THE Rubber Processors Association of Ghana (RUPAG) has petitioned the Ministries of Food and Agriculture, Finance, and Trade and Industry over what it describes as persistent under-declaration in the export of raw natural rubber.

In the petition, sighted by The Ghanaian Times, the Association expressed deep concern about what it termed systematic undervaluation of raw rubber exports, regulatory non-compliance, and the continued export of unprocessed rubber in contravention of Government’s value-addition policy.

It said the practice was depriving the country of significant foreign exchange and undermining Government’s industrialisation drive.

According to RUPAG, official export data covering January to September and December 2025 revealed that a total of 39.32 million kilogrammes (wet) of raw rubber were exported under 195 export declarations, with a cumulative declared Free on Board (FOB) value of just US$4.48 million.

However, when benchmarked against reference prices issued by the Tree Crops Development Authority (TCDA), which constitute the statutory minimum purchase prices, the same exports should have yielded about US$26.03 million.

This discrepancy, RUPAG noted, pointed to an estimated under-declaration of about US$21.55 million.

A further month-by-month analysis, comparing TCDA minimum prices with average FOB values declared by exporters, revealed that declared export prices were, on average, about 78 per cent below the applicable minimum prices.

“The consistency and scale of this variance strongly suggest a pattern of systematic under-declaration rather than isolated reporting anomalies,” the Association stated.

RUPAG warned that the situation raises serious concerns about compliance with the Foreign Exchange Act, 2006 (Act 723), which requires the full and timely repatriation of export proceeds. It argued that the magnitude of the apparent under-declaration implies practices that significantly deny the State much-needed foreign exchange inflows at a time when the economy is under pressure.

Beyond valuation issues, the Association drew attention to the opportunity cost of exporting raw rubber instead of processing it locally.

Using prevailing SICOM TSR-20 processed rubber prices as a benchmark, RUPAG estimated that Ghana could have earned about US$75.79 million if the exported volumes had been processed domestically.

Compared with the declared export receipts, this represents an estimated foreign exchange opportunity loss of about US$71.17 million.

The Association also clarified that rubber farmers are not the direct exporters of raw rubber. Rather, exporters operate through intermediaries who aggregate rubber purchased on the local market and channel it for export.

This, RUPAG said, is critical for policy intervention, as it highlights where regulatory oversight and enforcement should be focused.

RUPAG further expressed concern about apparent administrative breaches of Regulation 50 of the Tree Crops Development Authority Regulations, 2023 (L.I. 2471), which requires mandatory consultation with the Rubber Value Chain Committee of the TCDA Board on matters affecting the rubber value chain, including exports.

The Association said it was not aware of any such consultations prior to the issuance of export permits, if permits were indeed granted.

The petition also pointed to an apparent contradiction between current export practices and government’s stated policy direction. The 2026 Budget Statement, presented under the Feed the Industry Programme, commits government to restricting the export of selected raw materials, including raw rubber, to support domestic processing, job creation, and industrial growth.

RUPAG in the statement disclosed that a new rubber processing factory was expected to commence operations in the Central Region in the first quarter of 2026.

With existing installed processing capacity already exceeding projected raw material production by 60,000 to 70,000 tonnes (dry) per year, the continued export of raw rubber could further constrain factory utilisation.

RUPAG called for an urgent inter-ministerial investigation into export valuation practices, strict enforcement of foreign exchange regulations, compliance with TCDA consultation requirements, and the immediate operationalisation of restrictions on raw rubber exports.