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Implementation Completion Report (ICR) Review - Cambodia Trade Facilitation And Competitiveness

1. Project Data:   
ICR Review Date Posted:
Project Name:
Cambodia Trade Facilitation And Competitiveness
Project Costs(US $M)
 10.33  n.a.
L/C Number:
Loan/Credit (US $M)
 10.00  9.85
Sector Board:
Cofinancing (US $M)
 0  0
Board Approval Date
Closing Date
12/01/2009 07/31/2012
Other domestic and international trade (80%), General public administration sector (20%)
Trade facilitation and market access (29% - P) Export development and competitiveness (29% - P) Technology diffusion (14% - S) Infrastructure services for private sector development (14% - S) Other public sector governance (14% - S)
Prepared by: Reviewed by: ICR Review Coordinator: Group:
Brian Ames
Rene I. Vandendries Ismail Arslan IEGPS2

2. Project Objectives and Components:

a. Objectives:

    The objective of the Cambodia Trade Facilitation and Competitiveness Project (CTFCP) is "to support the Recipient’s strategy to promote economic growth by reducing transaction costs associated with trade and investment, introducing transparency in investment processes, and facilitating access of enterprises to export markets". (Development Grant Agreement, Schedule 2, pg. 14 and Project Appraisal Document, Page 8).

b. Were the project objectives/key associated outcome targets revised during implementation?

If yes, did the Board approve the revised objectives/key associated outcome targets? No

Date of Board Approval:

c. Components:

The CTFCP consisted of four main components:

Component 1. Trade Facilitation Component (cost estimated at appraisal : US$6.15 million). This component consisted of a set of Information Technology measures that were to be applied to border management activities with a view to streamlining operations, improving transparency and accountability, and facilitating the achievement of all border-related government objectives. The project financed (a) an electronic Single Window integrating all trade facilitation agencies, including the deployment of Information and Communications Technology (ICT) for the automation of customs functions, linked to complementary improvements in systems, procedures and developments in the organizations involved in product clearance; (b) adherence to the Kyoto Convention, including the adoption of a risk management capacity; (c) design of a merit-based pay system for Cambodia’s trade regulatory agencies; and (d) development of an Integrity Action Plan for the Customs and Excise Department based on a self-assessment.

Component 2. Export Market Access Fund (cost estimated at appraisal: US$2.1 million). This component financed (a) technical support to the Ministry of Commerce’s Department of Export Promotion to establish the exporter technical assistance window; and (b) a technical assistance matching grant facility that covered 50 percent of the cost of achieving market standards or evidence of compliance with those standards. The Fund offered its services solely in response to private sector demand on a nondiscriminatory and a first-come-first served basis.

Component 3. Private Participation in Infrastructure and Investment Component (cost estimated at appraisal: US$0.8 million). This component financed a program of capacity building to implement the Law on Concessions and the Amended Law on Investment. The investment promotion sub-component supported the Council for Development of Cambodia (CDC) and the Cambodia Investment Board (CIB) in adopting strategies that streamlined the process of foreign direct investment and that enhanced the attractiveness of Cambodia as an investment destination through improvements in the regulatory environment as well as in factor markets. The program consisted of three distinct activities: (a) appointment of a local long-term resident advisor; (b) a series of 5-day training workshops for 15-20 CIB staff on subjects such as investment generation and facilitation; and (c) installation of an IT system.

Component 4. Legal Transparency Component (cost estimated at appraisal: US$0.4 million).This component was intended to finance (a) the establishment and maintenance of a website in the Khmer language to make readily available to the public the final judgments of all cases in the Supreme Court and in the Court of Appeals; (b) the establishment and maintenance of a website to ensure the electronic publication of all Cambodian laws, related regulations, and draft legislation in the commercial law field, broadly defined; and (c) training to utilize the established systems.

Replenishment of the Project Preparation Facility and project coordination added another US$0.88 million to the total cost at appraisal.

d. Comments on Project Cost, Financing, Borrower Contribution, and Dates

The CTFCP was a Specific Investment Loan (SIL) financed by an IDA grant in the amount of US$10.0 million and a government counterpart contribution equivalent to US$0.33 million. It was appraised in April, 2005; approved by the Bank Board on June 2, 2005; became effective on December 12, 2005; had a mid-term review in May 2008 (one year later than planned at appraisal); was restructured on May 2, 2008, August 26, 2008, and December 3, 2009; and was closed on July 31, 2012 (32 months after the expected closing date at appraisal).

