Review of: Estimating the Impact on Mozambique of Different Trade Policy Regimes: SADC, SACU or MFN? This note has been prepared at the request of USAID’s Trade and Investment Program (TIP), to provide an independent assessment of the recent paper on Estimating the Impact on Mozambique of Different Trade Policy Regimes: SADC, SACU or MFN? by Andrea Alfieri, Xavier Cirera and Alexis Rawlinson (hereafter AC&R). The review consists of three sections: general comments, technical comments, and conclusions. My intention in this review is to raise issues as I see them, focusing on constructive criticisms, as a input for other readers, particularly those without a strong technical background in economics. I trust that the authors will quickly point out any instances where my comments reflect a misunderstanding of their analysis. General comments The paper is chock full of useful data and pertinent insights. Among other things, it provides a valuable analysis of the SACU arrangements and the economic impact of four different trade reform scenarios for Mozambique: joining SACU, with and without the FTA with the EU; fully implementing the SADC Trade Protocol; and full unilateral liberalization of MFN tariff rates. Much to their credit, AC&R repeatedly emphasize that the results are limited by the partial equilibrium and comparative static methodology. Despite the limitations, the model yields new and valuable information on the direct, short-run impact of trade reform for each of 5270 HS product codes (though the paper only reports the 2-digit aggregations); results are also given for the impact on government revenue and consumer welfare, based on 2004 import data. As the authors explain, the analysis excludes indirect adjustments arising from market responses to the trade reforms, as well as dynamic effects on investment, innovation, production techniques and labor skills, in response to changing incentives and competitive pressures. The calculations also exclude the impact on Mozambican exports and production for the domestic market. Even with all the caveats given in the paper, AC&R do not adequately convey to a general reader the severity of the methodological limitations. For example, they say nothing about the extent to which partial equilibrium results can differ from general equilibrium effects, where the latter include upstream linkage effects, changes in the cost of labor and capital, changes in household income and consumption, and changes in the real exchange rate, among other indirect effects of trade reform. They don’t even mention how the trade reforms might affect the exchange rate. Because of the limitations of partial equilibrium methods, many analysts rely on CGE models to assess the economic impact of trade reform. I am not saying, however, that AC&R should have done a CGE paper. The estimation of partial equilibrium effects at the 6-digit level is a major contribution to the debate.1 My point is simply that the policy audience in Mozambique should have a better explanation of how much the 1 And CGE analysis has its own problems, including a much greater degree of aggregation, yielding impact results that are much less product-specific. limitations may matter. For generalist readers, it’s not enough to cite the caveats. Moreover, ACR claim that the partial equilibrium analysis provides “a clear orientation of the sign and magnitude of the changes expected…” (end of section 3.1, with similar language in section 9.1). This may be seriously misleading. xc: I guess we should put more emphasis on the limitations of the partial equilibrium analysis. The same comment applies to the static nature of the methodology, perhaps more strongly. AC&R do explain very clearly that the results exclude dynamic effects. But here, too, they do not adequately convey the severity of the problem. Indeed, the prospective dynamic gains are the driving force behind efforts to liberalize trade, across the globe. Estimates of the static effects routinely reveal very small net changes in welfare from trade reform. xc: Again, we should add a paragraph on potential dynamic gains, but the computation of these gains was out of the scope of the paper and out of reach with this methodology Some other important issues are more technical in nature. See next section. Technical comments, in order of appearance. Asterisks (***) indicate importance.2 Intro, para 5 - impact on exports: AC&R suggest that not having estimates of the impact on exports does not matter much because Moz already benefits from duty-free access for most products to RSA and the EU. Later, they also (rightly) express doubt that exports would rise significantly due to cost and capacity constraints. Nowhere do they point out, however, that import taxes have adverse general equilibrium effects on exports equivalent to a tax on the latter, through adjustments in the exchange rate and incentives for resources