I'm a clearing agent, not the importer of record. What's my role in the CoC requirement?

Who is legally responsible for the CoC

Under the PVoC programme (Government Gazette No. 54374, 20 March 2026), the obligation to ensure a valid Certificate of Conformity exists for a Phase 1 shipment rests with the importer of record — the entity named on the SAD500 as the importer. This is typically your client, not you.

As the clearing agent, you are not the importer of record. You are acting as the agent of the importer, and your obligation is to submit accurate and complete customs documentation on their behalf. If the importer has not obtained a valid CoC, you cannot manufacture one. What you can do — and what you should do — is make the CoC requirement a standard part of your pre-clearance documentation checklist.

What happens at the port without a CoC

From 20 September 2026, SARS Customs will require a valid CoC reference for any Phase 1 shipment from Mainland China before the SAD500 can be processed. If you submit a SAD500 for a Phase 1 shipment without a CoC reference, the submission will be rejected. The goods will be held. Your client will be liable for storage and demurrage costs from day one.

This is not a post-clearance audit risk — it is a pre-clearance gate. The hold happens before the goods clear, not after. Your client will call you. The conversation will not be pleasant.

What you need from your clients before September 2026

For every client who imports Phase 1 goods from Mainland China, you need to confirm three things before their next shipment:

1. Their Chinese supplier has engaged an accredited inspection body. The CoC must be issued by CCIC, SGS, Intertek, or Bureau Veritas at the factory or port of departure. If the supplier hasn't started this process, the client needs to brief them immediately — inspection cycles take 2–4 weeks.
2. The CoC has been registered on a permanent verification URL. A PDF in an email is not sufficient for port verification. The CoC needs to be hashed and registered so you can include a verification URL in the pre-clearance documentation.
3. You have the verification URL before the shipment arrives. The verification URL needs to be in your hands before the goods reach the port, not after. Build this into your pre-arrival documentation checklist.

The service-line opportunity

Every clearing agent with a book of Chinese-import clients is about to receive a wave of panicked calls in August and September 2026 from importers who haven't prepared. The agents who have a workflow ready — who can tell clients exactly what to do and where to go — will convert that panic into a value-added service. The agents who don't will spend August and September managing holds.

certificatesofconformity.co.za is working with clearing agents in Durban and Cape Town who want to offer CoC vault registration as a value-added service to their clients. The operational model is straightforward: the importer registers on the platform, uploads their CoC PDF, and the verification URL is generated. You include the URL in your pre-clearance documentation. The importer pays the minting fee directly. You provide the workflow guidance.

If you're interested in a partner arrangement — including white-label options and a commission structure on referred clients — see the clearing-agent partner page.

How to use the verification URL in your documentation

Once your client has registered their CoC on the platform, they receive a permanent verification URL in the format https://certificatesofconformity.co.za/v/{hash}. This URL is permanent — it doesn't expire, it doesn't require a login to access, and it returns the full CoC metadata including the SHA-256 hash, the issuing body, the applicable SANS codes, and the importer of record.

Include this URL in the additional information field of the SAD500 submission, or attach it as a supporting document reference. SARS Customs can verify the CoC in seconds without requesting the original PDF.

Verify with official sources: Government Gazette No. 54374 (20 March 2026). South African Association of Freight Forwarders (SAAFF) member communications on PVoC compliance. Customs and Excise Act 91 of 1964, Section 101. This article reflects the regulatory position as at 30 April 2026 and should not be relied upon as legal advice.