Exemptions & Edge Cases
PVoC Exemptions & Edge Cases — Who Doesn't Need a CoC?
The SABS PVoC programme applies broadly to Phase 1 goods from Mainland China, but several categories of imports are exempt or occupy regulatory grey areas. Understanding the boundaries of the programme is as important as understanding the requirements themselves — particularly for importers who operate in multiple product categories or use non-traditional import channels.
This page covers the known exemptions, the ambiguous edge cases, and the regulatory grey areas where SABS has not yet published clarifying guidance. For each category, the analysis reflects the regulatory position as at 30 April 2026. Where the position is ambiguous, the conservative approach (treat as subject to PVoC) is recommended until SABS publishes clarification.
Important caveat: The exemptions analysis below is based on the gazette text and publicly available SABS guidance. It is not legal advice. If your specific import situation is unclear, contact SABS directly or consult a customs attorney before importing.
Quick Facts
Pre-20-Mar 2026 shipments
Transitional — verify with SABS
Personal imports
Likely exempt — threshold not gazetted
NRCS-regulated products
Separate LOA regime — verify overlap
Non-China goods
Not in scope for Phase 1
Enforcement Date
20 September 2026
Gazette Reference
GG 54374 · 20 March 2026
Mandatory Deadline
20 Sep 2026 · 142 Days
Structural Comparison
Exempt vs Not Exempt — At a Glance
| Attribute | Exempt / Out of Scope | Not Exempt / In Scope |
|---|---|---|
| Pre-20-March 2026 shipments (transitional) | LIKELY EXEMPT — verify with SABS | Post-20-Sep 2026 commercial imports: NOT EXEMPT |
| Personal imports under threshold | LIKELY EXEMPT — threshold not gazetted | Commercial imports: NOT EXEMPT |
| NRCS-regulated products (LOA) | SEPARATE REGIME — may still need CoC | SANS-regulated products: NOT EXEMPT |
| Sample shipments | LIKELY EXEMPT — verify threshold with SABS | Regular commercial shipments: NOT EXEMPT |
| Goods from Vietnam/India/Bangladesh | NOT IN SCOPE — Phase 1 China only | Goods from Mainland China: IN SCOPE |
| Medical devices (SAHPRA) | SEPARATE REGIME — Medicines Act | Consumer electronics: NOT EXEMPT |
| Used/refurbished goods | AMBIGUOUS — verify with SABS | New goods: NOT EXEMPT |
| E-commerce small parcels (Shein/Temu) | AMBIGUOUS — threshold unclear | Commercial bulk imports: NOT EXEMPT |
This table reflects the regulatory position as at 30 April 2026. Several categories are ambiguous pending SABS clarification. Where ambiguous, the conservative approach (treat as in scope) is recommended.
Transitional Period
Pre-September 2026 Shipments
The gazette was published on 20 March 2026 and enforcement begins on 20 September 2026. This 6-month transitional period was intended to give importers time to establish relationships with inspection bodies and adapt their supply chains. Goods that arrived in South Africa before 20 September 2026 are not subject to PVoC requirements, regardless of when they were ordered.
The critical date is the arrival date at a South African port, not the order date or ship date. If your goods were ordered before March 2026 but will arrive after 20 September 2026, they are subject to PVoC requirements. There is no exemption for goods ordered before the gazette was published.
Some importers have asked whether goods in transit on 20 September 2026 are exempt. The gazette does not address this specifically. The conservative position is that goods arriving after 20 September 2026 require a CoC, regardless of when they were shipped. Contact SABS for formal guidance if you have goods in transit around the enforcement date.
Non-Commercial Imports
Personal Imports, Samples, and Trade Show Goods
The PVoC programme applies to commercial imports. Personal imports — goods for personal use, not for resale — are widely expected to be exempt, but the gazette does not define a specific quantity or value threshold for personal imports. This creates ambiguity for importers who bring in goods for their own use in commercial quantities.
Sample shipments for product testing and evaluation are widely expected to be exempt, but no formal sample exemption has been gazetted. The practical risk is that a held sample shipment (at R3,000–R8,000/day demurrage) may cost more than obtaining a CoC for the sample. Until SABS publishes a formal sample exemption, the conservative approach is to obtain a CoC for sample shipments of Phase 1 goods from China.
Trade show goods — goods imported temporarily for display at a trade show and then re-exported — may qualify for a temporary import exemption under existing customs rules. This is separate from the PVoC programme. Consult your clearing agent about the ATA Carnet or temporary import permit process for trade show goods.
Regulatory Overlap
NRCS-Regulated Products and Medical Devices
Some Phase 1 products are also subject to compulsory specifications under the NRCS Act, which requires an NRCS Letter of Authority (LOA). The LOA and the PVoC CoC are separate regulatory instruments — having one does not exempt you from the other. Products subject to both regimes include certain electrical appliances, certain cosmetics, and certain toys.
