This later tea-only update extended the reporting window to August 2025 and put financing at $35.5 million. It complements, but overlaps, the earlier four-month coffee-and-tea basket and must not be added to it.

USD 35.5m

Tea-related credits cited for January–August 2025

Eight months of tea financing—not a second total

Tea-related financing reached a reported $35.5 million in January–August 2025. The figure is a cumulative update to the earlier four-month coffee-and-tea analysis, not an additional amount, and it provides a test of demand, pricing and the composition of consumer imports.

The eight-month total averages about $4.4 million a month, but seasonality makes that descriptive rather than predictive. The original model assigned 20% to non-Libyan residents and 10% to re-export or smuggling, then said 60% remained. Those assumptions actually leave 70%: $24.85 million, not $21.3 million. The consumption model must therefore be corrected before its 5.4-million-kilogram conclusion is used.

The unit-value test behind the $35.5 million

The bank ledger adds a genuine concentration question: Andalus was assigned 20% and Nuran 19.6%, or 39.6% together. The ten largest companies were estimated above 60%. Tea is still a normal mass-consumption import, so concentration calls for a competition and exposure test—not a presumption that the product or transactions were illegitimate.

Consumption, stocks and re-export

The proposed family grouping placed roughly 62% with ten networks, but names and apparent kinship do not establish beneficial ownership or common control. The table also cannot prove how much tea reached shelves, and the earlier four-month total overlaps this period and must never be added to it.

The records needed to test the tea bill

Competition authorities and bank supervisors should focus on market concentration, related suppliers and abnormal unit values rather than judging the legitimacy of the product. Industrial policy can separately test whether local packing adds value without pretending Libya can replace imported tea leaves.

Publish value and weight by tea code, origin, supplier country, importer, bank and execution status, with amendments and cancellations. Retail-price monitoring would then allow landed cost and consumer price movements to be compared over the same months.

The concentration map needs ownership evidence

The company shares cited—9.4% for Wafira Al-Ghithaa, 8.4% for Al-Jaid, 7% for Gulf Al-Zahir and roughly 5%–6% for several others—can be reproduced from the financing file. Grouping them into family networks is a second analytical step and needs registry documents, shareholders, directors and authorised signatories.

The retail-margin comparison also needs like-for-like products. A landed estimate of LYD 29–31 per kilogram and retail observations of LYD 30–40 can imply anything from a very small to a sizable margin before wholesale, packaging, transport, tax and loss. A price panel by brand, grade and month would be more defensible than one range.

Editorial method: This investigation rebuilds the original calculation from the linked public records, preserves the source period and transaction stage, and separates documented figures from estimates, interpretation and allegations.

Mohamed Algarj