From 10 to 12 November 2025, the United Nations Environment Programme (UNEP), through its Law Division and the Secretariat of the Green Customs Initiative (GCI), participated in the Mid-term Evaluation Meeting of Operation DEMETER XI, held in Mombasa, Kenya. The meeting brought together 36 participants from 23 African and international customs administrations, including Angola, Belgium, Botswana, Burundi, Cameroon, China, the Democratic Republic of the Congo, Ethiopia, The Gambia, Japan, Kenya, Liberia, Mauritius, Namibia, The Netherlands, Nigeria, Sao Tome and Principe, Seychelles, South Africa, Tunisia, Uganda, Zambia, and Zimbabwe, to review progress and strengthen enforcement actions against illegal trade in environmentally sensitive goods.

UNEP delivered a presentation titled “Strengthening Legal and Institutional Linkages to Support Enforcement of Trade-related MEAs: Insights from the Green Customs Initiative,” highlighting the Green Customs Guide to MEAs as a practical tool that translates complex treaty obligations into operational guidance for frontline customs and border officials. The presentation also reflected on recent global developments, including the Minamata Convention on Mercury, the Kigali Amendment to the Montreal Protocol, and the Basel Convention’s plastic waste amendments.

Discussions highlighted ongoing enforcement challenges related to Free Trade Zones (FTZs) and the Prior Informed Consent (PIC) procedure under the Basel Convention. While customs administrations across the region require import and export declarations for goods entering or leaving FTZs, environmental controls often remain fragmented. UNEP emphasized that FTZs, though granted special customs status, remain legally part of a country’s territory and are therefore subject to environmental licensing and import restrictions under national and international law. Without effective oversight, FTZs risk becoming loopholes for illegal dumping or transit of hazardous waste. Participants noted emerging good practices, such as Thailand’s 2025 ban on plastic waste imports, which explicitly extends to FTZs, ensuring coherence between trade and environmental regulation.

The meeting also noted that several African national management authorities continue to rely on partially manual PIC systems, causing delays in obtaining import consents. Efforts are underway to streamline the procedure through digitalization, improved inter-agency coordination, and interoperable electronic systems linking environmental authorities with customs and regional databases.

In its intervention, UNEP underscored the critical role of customs and border control officers as the first line of defense against environmental crime, emphasizing the importance of bridging legal frameworks with institutional practice to make enforcement of multilateral environmental agreements (MEAs) more effective. The meeting strengthened collaboration among customs administrations, MEA secretariats, and international partners, including the World Customs Organization (WCO), the BRS Conventions Secretariat, and UNEP OzonAction, while reaffirming recognition of the Green Customs Initiative as a vital platform for empowering customs officers, fostering inter-agency coordination, and supporting robust enforcement systems that protect the environment and advance the Sustainable Development Goals.