5-Year CoC Document Retention: What Does It Mean for Importers?

The Legal Requirement

5 Years Under the Customs and Excise Act

Section 101 of the Customs and Excise Act (Act 91 of 1964) requires importers to keep records of all customs transactions for a minimum of 5 years. This includes the SAD 500 declaration, the commercial invoice, the bill of lading, and all supporting documents — including the PVoC CoC.

SARS has the authority to audit importers' customs records at any time within the 5-year retention period. If an importer cannot produce a CoC for a past shipment during an audit, they may face penalties for failure to maintain records.

In practice, retaining records for longer than 5 years is advisable. Product liability claims can arise years after importation, and having a complete record of the CoC for each shipment can be valuable evidence in a product liability dispute.

What Records Must Be Kept

The Full CoC Documentation Package

For each shipment of regulated goods, the documentation package that must be retained includes: the original CoC PDF issued by the inspection body; the SAD 500 declaration that referenced the CoC; the commercial invoice for the shipment; and the CoC Vault verification record (hash, metadata, and verification URL).

The CoC Vault verification record is particularly valuable for retention purposes because it provides a tamper-evident proof that the CoC was authentic at the time of importation. If a CoC is later disputed, the verification record provides evidence that the CoC was registered on CoC Vault before the goods were imported.

Importers should maintain a systematic document management system for CoC records. CoC Vault's dashboard provides a centralised view of all registered CoCs, which simplifies the record management process.

CoC Vault Vault Subscription

Permanent Storage for 5-Year Compliance

CoC Vault's vault subscription provides permanent storage of CoC PDFs and verification records. Vault subscribers can access their CoC records at any time, download the original PDFs, and share verification URLs with SARS Customs, insurers, or other parties who need to verify the authenticity of a CoC.

The vault subscription satisfies the 5-year retention requirement by providing permanent, secure storage of CoC records. Vault subscribers do not need to maintain separate backups of their CoC PDFs.

Non-subscribers' CoC PDFs are deleted from CoC Vault after 30 days. Non-subscribers should maintain their own secure backup of CoC PDFs to satisfy the 5-year retention requirement.

Practical Implications

Building a CoC Record Management System

Importers who ship regulated goods regularly should establish a systematic CoC record management system before the 20 September 2026 enforcement date. This system should include: a centralised repository for CoC PDFs (CoC Vault vault subscription or equivalent); a record of the verification URL for each CoC; and a link between each CoC and the corresponding SAD 500 declaration.

CoC Vault's dashboard provides the centralised repository and the verification URL record. The link to the SAD 500 declaration can be maintained in the importer's existing document management system.