3. Relevance of Objectives & Design:

a. Relevance of Objectives:

The PDO of the CTFCP is consistent with both the government’s and the Bank’s current strategies for the country. Following the 2004 World Bank Investment Climate Assessment, the Government of Cambodia committed to improving the investment climate and to facilitating trade through the formulation of a 12-point action plan. The CTFCP was designed to help the Government implement several of these 12 actions drawing on the Bank’s successful experience in trade facilitation projects focusing on customs reform, modernization, and computerization in other countries. The project also is in line with the government’s National Strategic Development Plan, which aims to improve the competitiveness of labor-intensive industries and their exports, build a more conducive private sector investment climate, and facilitate trade through simplification of the trading and investment processes, greater transparency and better governance, and increased investor confidence. The project is fully consistent with the Bank’s Country Assistance Strategy (CAS) for Cambodia, which was prepared jointly with the ADB, DFID and the UN system, as well as with the East Asia Regional Strategy, whose focus is on supporting shared and sustainable growth. CAS Objective 1 aims to promote broad-based sustainable economic growth of 6-7% with equity, with the private sector playing the leading role by enabling higher levels of investment, including foreign direct investment, to connect Cambodian firms to international markets and increased private investment in infrastructure. The relevance of objectives rating is high.

b. Relevance of Design:

The design of the CTFCP was consistent with its objectives. It benefited from the identification of weaknesses in the functioning of export markets in the 2004 Investment Climate Assessment and from the government’s creation of a consultation mechanism aimed at building trust between the public and private sectors and a consensus for the country’s national poverty reduction strategy. ‘The project’s original design, however, stretched the government’s limited implementation capacity, particularly regarding the IT components. The proposed electronic Single Window was based on the Singapore model and proved to be too broad and complex for a country at Cambodia’s stage of institutional development to implement. Also, the trade information website and the automation of certificates of origin (C/Os) never materialized due to procurement delays. The project faced repeated procurement challenges including the shortage of qualified firms and suppliers due to the complex and specialized nature of the consulting services and goods required for the project. Following the mid-term review, the government requested a detailed review of the Automated System for Customs Data (ASYCUDA) implementation and the conclusions and lessons learned from the evaluation were subsequently incorporated into the design of the restructured project.

The project’s Results Framework provided a clear statement of the objectives and causal link to the expected intermediate and final outcomes. The intermediate performance indicators were directly relevant to each of the components and were clear and measurable. Moreover, the Results Framework was revised after the mid-term review with a view to strengthening the project’s performance. Three additional indicators were added to the trade facilitation component that focused on the heightened emphasis being placed on ASYCUDA and C/Os, one new indicator was added to the export market access fund component to focus on non-donor funding for Better Factories Cambodia (BFC) operations, and one new indicator was added to the legal transparency component to focus on trade information website compliance with World Trade Organization obligations. Finally, neither the PAD nor the ICR identified any unintended (positive or negative) effects, but none were likely to occur. The relevance of design is rated substantial.

4. Achievement of Objectives (Efficacy) :

The ICR reviewed progress of the 2 PDO outcome indicators, as well as of the 13 intermediate outcome indicators, identified in the Results Framework. The assessment below is conducted on the basis of the restructured project through the extended closure date.

Overarching objective: Promote economic growth

The project’s contribution to the promotion of economic growth can be measured indirectly through higher GDP growth and improvements in investor’s perception of doing business in Cambodia. Economic growth averaged 7.9% per annum over the project life versus less than 4 percent in the years immediately preceding the project. However, it is impossible to identify the precise contribution of the project to economic growth given the variety of other domestic and international factors that affected growth during this period. There was however a noticeable, measurable improvement in investor’s confidence during this period as both the number of firms reporting corruption as a moderate, major or severe problem (original indicator) exceeded the target of a 10 percentage point decline between 2004 and 2012, and the share of traders considering customs and trade as a severe or very severe constraint (a more focused indicator added during the project’s restructuring) exceeded the target of 15% or lower of traders.

