Applicability
Do I Need a CoC for Imports from Hong Kong?
Hong Kong SAR is not Mainland China for the purposes of the SABS PVoC programme. The Phase 1 requirement applies to goods originating from Mainland China — not to goods manufactured in Hong Kong and shipped from Hong Kong. However, goods manufactured in Mainland China and transshipped through Hong Kong still require a CoC, because the country of origin is Mainland China.
Hong Kong SAR vs Mainland China
The Legal Distinction
Hong Kong is a Special Administrative Region (SAR) of China with its own customs territory, separate from Mainland China. For customs and trade purposes, Hong Kong is treated as a distinct jurisdiction. Goods manufactured in Hong Kong and exported from Hong Kong are considered to originate from Hong Kong, not from Mainland China.
The SABS PVoC Phase 1 programme applies to goods originating from Mainland China. Government Gazette No. 54374 specifies "Mainland China" as the country of origin scope. Hong Kong SAR is not Mainland China for this purpose.
What Matters: Country of Origin, Not Port of Shipment
Origin vs Transshipment
The critical question is not where the goods were shipped from, but where they were manufactured. If goods were manufactured in Mainland China and shipped directly from a Mainland China port, they require a CoC. If goods were manufactured in Mainland China, shipped to Hong Kong, and then transshipped to South Africa, they still require a CoC — because the country of origin is Mainland China.
If goods were genuinely manufactured in Hong Kong (not just assembled or relabelled), they do not require a PVoC CoC under Phase 1. However, importers should be prepared to demonstrate Hong Kong origin if challenged by SARS Customs.
How SARS Customs Determines Origin
Substantial Transformation and Rules of Origin
SARS Customs applies rules of origin to determine where goods were manufactured. For most Phase 1 goods, the country of origin is determined by where substantial transformation occurred — where the goods were manufactured or processed into their final form. Simply shipping goods through Hong Kong does not change their country of origin.
If your supplier is in Hong Kong but sources components or finished goods from Mainland China, the goods may still be considered of Mainland China origin. Consult your clearing agent about the applicable rules of origin for your specific product category.
Practical Guidance for Hong Kong Importers
What to Do
If your supplier is based in Hong Kong and manufactures goods in Hong Kong (not in Mainland China), you do not need a PVoC CoC for Phase 1. Keep documentation demonstrating Hong Kong manufacture (factory certificates, production records) in case SARS Customs queries the origin.
If your Hong Kong supplier sources goods from Mainland China factories, or if the goods are manufactured in Mainland China and transshipped through Hong Kong, you need a PVoC CoC. Engage one of the four designated inspection bodies (CCIC, SGS, Intertek, Bureau Veritas) in Mainland China to inspect and certify the goods before they leave China.
Frequently Asked Questions
Common Questions
Does Phase 1 apply to goods from Hong Kong?
Phase 1 applies to goods originating from Mainland China. If goods are manufactured in Hong Kong, they do not require a PVoC CoC. If goods are manufactured in Mainland China and transshipped through Hong Kong, they do require a CoC because the country of origin is Mainland China.
What if my supplier is in Hong Kong but sources from China?
If your supplier sources finished goods or key components from Mainland China factories, the goods may be considered of Mainland China origin. The rules of origin determine this based on where substantial transformation occurred. Consult your clearing agent about the applicable rules of origin for your product category.
Does Phase 1 apply to goods from Macau?
Macau SAR is also a separate customs territory from Mainland China, similar to Hong Kong. The same analysis applies: goods manufactured in Macau do not require a PVoC CoC, but goods manufactured in Mainland China and transshipped through Macau do.
What documentation do I need to prove Hong Kong origin?
To demonstrate Hong Kong origin, keep factory certificates, production records, and certificates of origin issued by the Hong Kong Trade and Industry Department. Your clearing agent can advise on the specific documentation required for your product category.
Continue Learning
The PVoC Programme
Full regulatory context for the SABS PVoC programme.
Phase 1 China Only — What About Vietnam, Thailand, Bangladesh?
Country scope for Phase 1.
Goods Made in China but Shipped from Elsewhere
The transshipment and origin question.
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.
Importing from Hong Kong? Check the country of origin.
If goods are manufactured in Mainland China, they require a PVoC CoC regardless of where they are shipped from. If genuinely manufactured in Hong Kong, no CoC is required.
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.