This is part of Tanzania's efforts at combating counterfeits which is, of course, welcomed. However, it will create an additional administrative burden on rights holders. It is separate from trade mark registration procedures.

Applications to the FCC will need to include additional information (that is not provided in a trade mark application):

• Place of manufacture of the goods bearing the trade mark;
• A sample of the goods or clear digital photographic representation of the goods bearing the mark;
• Details of any licensees, subsidiaries or affiliated entities authorised to use the trade mark.

Each recordation will need renewing annually.

Business that do not comply may see delays created at Tanzanian ports of entry, impacting on supply chains and overall business operations.

This is applicable to the Tanzanian mainland but not Zanzibar, which is legally distinct. Nevertheless, it's likely products imported into Zanzibar may also circulate on the mainlands too.

A similar system exists in neighbouring Kenya, although an indefinite grace period exists, effectively making the process optional (i.e. unrecorded goods can be imported).

Brand owners would be wise to look through the products they are importing into Tanzania, filing any top up trade mark applications as may be necessary, and then to ready themselves to file recordation applications with the FCC by collating together the relevant information and documents. They will then be well prepared to avoid any delays the new system could cause to them importing their goods into Tanzania. Test link.