Does PVoC Phase 1 Apply to Countries Other Than China?

Why the China Misconception Exists

How the Confusion Started

The misconception that PVoC only applies to goods from China likely arose because China is the dominant source of regulated goods imported into South Africa. When the PVoC programme was first communicated to industry, much of the discussion focused on China-origin goods because they represent the largest volume of regulated imports. This led some importers to incorrectly conclude that PVoC only applies to Chinese goods.

Additionally, some early communications about PVoC referred to "Phase 1" in the context of specific product categories or inspection body rollouts, which may have been interpreted as applying only to certain origin countries. This interpretation is incorrect.

The SABS PVoC programme applies to regulated goods from all countries. The programme documentation is clear on this point: the CoC requirement applies based on the product category, not the country of origin.

Countries Commonly Affected

Where South Africa Sources Regulated Goods

South Africa imports regulated goods from a wide range of countries. China is the largest source, but significant volumes of regulated goods also come from Vietnam (electronics, furniture, textiles), India (pharmaceuticals, chemicals, textiles), Bangladesh (garments, textiles), Turkey (electrical equipment, automotive parts), Germany (machinery, automotive parts, chemicals), and many other countries.

Importers who source regulated goods from any of these countries — or from any other country — need to obtain PVoC CoCs for those goods before shipment to South Africa. The inspection body must be able to inspect the goods at the origin location, and all four major inspection bodies (Bureau Veritas, Intertek, SGS, TÜV Rheinland) operate globally.

Importers who have been obtaining CoCs for China-origin goods but not for goods from other countries should review their supply chains and ensure that all regulated goods — regardless of origin — have valid CoCs before the 20 September 2026 deadline.

The Origin-Neutral Principle

How PVoC Determines Applicability

The PVoC programme determines applicability based on the product category and HS code, not the country of origin. If a product falls within the regulated product scope (as defined by the SABS PVoC product scope), it requires a CoC regardless of where it was manufactured.

This origin-neutral approach is consistent with WTO principles on non-discrimination in trade. South Africa cannot require CoCs for goods from China but not for equivalent goods from Germany — the requirement must apply equally to all origin countries.

Practical Implications

Reviewing Your Supply Chain

Importers who source regulated goods from multiple countries should review their entire supply chain and ensure that PVoC CoCs are obtained for all regulated goods, regardless of origin. This may require engaging inspection bodies in multiple countries.

All four major inspection bodies (Bureau Veritas, Intertek, SGS, TÜV Rheinland) operate globally and can conduct pre-shipment inspections in most major manufacturing countries. Contact the inspection body directly and provide the origin country and product details to confirm their capacity to inspect in that country.