to move away from export industries. xc:We can add this general equilibrium effect as section 6. However, I believe that this would depend on how export sectors are treated. The government may be assisting export sectors via tax breaks and duty drawbacks. So the distortion may not be biased against exporters. In any case this is an empirical issue and maybe we should mention it. * After Table 2 – the higher duty rates are mainly for revenue collection: It’s almost tautologically true that goods facing higher duty rates are the main source of customs revenue. But the revenue objective could just as well be achieved with lower and more uniform rates. Thus, revenue objectives cannot explain for the observed dispersion in duty rates, which create very high rates of effective protection and costly incentives for inefficient resource allocation. 2 I avoid using page numbers for reference because some readers may be printing on A4 rather than lettersize paper, which affects the pagination. 2 xc: The intention of the paragraph was to differentiate between two objectives of trade policy, revenue vs protection, and to say that is not protection that explains the tariff structure. High tariffs may not bring much revenue because protect a sector with few imports or price elasticity of demand is very high. The point we want to make is that revnue objective dominates protection objective. About: “the revenue objective could just as well be achieved with lower and more uniform rates”. I think that it may be also maximized with higher dispersion in few tariffs, while others are duty free. This depends eventually on the trade policy objectives, but I think that at some point we (or someone else) should do an exercise of simulation for achieving an “optimal” tariff structure. * Section 3.1 - price elasticities: The analysis would be improved by (a) more justification for using unitary export elasticity for RSA, rather than a higher or lower elasticity, and (b) sensitivity analysis reporting the effects of alternative parameterization. The reader is given no clue about the extent to which this assumption affects the results. xc: See final note ** Section 3-2 – Definition of scenarios: The MFN scenario is a curiosity. It’s not clear that this is a very informative option, because no one is advocating zero duties across the board. A better option would have been to examine the effects of moving to a low, uniform tariff at (say) 5% while eliminating all exemptions. xc: The idea was to get a higher bound of the estimations. This scenario has been incorporated in the revised version *** Same place: I don’t see why the reduction to 20% in top duty rate is incorporated in the post-reform scenarios but not the baseline. Using 25% for the baseline overstates the revenue loss from the indicated reforms. Worse, Table 6 shows the 20% rate being used for only the FTA scenario. If other scenarios do not incorporate the top-rate reduction, then the revenue impacts are all skewed against FTA. xc: But the level of imports in 2004 was with the rate at 25% not 20%. Of course this implies that part of the tariff reduction would happen anyway because MFN commitments. We should specify this rather than changing our pre-reform to 20%. FTA is the only scenario that includes this reduction, because the others imply adopting a different tariff structure, SACU or 5% *** Below Table 6, SACU scenarios: It’s hard to see how Mozambique could avoid the de facto effect of the TDCA under SACU. Thus, the SACU 1 scenario (without TDCA) is largely irrelevant. There also seems to be a serious problem with the SACU 2 (with TDCA) scenario. The calculations include the effect of reducing duties on 3 imports from the EU to zero, but exclude the impact of TDCA the price of imports from RSA. Consequently, it’s not clear that either SACU scenario makes sense. xc: There is uncertainty about the final outcome TDCA-EPA. That is why we opted for using the two scenarios that we know in practice. I agree that the TDCA is the most likely, but it is still uncertain. Not sure I understand your second point “but exclude the impact of TDCA the price of imports from RSA” ** Figure 3: For generalist readers, it would be useful to use this figure to make a few additional pedagogical points: o In this case eliminating duties on SADC imports has no effect on the price or the consumer surplus in Moz. There is still a negative revenue effect, equal to the shaded area shown in my Figure 1 below. (This point is presently buried in the Methodological Appendix.) o In this case, the shaded area also represents a real resource cost to Mozambique from trade diversion. Moz will now be paying South African suppliers a price of (1+τ)p*. In the initial (tariff-ridden) situation, suppliers in RSA were only paid p*, with the difference being a transfer from consumers in Moz to the Treasury in Moz – not a real welfare cost to the