Phase 1 only applies to China — what about Vietnam, Thailand, Bangladesh?

The Question Stated Plainly

Many importers and businesses operating within South Africa's regulatory landscape are seeking clarity on the geographical scope of the new Certificate of Conformity (CoC) requirements. Specifically, there is a common inquiry regarding whether the initial phase of these regulations, often referred to as 'Phase 1', extends beyond Mainland China to include other significant manufacturing and export hubs such as Vietnam, Thailand, and Bangladesh.

This article aims to address this question directly, providing a clear understanding of the current regulatory framework as it pertains to the origin of goods requiring a Certificate of Conformity for importation into South Africa.

Regulatory Framework

The implementation of mandatory Certificates of Conformity for certain imported goods into South Africa is governed by specific legislative instruments. The primary directive establishing these requirements is outlined in Government Gazette No. 54374, published on 20 March 2026. This Gazette details the scope, effective dates, and procedural aspects of the CoC program. It is crucial to refer to this official publication for precise legal definitions and requirements.

The South African Bureau of Standards (SABS) is the designated authority responsible for overseeing and enforcing these regulations. Their role includes the accreditation of conformity assessment bodies and the issuance of guidelines to ensure compliance. Any expansion or modification to the geographical scope or product categories under the CoC program would typically be communicated through subsequent Government Gazettes or official SABS announcements.

For the purposes of Phase 1, the regulatory framework explicitly defines the countries of origin that are subject to the immediate requirements. This specificity is designed to allow for a phased implementation, enabling both regulators and industry stakeholders to adapt to the new compliance obligations progressively.

Specific Answer: Geographical Scope of Phase 1

To directly answer the question: Phase 1 of South Africa's Certificate of Conformity regulations applies exclusively to goods originating from Mainland China. This means that if your supply chain is entirely outside of Mainland China, the requirements of Phase 1 do not currently apply to your imports.

Countries such as Vietnam, Thailand, Bangladesh, and India are explicitly not in scope for Phase 1. Importers sourcing goods from these nations are not presently required to obtain a Certificate of Conformity under the current Phase 1 directives as stipulated in Government Gazette No. 54374 (20 March 2026).

While there has been an announcement regarding a forthcoming 'Phase 2' of the CoC program, which is expected to expand the geographical coverage to include additional countries, it is important to note that Phase 2 has not yet been formally gazetted. Until such time as a new Government Gazette is published, detailing the specific countries and effective dates for Phase 2, the regulations remain limited to Mainland China for Phase 1.

Businesses should monitor official SABS communications and subsequent Government Gazettes for updates regarding the expansion of the CoC program. The SABS has not yet published the definitive list of Phase 2 expansion countries or their respective implementation dates. Therefore, any goods imported from countries other than Mainland China are not subject to the CoC requirements under the existing Phase 1 framework.

In summary, if your imported goods originate from Vietnam, Thailand, Bangladesh, India, or any other country outside of Mainland China, you are not currently impacted by the Phase 1 Certificate of Conformity regulations. Compliance efforts should remain focused on goods from Mainland China until further official announcements are made regarding Phase 2.