Intermediate Objective 1: Reducing transaction costs associated with trade and investment

Before the project, customs clearance at the country’s biggest seaport involved multiple steps, documents, and time waiting that resulted in reduced opportunities for trade and growth. At the end of the project, all processes have been centralized into a single electronic document covering nearly 100 percent of customs declaration clearances. Although the automation of C/Os was not fully achieved under the project due to procurement problems, the procedures were substantially simplified and streamlined and this component is expected to be implemented under the separate Trade Development Support Program (TDSP) multi-donor trade facility that is managed by the Bank. Moreover, the subsequent adoption and good progress in implementing the ASYCUDA World system (in place of the initially proposed Single Window) contributed to the ultimate achievement of this objective. Regarding the targets of the three original intermediate indicators and the three new indicators added during the project’s restructuring, two were fully achieved, two were partially achieved and two were not achieved. The target for automation of C/O issuance was not achieved due to the failed procurement process and the target for a reduction in the time to clear imports was not achieved, although export processing times improved substantially after the implementation of ASYCUDA.

Efficacy in achieving the first intermediate objective is rated substantial.

Intermediate Objective 2: Facilitating access of enterprises to export markets

The Export Market Access Fund (EMAF) matching grant facility was the main component which encouraged small firms to become exporters through the provision of technical assistance and matching grants to promote products overseas. According to the ICR, the EMAF was successful in opening new markets and encouraging new exporters, with the return on matching grants higher in some sectors versus others. It also points to the ILO’s BFC initiative as resulting in a rapid increase in exports as a result of the reassurances given to large foreign buyers as to the social responsibility of Cambodian factories. Over the project period, garment exports increased from US$2 billion (2004) to US$4.6 billion (2012). Success as measured by achievement of the targets for the three intermediate indicators for this component was broadly positive. Although the number of new exporters created fell way below the target, the number of firms preparing export development plans and the share of non-donor revenues of the Better Factories Cambodia (BFC) exceeded the targets.

Efficacy in achieving the second intermediate objective is rated substantial.

Intermediate Objective 3: Introducing transparency in investment processes

This component of the project was not successfully implemented. Although the new Concessions Law was adopted by parliament and the relevant officials were trained, zero Private Participation in Infrastructure (PPI) transactions have been piloted under the new law. Part of the reason for this, however, was the onset of global financial crisis in 2009 which undermined foreign direct investment in all emerging markets. In addition, the roll out of the Investment Tracking system to the Council for the Development of Cambodia’s departments was limited to a single department. Neither of the two intermediate indicators regarding the number of PPI contracts piloted under the new law nor the ranking of Cambodia in the IFC’s Global Investment Promotion Benchmarking was achieved.

Efficacy in achieving the third intermediate objectives is rated negligible.

Intermediate Objective 4: Improving legal transparency

This component of the project was also not successfully implemented. Although the websites for the Ministry of Justice and the Supreme Court were set up and training sessions were successfully conducted, both the volume and the content of information available of those websites fell way short of expectations. No cases after 1997 have been made publicly available and the total number of cases processed by the courts is unknown. Despite the public release of updated hearing schedules and improvements in the Ministry of Justice’s web site, the volume of information fell short of the target of covering 50% of the judgments. Moreover, the Trade Information Website (TIW), which was added during the 2009 restructuring of the project, was not established by the closing date, although it is expected to be completed under the Bank-managed Trade Development Support Project (TDSP).

Efficacy in achieving the fourth intermediate objective is rated negligible.

5. Efficiency:

The ICR argued that the nature of the project’s components made it hard to calculate a net present value or an economic return and noted the difficulty of defining a plausible counter-factual. It did, however, make reference to the PAD providing such an economic/financial analysis based on the project simplifying the import process. The PAD also maintained that many of the project’s benefits regarding improved investor confidence cannot be readily quantified, and justified the project based on an economic analysis of the expected reduction of time to clear imports (50%) whose cost-benefit stream was projected with an ERR of 216%. The PAD also estimated an incremental increase in the taxes on imports arising from the project, which resulted in an IRR of 144%. Given that imports clearance time did not decrease during the project period, the project’s ERRs and IRRs based on this methodology was zero or negative. The ICR notes that the import clearance time was not reduced since the project’s restructuring, but suggests that the economic and financial returns were still very high given that the automation of customs procedures makes compliance higher, that the EMAF did support firms in preparing draft export plans, and that the EMAF has helped Cambodia industry gain access to the US and European markets. It does not, however, attempt to quantify the project’s ERR or IRR, although it does note that an exercise could have been conducted to determine whether the value of incremental exports relative to the cost of managing the program could have been achieved more efficiently by relying more on the Ministry of Commerce staff rather than on the international consulting firm. In addition, the long delays experienced in project implementation also reduced efficiency. Efficiency in achieving the project’s objectives is therefore rated modest.