nation. (More on that below). aa: It seems to me that Bolnick’s is sometimes confusing welfare effects computed using standard Harberger triangles with trade diversion and trade creation effects. They are different concepts and maybe we should make it clearer in the text by interpreting the welfare change along the following lines. For instance, in the figure below I think there’s no doubt that by defining Mozambique’s welfare as Rev + CS, the country is having a net loss equal to the shaded area due to revenue loss. This loss can be “interpreted” as a transfer to SADC exporters (A) plus a resource loss due to trade diversion (B) which is actually a deadweight loss for the all FTA. This is clearly explained by Panagariya in the case referring to figure 2 in his paper. 4 Figure 1: Imports from SADC and ROW SADC1 Price (1+τ)p* SADC0 E1 ROW1 A B E0 p* ROW0 Demand Imports Msadc1 Msadc2 M1 M0 *** Para after Eq (12) – Import demand elasticity assumptions: These parameters are critical to the empirical results, and should not be dished up with a simple reference to Stern et. al (1976). Please elaborate! Are the Stern estimates pertinent to a country like Mozambique? What are some representative parameter values for key sectors? Are these short-run or long-run elasticities? How sensitive are the results to reasonable parameter changes? Am I making a mountain out of a molehill? xc: Well the issue here is that we do not have any information on import demand elasticities and its computation with the data available in Mozambique is very difficult. Of course the results are very sensitive to the import demand coefficients, but we could not find any other source. In future work we will do some sensitive analysis. In any case the ordering of the scenarios in terms of welfare will not change Section 4.1, first bullet (and section 4.4) – SACU w/o TDCA involves “greater protection than existed in 2004”: The numbers here don’t support this statement. They show that under SACU 1 the average price of imports drops by 3.55%, and (in Table 7) the value of imports falls less than this, indicating a rise in import volume. A drop in import prices and rise in volume do not suggest greater protection. aa: we deleted the above statement from the text already **** Before Table 7 – revenue losses exceed consumer gains, implying overall national welfare loss: This is the first of many places in the paper where the algebraic sum of the change in revenue and the change in consumer surplus is used to tally the change in national welfare. Either I’m not thinking clearly (always possible!) or this computation introduces a major problem with the quantitative results. Let me use a 5 simple example, shown in my Figure 2 (below), to make my point. The example is the MFN case, with a tariff of τ applied to all imports of a particular good. Figure 2: Simple tariff case Price E1 (1+τ)p* A ROW1 B E0 p* ROW0 Demand Imports M0 M1 Suppose we remove the tariff. Consumer surplus improves by A+B, while revenue declines by A. The foregone revenue, however, is a transfer from the Treasury to the consumers. It is not a national welfare loss. aa: Do we say it is a national welfare loss? It seems to me that in the text we simply say that the net welfare change defined as Tariff revenue + consumer surplus is (in this case) positive by B (A is a transfer and B is a gain from trade) This is clearly explained in the JEL paper by Panagariya (2000, p. 290-291), which the present study cites as the main source of the model being used. aa: Actually this is not correct. Panagariya in a similar case in the quoted paper (fig 1a – p291) states clearly that B is a net (welfare) gain for A (in the text the example refers to the opposite case so the author defines “the area e as a net loss” to the home country). Furthermore, in the MFN case, area A cannot possibly exceed area (A+B). The difference (triangle B) is often called the “deadweight loss,” because this part (and only this part) of the tax-induced loss to consumers is not offset by a corresponding gain to the Treasury. When the tax is removed, triangle B represents the net gain in national welfare, which must be positive in the partial equilibrium model. aa: Agreed. The case shown in my Figure 1, above, is quite different. There is no change in the equilibrium price or quantity, and therefore no change in consumer surplus. And in that example the loss of revenue does correspond to a national welfare loss – but the 6 welfare effect derives from paying a higher price to suppliers in RSA, not from the loss of revenue to the Treasury. Thus, the change in national welfare is not equal to the change in revenue plus the change in consumer surplus. The correct formula is to tally the net welfare effect as the change in the deadweight loss triangle plus the change in the real cost of imports due to trade diversion. xc: Not sure I understand your point. Should not be trade