South Africa’s move to introduce mandatory pre-export verification for certain imports from China has raised industry concerns that broad customs tariff codes could result in cargo being incorrectly flagged, detained and delayed at ports of entry.
Speaking at the Cape Port Liaison Forum (PLF), an initiative of the Cape Chamber of Commerce, customs expert Clifford Evans warned that while the intent behind the new Pre-Export Verification of Conformity (PVoC) programme was understood, the practical realities of policing it could create significant disruption.
The programme, which becomes mandatory from September following a six-month transition period, will require importers to obtain a Certificate of Conformity (CoC) before shipment to South Africa, confirming that goods meet the country’s safety and quality standards before they leave the country of origin.
Targeting high-risk consumer goods such as toys, electrical appliances and furniture, the system is designed to prevent unsafe products from entering the local market. The pilot phase will begin with products from China as the country is South Africa’s largest import partner before expanding progressively to other countries.
“There are products entering the country that are not regulated and there is a clear need to address that,” Evans said. “The concern is around how this is going to be enforced and whether the systems in place are capable of doing so effectively.”
A key issue raised by clearing agents relates to the reliance on Harmonised System (HS) tariff codes to identify goods that fall within the scope of the programme. According to guidance from the South African Bureau of Standards, affected products will be mapped to specific HS codes and integrated into the customs risk system, allowing authorities to flag shipments automatically.
In theory, this provides a clear mechanism for enforcement. In practice, it is far less straightforward.
“If you look at the tariff codes for toys as an example, you essentially have two broad categories with many items falling under a general ‘other’ classification. There isn’t a specific code that distinguishes between all these different types of toys,” Evans said.
This lack of alignment between the product list and the tariff code structure raises the risk that a wide range of goods could be incorrectly flagged.
“The reality is that if enforcement is based purely on HS codes, there is a strong likelihood that every toy consignment from China could be detained,” he said. “That opens the door to large-scale incorrect detentions and significant delays.”
Regulatory roles
A second concern relates to the apparent overlap in regulatory roles. Traditionally, the SABS is responsible for developing standards while the National Regulator for Compulsory Specifications (NRCS) oversees enforcement. Under the new framework, however, SABS appears to play a more active regulatory role in the PVoC process.
“We now have a situation where both SABS and NRCS are involved and it’s not entirely clear how those responsibilities are going to be managed. The question is whether there is sufficient capacity and clarity to enforce this effectively,” Evans said.
Despite these concerns, he noted that the six-month transition period provided an important window for engagement.
The SABS has indicated that the roll-out will include training sessions, roadshows and the publication of guidance material to support industry understanding, a move that has been welcomed by industry saying it will provide the necessary platform for proper engagement.
“We have to start preparing for the change now and use the next six months to make sure the implementation works. There is still time to address the concerns,” said Evans.
He advised importers to work closely with their suppliers in China over the next six months to ensure that the required certificates were in place ahead of shipment. Goods arriving without a valid CoC may be held, inspected or delayed at the border.
“As an industry, we need to start communicating this to clients immediately. Six months sounds like a long time, but it moves quickly. If suppliers are not ready, we are going to see disruptions,” he said.
“If implemented as it stands, there is a real risk of unintended consequences. And the biggest of those is cargo coming to a standstill.”