a. If available, enter the Economic Rate of Return (ERR)/Financial Rate of Return at appraisal and the re-estimated value at evaluation:

Rate Available?
Point Value
ICR estimate:

* Refers to percent of total project cost for which ERR/FRR was calculated

6. Outcome:

The “moderately satisfactory” rating reflects the combined ratings for relevance, efficacy, and efficiency. The CTFCP was consistent with both the government's and the Bank's current strategies for the country and the project design was consistent with its PDO, although it stretched the government's limited implementation capacity, particularly regarding the IT components. Efficacy in achieving the PDO and the first two of the four intermediate objectives was substantial, while efficacy for the two intermediate objectives regarding transparency in investment processes and in the legal system was negligible. However, the efficacy of the first two intermediate objectives has a much higher weight relative to the remaining two objectives regarding the overall outcome rating given the significantly larger amounts of monies involved. Efficiency was modest, as import clearance time did not decrease during the project period, although customs compliance was higher, support was provided to firms in preparing draft export plans, and local industry was able to increase access to the US and European markets during the project period.

a. Outcome Rating: Moderately Satisfactory

7. Rationale for Risk to Development Outcome Rating:

The risk to sustaining the reforms supported by the CTFCP and to achieving the intended development outcome is significant. The current automation system involves high costs (outsourcing work to local ICT consultants, software maintenance, upgrades, etc.). As the components and the objectives regarding private participation in infrastructure and investment and with regard to legal transparency were never fully implemented or achieved, this will require redoubled efforts on the part of the authorities if these measures are to be brought into fruition and have the desired results. Also, there remains concern on the part of the private sector regarding the governance and transparency in key parts of the government despite the perception of improvements in corruption in recent investment climate surveys. The key mitigating factor will be the demonstration of strong political will and commitment on the part of the government to continue to pursue its governance and customs modernization reform effort, and there are signs that such will exists. A second mitigating factor will be support provided by the Bank-managed TDSP, which is picking up where the project left off and should help to maintain, update, and sustain the new ASYCUDA system. Finally, the creation of the Government-Private Sector Forum, the Customs-Private Sector Partnership Mechanism, and the various Technical Working Groups should continue to help remove obstacles and address outstanding issues as they arise going forward.

a. Risk to Development Outcome Rating: Significant

8. Assessment of Bank Performance:

a. Quality at entry:

The Bank’s performance regarding quality at entry was moderately unsatisfactory. The ICR rightly points out that the Bank should have recognized at the appraisal stage that the implementation of a Single Window requires high performing public institutions with strong institutional capacity. While it has been successful in advanced countries with good governance such as Japan and Singapore, it was overly ambitious to assume that it could be successfully implemented in a less developed country, such as Cambodia, with poor governance and weak institutional capacity. Moreover, the fact that necessary support from international consulting firms was not easily available along with the procurement problems and delays experienced, did not bode well for satisfactory implementation. The differences in view between the Government and the Bank on the electronic Single Window and the eventual shift away from the Single Window to the ASYCUDA system meant that precious time and scarce resources could have been more effectively deployed at the onset of the project. It is interesting to note that this same mistake was made in the design of Bank support for other countries within the region (i.e., Vietnam), reflecting perhaps overly ambitious expectations.