diversion incorporated in the loss of revenue not being transferred to consumers? We have revised our figures, because there was a scaling problem, that underestimated consumer surplus, and maybe now the figures are more in line with your comment. In any case, we prefer to use changes in consumption surplus and revenue because are more relevant for the policy makers. Trade creation and trade diversion are what explain changes in consumer surplus and revenue. ** Section 5.2 – fraud adjustment: I haven’t read Van Dunem’s (2005) paper to see how he arrives at the fraud elasticity of 1.4. But the explanation given here suggests that Van Dunem assumes that the entire bilateral discrepancy between the reported CIF value of imports to Moz and exports from RSA is due to fraud on the Moz side. That sounds plausible. Except that (a) footnote 4 in section 2.1 suggests that the discrepancy is very small, which belies such a large elasticity; and (b) there is a history on the RSA side of claims for fictional exports or back-and forth exports for purposes of defrauding the government on duty drawbacks, VAT refunds, and other export incentives. Also, (c), it’s unlikely that a single elasticity applies to a reduction from 20% to 5% versus a reduction from 5% to 0%. This adjustment turns out to have a large effect on the results. Thus, it merits more careful discussion, and possibly more careful application of Van Dunem’s estimate. xc: Without discussing van Dunem’s paper. Our footnote refers to totals and the problem of unclassified imports in 2004. Before this year there were more discrepancies, and at the product level discrepancies still persist. By using this elasticity we wanted to make the point that if it is positive then trade reform may trigger larger registered trade flows. We use 1.4 because that is the reference that we have for Mozambique. But as you mention, quite likely there should be some threshold effect on the elasticity, a tax level at wich smuggle happens. Several tables (e.g., Tables 22 and 28) lack mention of units. Are the numbers in rand, dollars, millions, billions? Billion dollars * Just below Table 24 – Kirk and Stern (2004) results: There is such a large difference between the present results and those of Kirk and Stern – even a reversal in the sign of the net welfare effect – that one would appreciate a more thorough discussion of the reasons. xc: It is difficult to discuss when their approach is quite different, since they applied percentages on aggregate numbers, while we aggregate from impacts at the product level 7 * Section 7.1 – price transmission: This excellent passage neglects an important point. The net welfare effect from trade liberalization should include the net benefit to consumers from lower prices on goods produced domestically that face more intense foreign competition due to the reform. To be sure, there is a corresponding loss of income to domestic producers, but as resources are reallocated to alternative uses, a simple partial equilibrium model shows that the benefit to consumers exceeds the loss to producers. Calculations in this paper show only the welfare change associated with net imports (because that’s where we have data). This focus is likely to understate the change in national welfare, possibly to the point of reversing some results. This is just another way of underscoring the limitation of the partial equilibrium analysis. xc: Agree, but again we cannot quantify that. In any case its is important to point out at the importance of price transmission * Section 8, trade deficit – The analysis in this section is weak. Changes in the overall trade balance are inherently driven by a variety of macroeconomic and microeconomic factors that fall well outside the scope of the partial equilibrium analysis in this paper. Among other things, the trade balance varies with the availability of international financial flows (including grants and remittances); the trade balance also depends heavily on the balance between domestic saving and investment; changes in trade patterns due to economic reforms may produce offsetting exchange rate effects. In addition, the rapidly growing trade deficit indicated in Table 28 is a figment of the dates chosen. Using 2002 as the starting point rather than 2001, the deficit has narrowed, not widened. In essence, this section reads like an afterthought and adds nothing useful to the findings. Methodological Appendix: I went through only a few sub-sections, and found a few issues of note: o Section 10.2.1.2 Case 2: As I understand this case, Trade Creation (TC) is not zero. This can be seen in the difference between M* and M0 in the graph, and the fact that both variables enter the CS equation. xc: Panagaryia in an identical example in his paper (fig.3 – case 2, p. 296) defines Trade Creation as greater than zero. However, this seems to contradict previous definitions of trade