Cosmetics & Toiletries — Phase 1
Cosmetics Import Compliance & PVoC Requirements
Phase 1 goods from Mainland China require a Certificate of Conformity (CoC) issued by an accredited inspection body before they ship. From 20 September 2026, SARS Customs and the Border Management Authority (BMA) will refuse clearance for any Phase 1 shipment without a valid CoC.
Phase 1 Scope
What Cosmetics Products Are in Scope
Phase 1 covers cosmetics and toiletry products imported from Mainland China, including: skin care products (creams, lotions, serums), hair relaxers and hair dyes, skin-lightening products, nail products (nail polish, nail care), fragrances and perfumes, and colour cosmetics (foundation, lipstick, eyeshadow). The applicable SANS codes are SANS 1557 (cosmetics) and SANS 10400 (labelling requirements).
SANS Reference
Applicable SANS Standards
The primary SANS codes for cosmetics are SANS 1557 (cosmetics — covers ingredient safety, microbiological limits, and packaging requirements) and SANS 10400 (labelling — covers required label information, language requirements, and claim restrictions). For the authoritative SANS code reference, visit sansstandards.co.za.
Structural Comparison
With CoC vs Without CoC
| Attribute | Without CoC | With CoC (Registered on Vault) |
|---|---|---|
| CoC Status | No CoC — goods held at port | Valid CoC — goods cleared |
| Port Delay | R3,000–R8,000/day demurrage | No delay — SAD500 clears |
| Penalty Risk | Potential 15% CIF surcharge (East African precedent) | No penalty |
| Document Retention | Non-compliant — Customs Act §101 not satisfied | 5-year encrypted retention |
| Verification Method | Paper-based, manual, slow | QR code scan — verified in seconds |
| Clearing Agent Workflow | SAD500 rejected — goods held | Verification URL in SAD500 — cleared |
Frequently Asked Questions
Common Questions
Does my hair relaxer shipment need a CoC?
Yes. Hair relaxers imported from China are in scope for Phase 1 PVoC. The applicable standard is SANS 1557. Your inspection body (CCIC, SGS, Intertek, or Bureau Veritas) must verify the products against this standard before they ship from China.
What about skin-lightening products?
Yes. Skin-lightening products imported from China are in scope. SANS 1557 covers ingredient safety requirements, including restrictions on certain active ingredients. The inspection body will verify compliance with these requirements.
Do labelling requirements affect the CoC?
Yes. SANS 10400 labelling requirements are part of the conformity assessment. Products must be labelled in English and Afrikaans (at minimum) with the required information. Non-compliant labelling will prevent the CoC from being issued.
My cosmetics already have EU CPNP registration — does that replace the CoC?
No. EU CPNP registration satisfies European requirements. It does not replace the PVoC CoC for South African imports. The inspection body will review your EU documentation as supporting evidence, but the CoC must still be issued for each shipment.
Minting Fee Worked Example
What Does a Cosmetics CoC Cost to Register?
The CoC Vault minting fee is tiered based on the declared CIF value of the shipment. For a typical commercial cosmetics shipment from China:
| Shipment CIF Value | Tier | Minting Fee |
|---|---|---|
| R250,000 (small cosmetics order) | 2% tier | R5,000 |
| R600,000 (medium cosmetics order) | 2% tier | R12,000 |
| R1,200,000 (large cosmetics order) | 1% tier | R12,000 |
| R2,500,000 (bulk cosmetics import) | 1% tier | R25,000 |
CIF tiers: ≤R1M = 2%, R1M–R10M = 1%, R10M–R100M = 0.5%. The R1,997 onboarding fee is a one-time payment per importer entity — not per shipment.
Common Inspection Failures
Cosmetics Inspection Pitfalls to Avoid
Restricted ingredients not disclosed
SANS 1557 maintains a list of restricted and prohibited ingredients. Products containing undisclosed restricted ingredients will fail the conformity assessment. Provide a full ingredient list (INCI names) to the inspection body.
Labelling not in English and Afrikaans
SANS 10400 requires cosmetics labels to include the required information in English and Afrikaans. Products labelled in English only, or with Chinese text, will not receive a CoC.
Microbiological limits exceeded
SANS 1557 sets microbiological limits for cosmetics. Products that have been stored improperly or have a short shelf life may fail microbiological testing. Ensure products are within shelf life and have been stored correctly.
Therapeutic claims triggering SAHPRA jurisdiction
Cosmetics with therapeutic claims (e.g., 'treats acne', 'reduces inflammation') may be classified as medicines by SAHPRA, requiring a separate registration. Avoid therapeutic claims on cosmetics labels.
Continue Learning
The PVoC Programme
Full regulatory context for the SABS PVoC programme.
Phase 1 Sectors Hub
All five Phase 1 sectors with SANS codes and inspection guidance.
How to Brief Your Chinese Supplier
Practical guide to managing the supplier relationship during PVoC implementation.
How Much Does a CoC Cost?
Honest breakdown of CoC costs including the tiered minting fee.
sansstandards.co.za
The South African National Standards catalogue.
Register Your Cosmetics Import Entity
R1,997 one-time onboarding. Each CoC registration takes minutes. Have your vault active before 20 September 2026.
Verify with official sources: Government Gazette No. 54374 (20 March 2026). sansstandards.co.za for applicable SANS codes. This article reflects the regulatory position as at 30 April 2026 and should not be relied upon as legal advice.