The Southern African Association of Freight Forwarders (SAAFF) has proposed the establishment of a single-window digital platform for e-waste compliance following concerns over regulatory coordination, import permit requirements and the administration of retrospective Extended Producer Responsibility (EPR) obligations.
SAAFF said the proposed system could streamline information sharing between industry and government, reduce administrative red tape and provide greater certainty for importers, freight forwarders and customs brokers.
The proposal follows concerns raised with Freight News that the International Trade Administration Commission (ITAC) was allegedly withholding import permits for electronic goods unless applicants could prove registration and levy clearance with the EPR Waste Association of South Africa (eWASA).
The concerns included claims that importers could be restricted in their choice of compliance mechanisms, required to provide commercially sensitive trade data to a private organisation and face retrospective financial liabilities dating back to November 2021.
Both ITAC and eWASA rejected claims that registration with eWASA was required for the issuing of import permits.
ITAC clarifies permit requirements
ITAC said the Department of Forestry, Fisheries and the Environment (DFFE) had not instructed it to withhold import permits based on registration with eWASA.
“ITAC does not subscribe to eWASA, nor does it depend on any private Producer Responsibility Organisation to approve import permit applications for e-waste. Instead, ITAC relies exclusively on approvals or recommendations from the Department of Forestry, Fisheries and the Environment, which is the designated regulatory authority for waste management,” ITAC said.
The commission also rejected claims that outstanding levy payments or retrospective collections influenced its decisions on import permits. “Outstanding financial payments or levy collection do not factor into the adjudication or issuance of import permits. Consequently, ITAC does not withhold permits on this basis,” it said.
eWASA chief strategy officer Jordan Joseph confirmed that participation in the organisation’s compliance scheme was voluntary. “eWASA is not collaborating with ITAC to make it a prerequisite for compliance.”
He said importers could also operate independent compliance schemes in accordance with the regulations.
However, Joseph said eWASA’s position was that producers that had failed to comply with EPR obligations since the regulations took effect would be required to meet their obligations retrospectively.
“DFFE’s position in terms of the commercial aspects is that any producer who has neglected to comply with the promulgated legislation and gazetted notice is welcome to come into the fold, but it is non-negotiable that they would have to honour their obligation dating back to 2021,” Joseph said.
He added that eWASA offered payment arrangements of up to two years to assist affected businesses with financial planning.
Addressing concerns about commercially sensitive information, Joseph said individual producer trade data was protected and that only aggregated information was submitted to the DFFE on a biannual and annual basis.
Industry calls for coordinated system
SAAFF said experience since the implementation of the EPR Regulations in November 2021 had highlighted opportunities to simplify administrative processes and improve coordination between government, PROs and industry.
“SAAFF advocates for a more structured and consultative implementation framework that is underpinned by clear governance, standardised operating procedures, transparent workflows, and well-defined roles and responsibilities across all participating authorities,” the association said.
It said freight forwarders and customs brokers required greater certainty, visibility and consistency in the administration of environmental levies and associated compliance obligations.
“This includes clear guidance on the administration of compliance requirements, the associated levy obligations and transparent processes relating to retrospective assessments and payment arrangements, and improved coordination between the DFFE, ITAC, PROs and representative industry bodies,” SAAFF said.
The association has proposed a ‘Single Window’ approach that would provide a digital interface between industry and government and facilitate integrated information sharing and secure data exchange.
The proposal is outlined in the SAAFF-ITAC Concept Note on E-Waste Levy Administration and Regulatory Coordination, authored by SAAFF head of the SARS and Other Government Agencies Division, Devlyn Naidoo.
The concept note calls for a collaborative workshop between industry and authorities to address the administration of e-waste compliance requirements.
“The introduction of a Single Window + platform represents a significant opportunity to modernise levy administration by providing a single digital interface between industry and government with trade involvement upstream, removing the friction and waste in respect of permits, certificates and licences through a transparent, unmanipulated view,” Naidoo said in the document.
Naidoo added that SAAFF would support an annual independent audit of imported commodities subject to EPR obligations, together with an assessment of statutory levy administration and utilisation.