creation that should imply bothh generation of new trade and switch towards more efficient producers (with respect to either domestic or other external producers). In our case we say that there is no trade creation since SA is not more efficient than the ROW and we define this increase in trade as something else: a so-called “consumption effect” following Morrisey, Milner and McKay. In Panagariya there’s no mention to such consumption effect. o Same section and case: the equation for ΔE seems to include only the quantity effect on VAT revenue and neglect the price impact from having a smaller tariff rate (=P0 - Psa in Figure 10.2.1). xc: corrected o *** Same section and case: This section has the first appearance of the equation for the net national Welfare Effect (WE) in the Appendix. It is given as: WE = ΔR + CS. In line with my earlier comments, and my Figure 2 above, CS is defined to include the revenue loss rectangle plus the deadweight loss triangle. If my comments are on target, then this is not the correct equation for WE. The problem 8 applies throughout the paper. aa: See comments made above. It is possible to distinguish standard welfare effects from trade creation and diversion effects. The result, however, should not change. o *** Section 10.2.4, MFN scenario: The equation for CS in this section appears to be incorrect. Elimination of the tariff (τ) yields a gain in consumer surplus equal to ΔP*M0 (the rectangle) plus (1/2)*ΔP*ΔM (the triangle). Also, the labels for P and M in Figure 10.2.4 are incomplete. xc: I think is correct as it is xc: We solved the model in GAMS as a system of equations, so in reality there is only one case for every scenario and the algebra is irrelevant. It is in the paper as an illustration of the methodology Conclusion The authors deserve great credit for producing these important results, and also for calling attention to shortcomings of the static partial equilibrium analysis used in the paper. Their computations provide very interesting and useful information on the direct impact of trade reform on particular sectors, but their overall conclusion should be much more attenuated. Despite the caveats, the authors lean too heavily on the empirical results to make the case for joining the SACU customs union. This is particularly problematic considering that the results for the SACU case are estimated using the current revenue sharing formulae. As the authors acknowledge, the consequent changes affecting the revenue shares for BLNS raise serious doubts that SACU would admit Mozambique using this formula. xc: I think maybe we should lower the tone in the conclusions, but the objective was not to propose joining the SACU. It was only to acknowledge that with the methodology used SACU implies larger welfare than SADC because of revenue transfer. Also, we acknowledge that SACU is also full of problems and difficulties, and more important that domestic reform is crucial. In addition, my technical comments raise several questions about the calculations, especially the net national welfare effect, and the sensitivity of the findings to variations in key parameter assumptions. After reading the paper, I conclude that moving ahead with discussions on joining SACU is warranted. But this conclusion is driven by impacts that are outside the static partial equilibrium model, such as unhindered trade with the dominant regional economy in South Africa, the likely impact on investment, and simpler rules of origin. The revenue effect is a possible bonus for entering SACU, but it should not be regarded as a motive. This is because the estimates are soft, and the revenue sharing arrangement is likely to change anyway if Mozambique were to be admitted. xc: Agree, but the paper was an attempt to provide a framework for discussion However, the potential negative effects of SACU membership must be kept clearly in mind. These include the loss of control over tariff and excise policies; accession to a more complex tariff structure; and exposure to trade policy decisions made by South 9 Africa in response to domestic political pressures. xc: I think we try to mention these problems in the paper The policy decision therefore involves judgments on the trade off between benefits and costs. The answer cannot be determined by technical analysis alone. -----------------Bruce Bolnick Nathan Associates October 23, 2006 xc: we would like to thank you for your extensive and thorough comments. Just to add that that the idea is to work on improving the estimates with a methodology that uses the CES function at HS-6 and do some more sensitivity analysis. We hope that this can provide valuable information for decision making in trade policy, and it can also provide more robustness at the results of this paper. In addition, just to add that we will be replace the version on the web with an updated version that includes some of the comments here. 10