In its bid to stop anti-competitive coordination, CUTS International has pointed to Ghana’s domestic aviation industry as a perfect example of how competing businesses should independently handle cost pressures without forming cartels.
When faced with rising operational costs, such as fuel price hikes, airlines also frequently apply surcharges. Crucially, however, each airline calculates and applies these surcharges independently.
CUTS contrasts this with the cement industry’s recent move, arguing that business associations must never be used as a front for price coordination that stifles competition.
How Airlines Do It
To illustrate how a healthy competitive market handles industry-wide cost pressures, CUTS analyzed fare and surcharge data for the Accra-Kumasi airline route as of September 15, 2026. The analysis revealed a stark contrast in fuel surcharges:
Africa World Airlines (AWA): Applied a fuel surcharge of GH¢220.
PassionAir: Applied a fuel surcharge of GH¢75.
This vast difference, CUTS International says, is economically rational. The two airlines operate different fleets with highly distinct operating economics. Africa World Airlines operates jet aircraft, which have different fuel consumption rates, while PassionAir utilizes turboprop aircraft. They also have different commercial strategies and fleet structures.
Even though both airlines face the exact same broad fuel cost pressures, they independently determine their respective surcharges. CUTS notes that if these competing airlines met in an emergency meeting and agreed on an identical fuel surcharge for all passengers, it would spark immediate cartel investigations.
The exact same principle applies to cement. A common industry challenge does not justify a uniform, industry-wide price.
Trade Associations: Advocacy vs. Anti-Competitive Coordination
CUTS acknowledges that trade groups like the Chamber of Cement Manufacturers, Ghana (COCMAG) have a legitimate and vital role to play. It is entirely appropriate for COCMAG to collectively lobby the government, the Ghana Ports and Harbours Authority (GPHA), and other public bodies over shared issues like port congestion and vessel delays.
However, there is a clear legal and economic boundary between legitimate industry advocacy and the coordination of commercial pricing. An association crosses this boundary the moment its members begin discussing, recommending, or agreeing on specific prices or surcharges.
In response, CUTS has formally called on COCMAG to clarify two key points:
Is the GH¢12 surcharge a mandatory collective decision or a recommendation?
Are individual cement manufacturers entirely free to charge less, charge more, or apply no surcharge at all?
Furthermore, CUTS has warned the chamber against using its proposed “monthly monitoring” and “January 2027 review” as backchannels to exchange sensitive, non-public commercial data, such as future pricing plans, production volumes, individual operating costs, clinker stocks, or shipping schedules.
