On 28 September the South African Revenue Service (SARS) released a letter sent to “All External Stakeholders”, titled “Enforcement of Section 64d - Bonded Goods to be in Sealed Containers”.
Various correspondence from Stakeholders dating back to August 2020 refers.
The concerns raised were that information was received from agents that as of the 01 September, all bonded goods must be imported into the Republic under sealed conditions i.e. containerised.
Whilst we do not have the benefit of the rationale that led to this decision at this time, it has been a practice to degroup containers destined for Africa and repack onto trucks, given container shortages, and not done in degrouping facilities due to capacity constraints.
The World Trade Organization (WTO) estimates that supply chain disruptions and trade restrictions caused by the pandemic have added 25% to the cost of exporting and advocates that countries must fully implement the Trade Facilitation agreement (TFA) to aid trade recovery. The World Customs Organization (WCO) in their 2020 Environmental Scan recommends that:
- Customs cannot practise business as usual during the crisis
- Customs needs a healthy private sector in order to perform and reach its annual objectives
- The crisis showed the need for exceptional facilitation measures for legitimate trade in order to keep seamless flows of goods and allow companies to run their businesses to the greatest possible extent
- A healthy and satisfied private sector is the basis for good Customs performance.
- Applying fair conditions under these circumstances guarantees a better partnership for the future and mitigates the risk of fraudulent activities.
- The environment created by this exceptional crisis has positioned Customs as one of the key actors in the provision of trade facilitation and the protection of businesses.
SARS however has investigated and would like to state that the amendment of Section 64D of the Customs and Excise Act No. 91 of 1964 does not affect the declaration process of cargo that will be transported or any importations, exportation or transit cargo.
The cargo can be either containerised, breakbulk or bulk cargo.
When cargo is declared, clients must declare their cargo and must complete mandatory fields on their declarations
The client must complete the following fields as follows and these will determine the specific requirements about the declaration, (the amendment of section 64D did not and will not influence the declaration process):
Box A2 - Transport document number
Box 5 - Remover code SAD502)
Box 25 - Transport Code
1 - Maritime
2 - Rail
3 - Road
4 - Air
5 - Mail
6 - Other
Box 26 - Removal transport code
Box 31A - Marks, numbers and description of packages
Box 31B - Number of packages
Box 31C - Container Number. (Denotes the number of ISO container conveying the goods)
Box 31B - Full / Empty Indicator. (This field must be completed if a Container Number is present)
4 = Empty,
5 = Full (FCL Groupage),
7 = Full, mixed consignment (LCL),
8 = Full, single consignment (FCL)
Box 31B - Seal Number. (This field must be completed if a Container Number is present.)
Box 35 - Gross mass
Clients need to ensure compliance with the above procedures and no other requirements or changes will be required to the current practice
Story by: Riaan de Lange