Goods in SA Bonded Warehouse Before 20 September 2026 — Do They Need a CoC?

What Is a Bonded Warehouse?

Goods Under Customs Control

A bonded warehouse is a secure facility where imported goods can be stored under Customs control without payment of import duties and taxes. Goods in a bonded warehouse have entered South Africa physically but have not yet been formally imported — they remain under Customs control until they are cleared for import.

Because goods in a bonded warehouse have not yet been formally imported, the question arises whether the PVoC CoC requirement applies to them at the time they are released from the warehouse. The answer depends on whether the goods were placed in the bonded warehouse before or after the 20 September 2026 enforcement date, and on SARS Customs's transitional provisions.

The Key Risk

Detention on Release After the Deadline

The key risk for importers with goods in bonded warehouses is that SARS Customs may require a PVoC CoC when the goods are released from the warehouse after 20 September 2026, even if the goods arrived in South Africa before the deadline. If SARS Customs takes this position, goods released from bonded warehouses without a CoC after the deadline will be detained.

This is a significant risk for importers who have large volumes of regulated goods in bonded warehouses that they plan to release after the deadline. The cost of detention — demurrage and storage charges of ZAR 6,693+/day — can accumulate rapidly while the compliance issue is resolved.

Obtaining a PVoC CoC for goods already in a bonded warehouse is difficult because PVoC CoCs are pre-shipment documents — they are issued by inspection bodies before the goods are shipped. There is no standard mechanism for obtaining a CoC for goods that are already in South Africa.

The Recommended Approach

Confirm with SARS Customs Before the Deadline

Importers with regulated goods in South African bonded warehouses should confirm with SARS Customs — before 20 September 2026 — whether a PVoC CoC will be required when the goods are released. SARS Customs may issue guidance on transitional provisions for bonded warehouse stock, similar to the guidance issued for goods in transit.

If SARS Customs confirms that bonded warehouse stock placed before the deadline is exempt from the CoC requirement, obtain written confirmation and retain it with the goods' documentation. If SARS Customs confirms that a CoC is required, work with an SABS-accredited inspection body to determine whether a retrospective inspection is possible.

The safest approach is to release all regulated goods from bonded warehouses before 20 September 2026, before the enforcement date. This avoids the transitional uncertainty entirely.

Practical Implications

Planning for Bonded Warehouse Stock

Importers who regularly use bonded warehouses for regulated goods should review their current bonded stock and plan for the 20 September 2026 deadline. Goods that can be released before the deadline should be released before the deadline. Goods that cannot be released before the deadline should be the subject of a direct enquiry to SARS Customs about transitional provisions.

For future shipments, ensure that PVoC CoCs are obtained before goods are shipped to South Africa, so that the CoC is available when goods are released from the bonded warehouse.