Under-invoicing rocks raw rubber exports
Investigations by the Daily Graphic have revealed an under-declaration of over $70 million exports of rubber over two years.
The checks indicate that export volumes exceeded stated permits, with a compromised system that threatens the country’s local processing infrastructure.
For instance, discoveries include export Free on Board (FOB) under-declaration of nearly $50 million in 2024 and more than $21.5 million in 2025, where the export volumes exceeded official export permits issued in both instances.
Export data of raw rubber obtained from the Ghana Revenue Authority (GRA) show that the nation exported 89.68 million tonnes of raw rubber in 2024 alone, although the industry’s supervising body, the Tree Crops Development Authority (TCDA), did not issue a single permit for raw rubber export in that year.
Conversely, the TCDA issued permits for the export of 13,000 tonnes of raw rubber in 2025. However, official data covering the entire year, except for October and November, show that 39,000 tonnes of raw rubber were exported, representing an excess of 26,000 tonnes of raw rubber export, nearly 200 per cent more than the issued permits.
The scale of under-invoicing in the raw rubber export business appears to facilitate a systematic repatriation of resources from the economy.
For instance, TCDA set the average minimum price of raw rubber for 2024 and 2025 at GH¢8.62 and GH¢9.08 per kilogramme, respectively, but the average declared FOB price for 2024 and 2025 by exporters of raw rubber was GH¢0.99 and GH¢1.91 per kilogramme, respectively.
This means that every kilogramme of exported raw rubber in 2024 and 2025 was under-invoiced by an average of GH¢7.63 and GH¢7.17, respectively.
Cumulatively, raw rubber exports were, therefore, under-invoiced by more than $49.6 million in 2024 alone, and by more than $21 million in 2025.
This means exporters declared just about 12 per cent of the actual value and volume of raw rubber exports for 2024, and about 22 per cent of the export in 2025.
FOB under-declarations
The FOB under-declarations tell a far more complex story.
In the export business, Section 15 of the Foreign Exchange Act, 2006 (Act 723) requires exporters to repatriate the full export proceeds through a licensed bank to meet the obligation of the Letters of Commitment necessary for export.
The process ensures that they return the entire export revenue into the local economy.
By under-invoicing the value of exports, however, the exporter may keep the difference in value offshore that is, outside the economy of Ghana.
So, for 2024, the complicit exporters brought back just $6.17 million into the Ghanaian economy out of the actual export value of $55.83 million, while in 2025, they shipped out $26.03 million worth of raw rubber but brought back just $4.48 million.
Customs records available to the Daily Graphic suggest that two agencies dominated the raw rubber export trade in 2024 and 2025.
For instance, one of the companies exported raw rubber to the tune of $44.96 million in value in 2024, representing about 91 per cent of raw rubber export for that year, while the second company also exported raw rubber to the tune of $21.23 million in value last year, representing 98 per cent of the total raw rubber exports for that year.
Intriguingly, the two major exporter company stated their FOB prices in July 2025 to be $0.069 equivalent to GH¢0.72 per kilogramme (KG), against the TCDA’s minimum price of GH¢9.8.
A rubber cultivator, George Eshun, who farms in the Nzema East District in the Western North Region, confirmed to the Daily Graphic that raw rubber was sold locally for GH¢8.30 currently.
He admitted, however, that he sold to whoever was ready and willing to buy, and that the market was not restricted to local processors.
Industry data
However, the issues within the system are even more complex and controversial.
Although local rubber processing factories currently have a combined capacity of 171,460 tonnes per year, industry data show that the country produced just around 110,800 tonnes of raw rubber in 2025, for instance.
This means that the country’s rubber processing capacity far outstrips the raw rubber production scale by a deficit of more than 60,000 tonnes, constituting about 35 per cent of the raw rubber produced by the country.
The wide deficit consequently leaves the local processing infrastructure idle for most of the year as the country is unable to supply in adequate quantities to meet local processing scale.
Export restriction
It is for this reason that the government announced a restriction on raw rubber export to ensure adequate supplies for local processing factories.
In January this year, the Minister of Trade, Agribusiness and Industry, Elizabeth Ofosu-Adjare, stated during her turn at the Government Accountability Series that Cabinet had approved restrictions on the export of raw natural rubber to protect domestic industries and ensure that local manufacturers had access to an adequate supply of raw materials.
Before that pronouncement, the Minister of Finance, Dr Cassiel Ato Forson, had announced the action during the presentation of the 2026 Budget Statement to Parliament in November last year.
Indeed, with approximately 39,000 tonnes of raw rubber exported in 2025, for instance, domestic processors were left with only about 60,000 tonnes of raw rubber to process.
"The truth is that the picture I see is not too pleasant for the industry," a stakeholder told the Daily Graphic.
Ultimately, the situation has exposed local processing companies to the risk of collapse.
Currently, all the local rubber processing firms are producing at less than 40 per cent capacity, with jobs cut by more than 35 per cent.
Since 2024, one of the local processing factories, Apex, has not processed a single ounce of raw rubber.
Data available to the Daily Graphic suggests that five of the other six processing factories have scaled down due to the lack of raw rubber.
But the problem lies deeper and extends into industry job security, youth employment, the value of investments in rubber processing infrastructure, and even state revenue from taxes.
Frustrations
Some correspondences obtained by the Daily Graphic reveal the frustrations of the Association of Natural Rubber Actors of Ghana (ANRAG) regarding the continued export of raw rubber.
For instance, by a letter dated July 2, 2025, the association, through its President, Emmanuel Owusu, raised concern over "the continued transportation and apparent export of raw rubber within the Tema Port enclave".
In response, however, the TCDA stated in a letter dated October 20, 2025, that "we do not possess the legal authority to unilaterally ban or suspend the business operations of licensed entities, including the exporters of unprocessed rubber".
The letter signed by the Chief Executive Officer of the authority, Dr Andrews Osei Okrah, instead insisted that the TCDA "has introduced and enforced stricter regulatory controls in the rubber industry, which are already yielding measurable benefits", and that "since the introduction of TCDA's licensing and export permit regime, both the number of exporters and the volume of raw rubber exports have declined significantly".
