Repair and Return Imports: Does a CoC Apply?

The General Rule

Re-Importation and PVoC

When goods are exported from South Africa for repair or refurbishment and returned, they are technically being re-imported. The PVoC CoC requirement applies to imports of regulated goods. Whether it applies to re-imported goods depends on the circumstances.

SARS Customs has provisions for goods exported temporarily for repair (the Temporary Export for Repair procedure). Under this procedure, goods that are exported for repair and returned in the same condition may be exempt from import duties. However, the PVoC CoC requirement is separate from import duty provisions, and the duty exemption does not automatically extend to the CoC requirement.

The safest approach is to confirm with SARS Customs before exporting goods for repair whether a CoC will be required on re-importation.

When a CoC Is More Likely Required

Modified or Upgraded Goods

If goods are modified, upgraded, or substantially refurbished during the repair process — for example, if an electrical appliance has its circuit board replaced with a newer model, or if a toy is repainted with new materials — the returned goods may be treated as new goods for PVoC purposes. In this case, a CoC would be required.

The key question is whether the goods returned are substantially the same as the goods that were exported. If they are substantially the same (minor repairs only), a CoC may not be required. If they have been substantially modified, a CoC is more likely required.

This determination is made by SARS Customs at the time of re-importation. Importers who cannot predict in advance whether their goods will be substantially modified during repair should obtain a CoC as a precaution.

Practical Approach

How to Handle Repair and Return

Before exporting goods for repair, contact SARS Customs and confirm the applicable procedure for temporary export for repair and the CoC requirements on re-importation. Obtain written confirmation of the applicable requirements.

If SARS Customs confirms that a CoC will be required on re-importation, arrange for the repair facility to engage an SABS-accredited inspection body to inspect the goods before they are returned to South Africa.

If SARS Customs confirms that a CoC is not required (because the goods are being returned in substantially the same condition), retain the written confirmation with the goods' documentation for presentation at the border.

After Re-Importation

CoC Vault for Repair and Return CoCs

If a CoC is obtained for goods being returned after repair, register it on CoC Vault in the same way as a CoC for a new import. The verification URL can be included in the SAD 500 documentation for the re-importation.

CoC Vault applies to repair and return CoCs in the same way as new import CoCs. The SHA-256 hash of the CoC PDF is calculated and a permanent verification URL is minted.