Applicability
Do I Need a CoC for Goods Made in China but Shipped from Another Country?
Yes. The PVoC CoC requirement applies based on country of origin, not country of shipment. If goods were manufactured in Mainland China, they require a PVoC CoC regardless of whether they are shipped directly from China or transshipped through Vietnam, Malaysia, the UAE, or any other country. The country of origin is determined by where substantial transformation occurred.
Quick Facts
Rule
Origin determines CoC requirement, not shipment port
Mandatory From
20 September 2026
Common Scenario
China-made goods transshipped via Vietnam, Malaysia, UAE
Key Question
Where were the goods manufactured?
Risk
Transshipment does not change country of origin
Mandatory Deadline
20 Sep 2026 · 140 Days
Country of Origin vs Country of Shipment
The Legal Distinction
The SABS PVoC Phase 1 programme applies to goods originating from Mainland China. Government Gazette No. 54374 specifies the country of origin scope, not the country of shipment. Country of origin is determined by where the goods were manufactured or substantially transformed — not by which port they were shipped from.
Transshipping goods through a third country does not change their country of origin. Goods manufactured in Shenzhen and shipped via Ho Chi Minh City are still of Mainland China origin and require a PVoC CoC.
Common Transshipment Routes
Why This Matters in Practice
Several common shipping routes involve transshipment through third countries: China via Vietnam (common for furniture and electronics), China via Malaysia (common for electrical goods), China via UAE (common for goods destined for Africa), and China via Hong Kong or Singapore (common for consolidated shipments).
In all these cases, if the goods were manufactured in Mainland China, they require a PVoC CoC. The transshipment point is irrelevant to the CoC requirement.
How SARS Customs Identifies Origin
Enforcement at the Port
SARS Customs applies rules of origin to determine where goods were manufactured. For Phase 1 goods, customs officers may request certificates of origin, production records, or other documentation to verify the country of origin. If goods are found to be of Mainland China origin but imported without a CoC, they are liable to detention and forfeiture under the Customs and Excise Act.
Importers who attempt to circumvent the CoC requirement by routing goods through third countries face the same penalties as importers who ship directly from China without a CoC.
What to Do if Your Goods Are Transshipped
Practical Steps
If your goods are manufactured in Mainland China and transshipped through another country, arrange the PVoC inspection in Mainland China before the goods leave China. The inspection must happen at the point of manufacture, not at the transshipment point. Engage one of the four designated inspection bodies (CCIC, SGS, Intertek, Bureau Veritas) in Mainland China.
The CoC is issued based on the inspection in China. Register the CoC on cofc after receiving the PDF. Give the verification URL to your clearing agent for the SAD500.
Frequently Asked Questions
Common Questions
Do goods transshipped via Vietnam need a CoC?
Yes, if they were manufactured in Mainland China. The transshipment through Vietnam does not change the country of origin. The CoC requirement applies based on where the goods were manufactured, not where they were shipped from.
What if my supplier is in Vietnam but uses Chinese components?
This depends on the rules of origin. If the goods undergo substantial transformation in Vietnam (i.e., the manufacturing process in Vietnam creates a fundamentally different product), they may be considered of Vietnamese origin and not require a PVoC CoC. If the goods are simply assembled or relabelled in Vietnam, they may still be considered of Chinese origin. Consult your clearing agent.
Can I get the inspection done in the transshipment country?
No. The PVoC inspection must be conducted in the country of origin — Mainland China — before the goods leave China. The inspection bodies (CCIC, SGS, Intertek, Bureau Veritas) have offices in China and conduct inspections there.
What documentation proves country of origin?
Certificates of origin, production records, factory certificates, and bills of materials can all be used to demonstrate country of origin. Your clearing agent can advise on the specific documentation required for your product category.
Continue Learning
The PVoC Programme
Full regulatory context.
Do I Need a CoC for Imports from Hong Kong?
The Hong Kong SAR question.
Phase 1 China Only — What About Vietnam, Thailand, Bangladesh?
Country scope for Phase 1.
Certificate of Conformity Guide
What a CoC is and how to register it.
I Was Told I Need a CoC — What Does That Mean?
The full explanation.
Goods made in China require a CoC regardless of shipment route.
The PVoC CoC requirement applies based on country of origin. Arrange the inspection in Mainland China before the goods leave.
Sources: Government Gazette No. 54374 (20 March 2026); Standards Act 8 of 2008; Customs and Excise Act 91 of 1964. Last verified: 3 May 2026. certificatesofconformity.co.za is an independent reference publication operated by LinkDaddy LLC, a Florida-registered US entity. Not affiliated with or endorsed by the SABS, NRCS, SARS, or any agency of the Government of South Africa.