Quality-at-Entry Rating: Moderately Unsatisfactory

b. Quality of supervision:

The quality of supervision was satisfactory. The ICR correctly emphasizes the point that the frequency of Bank supervision missions (16 in all) was adequate and provided numerous occasions for the Bank and the government to assess progress in implementation in the context of implementation status and results reports and aide memoires. The fact that there were three restructurings (two minor ones and one major one) also indicates that the experience in implementation was being drawn upon to restructure the project and redeploy resources to priority areas to help ensure the achievement of the project’s objectives and meet the government’s needs. It is also noteworthy that the decision to base the task team leader in Cambodia in early 2008 greatly facilitated the mid-term review and the subsequent restructuring of the project. It is unfortunate that the mid-term review was delayed by one year, as it is likely that critical restructuring of the project could have taken place earlier and, in turn, results could have been even better.

Quality of Supervision Rating: Satisfactory

Overall Bank Performance Rating: Moderately Satisfactory

9. Assessment of Borrower Performance:

a. Government Performance:

The ICR indicates that the government played an active role in the design and implementation of the CTFCP and took concrete actions to ensure the involvement of all key public sector bodies and the active participation of the private sector and other stakeholders. Full cooperation was also provided regarding the regular reporting to the Bank and support to the implementation status and results missions and the ICR mission. It is unclear as to why, given the differences of view between the government and the Bank on the modalities for the Single Window that the Cambodian authorities did not play a more active role at the onset in ensuring that the design of the project was in line with the public sector’s institutional capacity.

Government Performance Rating: Moderately Satisfactory

b. Implementing Agency Performance:

The performance of the government agencies involved in project implementation was mixed. The Customs Department and the Ministry of Commerce appear to have performed well regarding the implementation of the EMAF component, and the Ministry of Economy and Finance was actively engaged in addressing problems as they arose. In contrast, the Ministry of Justice and the Supreme Court failed to establish their websites and provide content in a timely manner. This was due mainly to a lack of political will, rather than institutional capacity constraints. Similarly, the CDC failed to introduce the PPI pilot activity and to roll out the ITS, which appears to be principally due to weak commitment on the part of the client. On balance, the performance of the implementing agencies was rated moderately unsatisfactory.

Implementing Agency Performance Rating: Moderately Unsatisfactory

Overall Borrower Performance Rating: Moderately Satisfactory

10. M&E Design, Implementation, & Utilization:

a. M&E Design:

The project’s objectives were clearly specified and it’s PDO and intermediate indicators were well defined and measurable with baselines and targets. The ICR provided a detailed review of how M&E was designed to capture key information about each of the project’s components. The trade facilitation indicators reflected progress toward the achievement of this component, with data taken from available Bank products, such as the Investment Climate Assessments and the Doing Business Report. Although the outcome indicators for the export market access fund component were broadly appropriate, the link between corporate responsibility, higher investment, and enhanced exports, as well as the gender dimension, was not adequately captured in the results indicators. Similarly, the ICR argues that the indicator in the private participation in infrastructure and investment component regarding the Global Investment Promotion Benchmarking (GIPB) may have been poorly chosen given that the Foreign Investor Perception Survey showed an improvement in investor perception while the GIPB showed no improvement. Finally, the inability of the task team to determine the total number of judgments issued by the courts rendered the indicator on legal transparency regarding the number of decisions disclosed as a proportion of the total number of relevant judgments immeasurable.

b. M&E Implementation:

The large number of ISR missions and the mid-term review (albeit with a one-year delay) implies that M&E implementation was broadly satisfactory. Both the Bank and the government had numerous occasions to review progress in implementation and discuss the need for modifications. Following the major restructuring in 2009, the baselines for each of the DPO and intermediate indicators were re-based and the targets in many cases were re-specified to seek an even stronger performance than that envisaged at appraisal. The problems in procurement regarding the automated customs procedures and the ill-fated attempt to implement the Single Window could have been addressed earlier in project implementation.

a. M&E Utilization:

The project was able to draw upon its M&E system and learn lessons from its experience in implementation. In particular, shortly before the original closing date, the project was substantially restructured and the closing date extended by 32 months. This allowed sizeable project resources (US$3.6 million) to be reallocated away from the sub-component on the Single Window to the further extension of ASYCUDA, the automation of C/O issuances, and the creation of the TIW. It is important to note that the restructuring took into account the slower-than-expected implementation of the customs automated system and the extension of the closing date allowed the customs administration to substantially complete its roll-out. Had the mid-term review taken place as originally envisaged, the project restructuring could have occurred earlier.

