Radiation Sources and TAEC Authorisation: The Approval Traders Miss

This page is the radiation source import operating file: which devices and materials the Commission must authorise before shipment, and how the practice licence, the permit and the customs release fit together. It is not a dose-limit manual.

• Licence classes behind the metals: copper and nickel
• Concentrate in a container: Dodoma processing
• Assay kit on a trading floor: gold doré sourcing
• The inspection after the certificate: environmental audits

As at 14 September 2026. Confirm forms, source categories and charges with the Commission on taec.go.tz; this file rests on Act No. 7 of 2003 and the regulations under its section 70.

What the Act calls a source

Act No. 7 of 2003 created the Tanzania Atomic Energy Commission and gave it the authorisation mandate. The statutory wording is wide, reaching any apparatus, device or material able to emit radiation: a machine that makes radiation only while switched on is caught as squarely as a sealed caesium-137 capsule. Section 17 puts the duty on the person, not the cargo. The head office sits at Njiro in Arusha, deciding files while the container waits in Dar es Salaam. What arrives without paper is rarely exotic:

• Handheld XRF analysers used by gold buyers, scrap yards and exploration crews: an X-ray tube in a pistol grip.
• Nuclear density gauges on road contracts: caesium-137 with an americium-241 beryllium neutron source.
• Baggage and cargo scanners for hotels, malls, banks and mine gates.
• Dental, veterinary and mobile C-arm units inside a clinic fit-out order.
• Ionisation smoke detectors holding americium-241, and thoriated tungsten electrodes by the carton.

Practice licence, consignment permit and the people layer

Three authorisations get collapsed into one word. The first attaches to a person and a premises for a defined practice: sections 17 to 20 separate a licence from a registration, with a certificate issued under section 20(4). The second is permission for a specific shipment, assessed against a serial number and an activity. The third covers people: a radiation protection officer, named and qualified, and workers in dosimetry whose badges are read against the worker record, not the machine.

Authorisations are site-specific: moving a gauge between quarries is a variation applied for beforehand. The Commission applies the IAEA categorisation of sealed sources, Category 1 down to Category 5, and the category drives the security arrangement, the packaging and, at the top of the scale, whether two regulators exchange consents before the source leaves its origin country.

Which item meets which desk

Customs release, electronic lodgement and Zanzibar

The authorisation is a condition of release, not a formality after it. Permits from agencies other than the revenue authority are lodged electronically and matched to the customs declaration, so cargo carrying no Commission reference against its bill of lading does not clear. Dar es Salaam port, Julius Nyerere and Kilimanjaro airports and the main road borders carry detection equipment at the gate; an alarm on an undeclared container is a worse start.

The mandate runs nationally; the clearing desk does not. Mainland cargo clears through the Tanzania Revenue Authority under the East African Community Customs Management Act, 2004, island cargo through the Zanzibar Revenue Authority. Imaging equipment meets the Tanzania Medicines and Medical Devices Authority under Cap. 219 on the mainland and the Zanzibar Food and Drugs Agency on the islands; neither registration substitutes for the radiation file. Import VAT at 18% under the Value Added Tax Act, Cap. 148 and duty at the applicable East African Common External Tariff band are separate again. Confirm the live schedule on tra.go.tz.

The order the desks actually take

1. Classify before the proforma is signed. Ask for the radionuclide, activity in becquerels and date of assay, or, for a machine, tube voltage and current.
2. Authorise the practice, not only the box. An import is authorised into a licensed or registered practice; a company holding neither applies for both, and that file is longer.
3. Appoint the radiation protection officer and list the workers who will carry dosimeters, while the equipment is still at the factory.
4. Apply for the consignment permit before the supplier ships, with the source or type certificate attached.
5. Collect the export-side paper. The exporting state’s authorisation, and for higher categories the consent exchange between regulators, is the supplier’s obligation and your delay.
6. Put the permit reference on the declaration before the vessel berths, and tell the clearing agent in writing that the cargo is licensed apparatus or Class 7.
7. Take the two inspections in order: the package on arrival, then the room, shielding and interlocks.
8. Diary the source out on the day it arrives. Record serial, activity, decay date and exit route.

What the file must contain

For radioactive material: the manufacturer’s certificate giving radionuclide, activity, serial number, date of assay and capsule classification; a leak-test result; the special-form certificate where the packaging relies on it; the Class 7 dangerous goods declaration with package type and transport index; and an emergency arrangement matched to the category, plus a security plan where the category demands one.

