On 05 June 2026, the International Trade Administration Commission of South Africa (ITAC) announced the initiation of an investigation for remedial action in the form of a safeguard measure against the increased imports of A3 and A4 office paper, classifiable under tariff headings 4802.56.20 and 4802.56.90, on which comment is due by 25 Jun 2026.
The safeguard investigation relates to the increased imports of other paper and paperboard, not containing fibres obtained by a mechanical or chemi-mechanical process or of which not more than 10% by mass of the total fibre content consists of such fibres, of a mass of 40 g/m² or more but not more than 150 g/m², in rectangular (including square) sheets with one side measuring 420 mm and the other side measuring 297 mm in the unfolded state, classifiable in tariff subheading 4802.56.20 and other paper and paperboard, not containing fibres obtained by a mechanical or chemi-mechanical process or of which not more than 10% by mass of the total fibre content consists of such fibres, other, of a mass of 40 g/m² or more but not more than exceeding 150 g/m², in rectangular (including square) sheets with one side measuring 297 mm and the other side measuring 210 mm in the unfolded state.
Based on the information submitted, ITAC decided that Mondi South Africa (Pty) Ltd has prima facie established that the events cited constitute unforeseen developments. These developments, together with the effects of obligations incurred under the General Agreement on Tariffs and Trade 1994 (GATT 1994), led to an increase in the volume of imports, both in absolute and relative terms. The surge in import volume is recent, sharp, significant and sudden enough. The Southern African Customs Union (SACU) industry is experiencing serious injury, and this is causally linked to the surge in imports.
The application, brought by Mondi South Africa (Pty) Ltd, the major producer of the subject product in SACU, was supported by Sappi Southern Africa Limited, the other manufacturer of the subject product.
A non-confidential version of the application is available for inspection at ITAC’s offices.
Unforeseen developments
Mondi submitted the following information to support its allegation of unforeseen development:
- The global structural decline in uncoated fine paper (UFP) demand beginning in 2007 and driven by digitisation and accelerated by Covid-19, constitutes an unforeseen development within the meaning of Article XIX of the GATT 1994;
- The resulting persistent global overcapacity has redirected surplus production into open markets, including South Africa;
- South Africa’s tariff bindings and market-access commitments under the WTO framework have had the effect of enabling increased imports under conditions of heightened competitive pressure; and
- The increased imports of cut sheets are therefore the result of both unforeseen developments and the effect of the obligations incurred.
Mondi also highlighted the effects of South Africa’s commitments under WTO agreements as follows:
- Bound its tariffs on printing and writing paper products at reduced ceiling levels of 20%;
- Rationalised and reduced tariff protection; and
- Eliminated quantitative import restrictions.
These commitments materially limited South Africa’s ability to adjust tariffs in response to unforeseen import surges. The binding of tariffs at relatively low levels has had the following effect:
- Increasing market accessibility for foreign producers;
- Limiting the use of ordinary tariffs and tariff increases to counter destabilising import volumes; and
- Exposing the domestic industry to increased global surplus capacity.
Moreover, Mondi noted that in 1994 imports accounted for a minor share of the South African cut-sheet market and consisted largely of speciality grades not produced domestically.
ITAC decided that ITAC submitted prima facie information indicating that the events cited by Mondi are regarded as unforeseen developments, and that, together with the effects of the obligations incurred under GATT 1994, they led to the alleged surge of imports of the subject product, in accordance with the provisions of Article XIX of GATT 1994.
Allegation of serious injury and causal link
The period of investigation for data evaluation for the purposes of determining the allegation of serious injury is from 01 January 2023 to 31 December 2025. Furthermore, this application contains information on increased import volumes and the serious injuries associated with them during the surge period, from 01 January 2023 to 31 December 2024.
The injury analysis is based on information submitted by Mondi, the major producer of the subject product in the SACU.
Mondi alleged and submitted prima facie evidence indicating that it was experiencing serious injury in the form of a decline in sales, net profit, output, market share and employment, during the period of surge from 01 January 2023 to 31 December 2024.
Furthermore, an analysis of the period under investigation from 01 January 2023 to 31 December 2025 indicates that Mondi has experienced serious injury, as reflected in declines in sales, output, net profit, market share, capacity utilisation and employment.
On this basis, ITAC found that prima facie evidence had been submitted to indicate that the SACU industry was experiencing serious injury that could be causally linked to the recent, sudden, serious and significant surge in imports of the subject products."
This investigation will be conducted in accordance with the International Trade Administration Act, 2002 (ITA Act) and the International Trade Administration Commission Safeguard Regulations (SGR), read with the World Trade Organization (WTO) Agreement on Safeguards (the Safeguard Agreement).
Please note that if any information is considered confidential, a non-confidential version of that information must be submitted to the public file at the same time as the confidential version. In submitting a non-confidential version, the following rules are strictly applicable, and parties must indicate:
- Where confidential information has been omitted and the nature of such information;
- Reasons for such confidentiality;
- A summary of the confidential information which permits a reasonable understanding of the substance of the confidential information; and
- In exceptional cases, where information is not susceptible to summary, reasons must be submitted to this effect.
This rule applies to all parties and to all correspondence with and submissions to ITAC, which, unless indicated to be confidential and filed together with a non-confidential version, will be placed in the public file and made available to other interested parties.
Failure to do so promptly will seriously hamper the proper administration of the investigation. Such party will not be able to subsequently claim an inability to make meaningful representations on the basis of the failure of such other party to meet the requirements.
Subsection 33(1) of the ITA Act provides that any person claiming confidentiality of information should identify whether such information is confidential by nature or is otherwise confidential, and any such claims must be supported by a written statement, in each case, setting out how the information satisfies the requirements of the claim to confidentiality. In the alternative, a sworn statement should be made, setting out reasons why it is impossible to comply with these requirements.
Procedures and time limits
All information submitted, including non-confidential copies thereof, should be received by ITAC by no later than 20 days from the date hereof. Late submissions will not be accepted.
Any interested party may request an oral hearing, provided that reasons are given for not relying on written submissions only. No request for an oral hearing will be considered more than 60 days from the date of this publication. ITAC may refuse an oral hearing if granting it will unduly delay the finalisation of the investigation.
Interested parties requesting an oral hearing shall provide ITAC with a detailed agenda for, and a detailed version, including a non-confidential version, of the information to be discussed at the oral hearing at the time of the request.