M&E Quality Rating: Substantial

11. Other Issues:

a. Safeguards:

The ICR and the PAD both noted that there were no safeguard policies triggered by the project, as the project involved only the installation of ICT systems and related equipment on established sites, and technical assistance.

b. Fiduciary Compliance:

The project faced repeated procurement challenges due to the specialized nature of the consulting services and goods required. Because of this, UNCTAD was selected on a single-source basis to develop the first phase of the customs software system. Although later phases were procured competitively, certain “middleware” had to be procured from a sole supplier suing the direct contracting method. Also, the procurement to supply a system for automating issuance of C/Os elicited only a few bids, all of which were rejected as non-compliant, and re-bidding could not be completed by the project closing date. Following instances of fraud and corruption in other projects in the Bank’s portfolio, an Independent Procurement Agent (IPA) was recruited by the Government in December 2007 to carry out procurement under all Bank-financed projects in Cambodia. After a difficult start up, another firm was recruited in 2009 and coordination between the IPA and the implementing agency has improved.

c. Unintended Impacts (positive or negative):

The ICR did not mention any unintended impacts nor do there appear to be any apparent unintended impacts.

d. Other:

12. Ratings:

IEG Review
Reason for Disagreement/Comments
Moderately Satisfactory
Moderately Satisfactory
Risk to Development Outcome:
Bank Performance:
Moderately Satisfactory
Moderately Satisfactory
Borrower Performance:
Moderately Satisfactory
Moderately Satisfactory
Quality of ICR:
- When insufficient information is provided by the Bank for IEG to arrive at a clear rating, IEG will downgrade the relevant ratings as warranted beginning July 1, 2006.
- The "Reason for Disagreement/Comments" column could cross-reference other sections of the ICR Review, as appropriate.

13. Lessons:

The four main lessons learned from the implementation of the CTFCP are:

1. Ambitious customs computerization schemes should not be pursued in low-income countries with limited institutional capacity and governance concerns. Although the Single Window has been effectively implemented in more advanced countries with strong administrative services and good governance, such as Japan and Singapore, it is much more problematic in low income countries with limited institutional capacity and governance concerns, such as Cambodia. Governance and institutional capacity considerations should therefore be carefully assessed at the design stage, particularly in low-income countries.

2. Implementation risks associated with ICT projects in low-income countries are high. The project experienced procurement problems due principally to the fact that there were only a limited number of suppliers and qualified consultants in these areas willing to work in Cambodia. As a result, delays were experienced in project implementation. The availability of necessary consultancy services and the provision of key equipment should therefore be carefully assessed at the design stage.

3. Close supervision and an in-country presence increase the likelihood for good project performance. Although the mid-term review was delayed, it nonetheless provided the opportunity to restructure and extend the project in light of the problems being experienced, which increased the likelihood that the project’s PDO and intermediate objectives would be achieved, albeit with some delay. In order to increase the likelihood of success, project implementation should be reviewed early on.

4. Respecting Bank Procurement standards can be costly to the government. CTFCP Stakeholders accused the Bank of excessive rigidity in its management of procurement that resulted several times in the rejection of all bids and created delays of up to 6-12 months due to the need to rebid. While these procedures are critical to safeguarding governance, they impose important costs on the government. In terms of delays in project implementation.

14. Assessment Recommended?


15. Comments on Quality of ICR:

The ICR was comprehensive and its tone candid. It appropriately underscored the importance of government buy-in to reform programs, such as customs automation, and noted how the lack of institutional capacity and problems arising from the procurement of key goods and services can undermine implementation. The ICR provided a comprehensive assessment of the project’s objectives, components, and targets, while noting the weaknesses in its design and quality at entry and the responsiveness of the Bank to restructuring and extending the project in order to better achieve the project’s objectives. While the ICR had an extensive discussion on M&E design, it could have discussed in greater detail M&E implementation and utilization. It could have also attempted to assess quantitatively the project’s efficiency with regard to export and investment facilitation, particularly since the PAD’s analysis (IRRs/EERs) was based solely on the presumed reduction in import clearance time which never occurred. The ICR did, however, do a nice job in assessing the qualitative aspects of the project’s efficiency.

a. Quality of ICR Rating: Satisfactory

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