For a generating device: the model specification with tube rating, shielding drawings showing lead equivalence and room occupancy, and the commissioning protocol. Both routes need the exporting regulator’s approval, an end-user statement naming the practice and the site, a written undertaking on return or disposal, the protection officer’s appointment, the dosimetry worker list and the commercial set. Second-hand buys fail here most often: an auction gauge with no certificate cannot be assessed.

Illustrative arithmetic: three gauges held at the port

A roads contractor orders three nuclear density gauges and tells the forwarder to sort the permits on arrival. Illustrative arithmetic, not a quotation:

• Landed value of the three gauges: TZS 96,000,000.
• Container held 34 days while the practice authorisation and the permit are opened from nothing.
• Storage and demurrage at TZS 310,000 a day: 34 × 310,000 = TZS 10,540,000.
• Crew and roller idle 21 working days at TZS 1,450,000 a day: 21 × 1,450,000 = TZS 30,450,000.
• Avoidable cost TZS 40,990,000: roughly 43% of what the equipment itself cost.

None of it buys a faster assessment. Demurrage is not a ground of urgency the Commission recognises.

Minerals carry their own radiation question

Tantalum and niobium concentrates, monazite and zircon sands, tin slag and rare-earth intermediates all carry naturally occurring radioactive material. Past the exemption level the parcel is radioactive material whatever the invoice calls it, and a portal alarm turns a routine export into a characterisation exercise with the box already loaded. A radiological report (nuclide, activity concentration, dose rate at the package surface) costs less before loading.

Uranium is a separate file. The Mining Act, Cap. 123 treats radioactive minerals as their own class, so the mineral right sits with the Mining Commission while handling, storage, transport and export sit with Arusha; Mkuju River in Namtumbo shows how long the two run in parallel. Ordinary metallic exports meet the mineral market, the 6% royalty and the 1% clearing fee under that Act.

The penalties are floors, not ceilings

The Act sets minimum sentences rather than caps. Section 72(1) carries a fine of not less than TZS 5,000,000 or imprisonment of not less than five years. Section 11(2) carries not less than TZS 3,000,000 or three years, and section 12(3) not less than TZS 500,000 or six months. Which provision is charged depends on the offence, and the Act has been amended since enactment, so read the live section before quoting it at a supplier.

The fine is seldom the expensive part. Detained cargo, a suspended authorisation on a mobilised site, and an insurer asking why an unlicensed source stood on the premises all cost more.

Where this file stalls

• The item is declared as a measuring instrument, so nobody in the chain flags it and the portal monitor does the flagging instead.
• A permit exists but no practice authorisation, so the gauge is lawfully imported into a store not authorised to hold it.
• No protection officer and no dosimetry, and the installation fails its first inspection with the contract running.
• The quotation omits the certificate and the return undertaking, and the buyer learns both are missing during assessment.
• A group assumes the parent’s authorisation reaches its Tanzanian subsidiary. It does not: the licence names a person and a place.

Disposal is decided at purchase, not at end of life

A sealed source decays but never stops being regulated: a caesium-137 gauge stays a licensed item long after it is too weak to work. Write repatriation into the supply contract, name who packages and ships it, and provision the cost now, not a decade later when the manufacturer has been acquired twice. Where return is impossible the route is a funded transfer to the Commission. Orphans surface three ways here: a plant sold without its inventory, a contractor who left between jobs, a scrap yard that bought the shielding for its lead.

Mandate-holders this file does not replace

The Commission authorises the source, the practice, the premises and the transport. TRA releases mainland cargo and ZRA island cargo. TMDA and ZFDA register the device on their respective sides. The Mining Commission licenses the mineral right and runs the mineral market. NEMC owns impact assessment and audit under the Environmental Management Act, Cap. 191. OSHA registers the workplace under the Occupational Health and Safety Act, Cap. 297. The Government Chemist Laboratory Authority controls industrial and consumer chemicals under Cap. 182, a regime often confused with this one. Zatra prepares, structures and coordinates; it issues no approvals and certifies no radiation safety.

What to confirm before you act

• The nuclide, activity and assay date, or the tube rating, in writing before any deposit.
• Whether the company already holds an authorisation covering the intended use at the intended site.
• Current forms, categories and charges from the Commission’s own portal, not a forwarder’s memory.
• The exporting regulator’s own approval, plus any regulator-to-regulator consent the category triggers.
• The declaration reference the permit will be matched against, and who lodges it.
• The written exit route for the source, and which party carries that cost.
• Whether the destination is mainland or Zanzibar, because two desks change with it.