinted, who emphasized the importance to change course within SADC by setting achievable goals for all members (Kikwete, 2016).

The slow pace of Tanzanian integration with SADC members is apparent in empirical terms. The establishment of the SADC FTA does not reveal any strong relationship with Tanzania’s trade within the region, except for its strengthened trade relationship with South Africa (Figures 12.1 and 12.2).

Intermediate products, stone and glass steadily comprised Tanzania’s main export goods to South Africa. The FTA led to tariffs over consumer goods to be abolished, which thereafter became the third most important Tanzanian export good to South Africa. Also imports from SADC members did not change much after the FTA, as South Africa remained the only prominent SADC trade partner of Tanzania.



At the time the SADC FTA came into force, Tanzania also had to adhere to EAC CU rules, being a EAC member. Even though tariffs on South African products did not fully adhere to EAC CET, Figure 13 shows how products from South Africa were taxed entering Tanzania, even after the SADC FTA. Some products adhered closely to the EAC CET, such as intermediate products being imported at rates between 7-11% and capital goods between 6-8%. Finished consumer goods however held tariffs much lower than the required 25%. Therefore, even though Tanzania profited from 0% rates to export to South Africa from 2010 onward, the abolishment was apparently not reciprocal. However, as Tanzania was allowed to maintain higher tariffs in SADC, it is not entirely clear whether the continued high import tariffs on South African products reflect an attempt to apply the EAC CET, or whether it reflects Tanzania’s general protective attitude towards its internal market. In any case, being member of the SADC FTA gave Tanzania the possibility to export to South Africa with reduced tariffs, even though it maintained protective measures for South African products entering Tanzania.

Extra-regional relations

The SADC-EPA was co-negotiated by Tanzania but not signed and ratified after negotiations ceased in 2014 and the EPA came into force in 2016 for the SADC EPA group. The terms of the EPA foresee complete abolishment of trade barriers for SADC members exporting to the EU market, and a reduction

0 5 10 15 20 25 30

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Weighted avergae (%)

Figure 13: Import tariffs for South African products entering Tanzania

Intermediate goods Capital goods Raw materials Consumer goods All Products

0 200000 400000 600000 800000 1000000 1200000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

In 1000 US$

Figure 12.1: top five exports destinations in SADC of Tanzania

South Africa Congo, Dem. Rep. Zambia

Malawi Mozambique

0 200000 400000 600000 800000 1000000 1200000

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014

In 1000 US$

Figure 12.2: top five import destinations in SADC of Tanzania

South Africa Mozambique Zambia Eswatini Namibia



of roughly 85% of trade tariffs for EU exports to SADC members (InBrief, 2006). Tanzania opted out of the SADC EPA negotiations in 2007 to join the EAC EPA negotiations. However, when EAC EPA negotiations came to an end in 2014 (Pichon, 2018), Tanzania neither singed nor ratified the agreement.

Multiple reasons can be found for this decision. First of all, it was worried that its industry was not ready yet to be opened up to the European Market under the terms of the EPA, especially considering that the EPA focused on manufacturing goods instead of services (Bertelsmann Stiftung, 2020). Also, since Tanzania benefitted from the EBA, it would benefit more having a unilateral agreement with the EU instead of a bilateral one with reciprocal opening of the markets. President Mpaka (1995-2005) opposed to the EAC EPA from the beginning (negotiations began in 2002 (Hangi, 2009)) and warned that Tanzania could not handle a two-sided trade liberalization. According to him, Tanzania’s industry would suffer from European competition (Hangi, 2009).

Conclusion of Tanzania

In general, the data points to Tanzania being a very protective state which was not too keen to liberalize its borders and abolish trade barriers. For Tanzania, the choice as to which REC to remain part of seems to be guided by Tanzania’s most important trade partners: South Africa (SADC) and Kenya (EAC). It looks like Tanzania used SADC to ensure a connection with South Africa, and EAC to do the same with Kenya. As Tanzania in many aspects also competed with Kenya, EAC also became a tool to keep Kenya close. In more specific terms, when the SADC FTA came into force in 2008 after Tanzania was already part of the EAC CU, Tanzania did not abolish tariffs on South African products, and it came close to adhering to the EAC CET. However, it started profiting from reduced tariffs to export to South Africa.