Medical devices regulated by the South African Health Products Regulatory Authority (SAHPRA) under the Medicines and Related Substances Act are subject to a separate regulatory regime. Medical devices are not Phase 1 products and are not subject to PVoC requirements. However, consumer health products (e.g., certain cosmetics with therapeutic claims) may fall under both SAHPRA and SABS PVoC jurisdiction — verify with both regulators.
The general principle is that the PVoC programme does not replace other regulatory requirements — it adds to them. If your product is subject to both NRCS and SABS PVoC requirements, you need both documents. See the NRCS LOA vs SABS CoC article for the full comparison.
E-commerce & Small Parcels
Shein, Temu, AliExpress, and the Grey Area
E-commerce imports from Chinese platforms (Shein, Temu, AliExpress, DHgate) occupy the most contested regulatory grey area in the PVoC programme. The Cape Chamber of Commerce publicly raised this concern in March 2026, noting that the gazette does not address small-parcel e-commerce imports and that applying PVoC requirements to individual consumer purchases would be practically unenforceable.
The likely outcome is that SABS will publish guidance distinguishing between personal consumer purchases (exempt) and commercial purchases for resale (not exempt). Until that guidance is published, the conservative position for commercial importers using e-commerce platforms is to treat their purchases as subject to PVoC requirements.
The practical challenge for e-commerce importers is that Chinese e-commerce platforms do not have established relationships with SABS-authorised inspection bodies, and the per-unit cost of obtaining a CoC for small-value items may be prohibitive. This is a structural problem with the programme that SABS will need to address. Monitor the SABS website for guidance.
Frequently Asked Questions
Common Exemption Questions
I placed my order before March 2026 — am I exempt?
The gazette was published on 20 March 2026 and enforcement begins on 20 September 2026. If your goods were shipped before 20 September 2026, the transitional period may apply. However, the gazette does not provide a clear exemption for goods ordered before March 2026 but shipped after September 2026. If your goods will arrive at a South African port after 20 September 2026, treat them as subject to PVoC requirements unless SABS publishes specific transitional guidance. Contact SABS directly for confirmation.
My goods are regulated by NRCS — do I still need a PVoC CoC?
The NRCS Letter of Authority (LOA) and the PVoC Certificate of Conformity are separate regulatory instruments. Some products require both. The NRCS LOA covers compulsory specifications under the NRCS Act. The PVoC CoC covers Phase 1 goods from China under the SABS PVoC programme. If your product is both subject to compulsory specifications (NRCS) and falls within a Phase 1 category (SABS PVoC), you may need both documents. Verify with both NRCS and your inspection body.
What about sample shipments for product testing?
Sample shipments are widely expected to be exempt from PVoC requirements, but the gazette does not explicitly define a sample exemption or specify a quantity threshold. Until SABS publishes clarifying guidance, importers bringing in samples of Phase 1 goods from China should either obtain a CoC for the sample shipment or apply to SABS for a formal exemption. The risk of holding costs (R3,000–R8,000/day) for a held sample shipment may outweigh the cost of obtaining a CoC.
Are Shein/Temu/AliExpress purchases exempt?
Small personal purchases from e-commerce platforms are widely expected to be treated as personal imports and therefore exempt. However, commercial quantities purchased through these platforms — for resale or business use — are likely subject to PVoC requirements. The threshold between personal and commercial imports has not been gazetted. The Cape Chamber of Commerce publicly raised this concern in March 2026 and requested clarification from SABS. Until clarification is published, commercial importers using these platforms should treat their purchases as subject to PVoC requirements.
What about used or refurbished goods from China?
The PVoC programme applies to goods, not to the condition of goods. The gazette does not explicitly exempt used or refurbished goods. However, the practical challenge is that used goods cannot always be inspected against SANS standards in the same way as new goods. The regulatory position on used goods is ambiguous. Importers of used or refurbished Phase 1 goods from China should contact SABS directly for guidance before importing.
Continue Learning
The PVoC Programme
Full regulatory context — what PVoC is, who it applies to, and what it requires.
PVoC Exemptions Article
Detailed analysis of all known exemptions and edge cases.
E-commerce PVoC
How PVoC affects Shein, Temu, and AliExpress imports.
Medical Devices PVoC
SAHPRA-regulated medical devices and the PVoC overlap.
NRCS LOA vs SABS CoC
Understanding the difference between compulsory specification LOAs and PVoC CoCs.
Phase 1 China Only
Why Phase 1 applies only to Mainland China and what happens with other countries.
Not Sure If Your Imports Are Exempt?
The safest approach is to register your importer account and consult with your clearing agent. R1,997 one-time onboarding. Each CoC registration takes minutes.
Verify with official sources: Government Gazette No. 54374 (20 March 2026). SABS website for exemption guidance. This article reflects the regulatory position as at 30 April 2026 and should not be relied upon as legal advice. Consult a customs attorney for advice specific to your import situation.