This created a situation in which Tanzania kept protecting its own market while simultaneously profiting from liberalization outside its own borders. Furthermore, in case of both SADC and EAC EPAs, Tanzania negotiated both EPAs knowing from the beginning that it opposed to reciprocal opening of markets. Therefore, it could have been the case that Tanzania actually participated in both negotiations to function as an opposing voice. In conclusion, it seems that Tanzania did follow patterns of forum shopping to stay connected to its most important trade partners and control extra-regional ties through different RECs.




Zambia’s approach to trade liberalization differs much from a protective state such as Tanzania. When Zambia became a multiparty liberal democracy in 1991, the incumbent president clearly chose the path of trade liberalization and privatizations (Zipar, 2014). Zambia’s membership history to RECs concerns SADC and COMESA, of which the country still is part of.

The overlapping membership of SADC and COMESA

The first step of COMESA liberalization: the COMESA FTA


Figures 14.1 and 14.2 show, during the time the COMESA FTA was established, on a global level Zambia’s main import partner was South-Africa, with as only African countries Tanzania (nr. 5) and Zimbabwe (nr. 3) following. Of these countries, only Zimbabwe was part of COMESA and also joined the FTA directly in 2000. Zambia’s biggest export partners around the beginning of the ’00 were the UK, South Africa (nr. 2) and Switzerland. Important African export partners next to South Africa were the DRC (nr. 5), Tanzania (nr. 6) and Zimbabwe (nr. 8). However, of these important African export partners the DRC did not join the SADC FTA and Tanzania withdrew from COMESA.

The inclination to trade liberalization can be observed in Zambia being one of the first nine states to immediately adhere to the COMESA FTA regulations and therefore committing to abolish all tariffs on COMESA originating products in 2000 (COMESA, 2022). In the keynote address given by the former Zambian president (Mr. Chiluba) in 1998, he clearly expressed its determination to advance economic integration in the COMESA region at fast pace, staying put on the integration milestones set as goal, such as to establish a CU in 2004 after the implementation of the FTA of 2000 (COMESA Authority of Heads State or Government, 1998). Empiric evidence shows that at first, the FTA itself did not create relevant new trade relations for Zambia.

1995 1996 1997 1998 1999 2000 2001 2002 2003 0

200000 400000 600000 800000 1000000

In 1000 US$

Figure 14.1: top nine world import partners of Zambia

South Africa United Kingdom Zimbabwe

Japan Tanzania France

India Germany Belgium

1995 1996 1997 1998 1999 2000 2001 2002 2003 0

200000 400000 600000 800000 1000000

In 1000 US$

Figure 14.2: top nine world export destinations of Zambia

United Kingdom South Africa Switzerland

Belgium Congo, Rep. Tanzania

Japan Zimbabwe Germany



Figures 15.1 and 15.2 show a slight increase of exports to Zimbabwe, but next to that, the first years after the FTA establishment imports or exports with trade partners who also singed the COMESA FTA, such as Kenya and Malawi, do not seem affected. Average tariffs regarding imports from these countries also experienced quite fluctuating trends, as Figure 16 shows.

The first step of SADC liberalization: the SADC FTA

According to the Diagnostic Trade Integration Study (2005), the share of trade with the EU had been declining in the past years while in the meantime Zambia’s trade ties with SADC members tightened (specially with South Africa, as also Figures 14.1 and 14.2 showed) (Ajwas, et al., 2005). As this was seen as a positive change, the government members were advised to continue on this path by further export diversification and focussing more on regional integration initiatives. While presiding as chairperson of the SADC in 2007, Zambian president Mwanawasa stated that his main objective during his serving term was to achieve a SADC FTA which had been under preparation since 2000. Other Zambian stakeholders, such as the Zambia Manufacturing Association, also seemed enthusiastic about starting to enjoy more liberalized trade in the SADC area (“SADC prioritises free trade”, 2007).

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 0

5 10 15 20 25 30 35 40 45

Weighted average (%)

Figure 16: average import tariffs on products from Kenya, Malawi and Zimbabwe entering Zambia

Kenya Malawi Zimbabwe

0 500000 1000000 1500000 2000000

In 1000 US$

Figure 15.1: top nine COMESA import partners of Zambia

Zimbabwe Congo, Dem. Rep. Eswatini

Mauritius Malawi Kenya

Namibia Egypt, Arab Rep. Uganda

0 500000 1000000 1500000 2000000

In 1000 US$

15.2: top nine COMESA export destinations of Zambia

Congo, Dem. Rep. Zimbabwe Malawi

Kenya Burundi Rwanda

Namibia Uganda Mauritius




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