Edge Case Applicability
Sample Imports and PVoC: Does a CoC Apply to Samples?
Product samples imported into South Africa for evaluation purposes are not automatically exempt from the PVoC CoC requirement. Whether a sample requires a CoC depends on whether it is a regulated product and whether any exemption applies. This article explains the key considerations.
The General Rule
Samples Are Not Automatically Exempt
The PVoC programme applies to regulated goods — products subject to compulsory SANS standards. The programme does not have a blanket exemption for product samples. A sample of a regulated product (for example, a sample LED luminaire or a sample toy) is subject to the same PVoC requirements as a commercial shipment of the same product.
Importers who bring in product samples for evaluation before placing a commercial order should be aware that the sample may require a PVoC CoC. Importing a regulated sample without a CoC after 20 September 2026 risks detention by SARS Customs.
Limited Exemptions
When Samples May Be Exempt
There are limited circumstances in which product samples may be exempt from the PVoC requirement. Samples that are imported for testing at an accredited laboratory (as part of the certification process itself) may be exempt, as they are not being imported for commercial use. Confirm this with SARS Customs before importing.
Samples that are clearly marked as "not for sale" and are imported in quantities that are clearly not commercial (for example, a single unit) may receive different treatment from SARS Customs. However, this is not a guaranteed exemption and depends on SARS Customs's discretion at the time of import.
The de minimis exemption (for low-value shipments) may also apply to some samples. Check the current de minimis threshold with an SABS-accredited inspection body or SARS Customs.
Practical Approach
How to Handle Sample Imports
The safest approach for importing regulated product samples is to obtain a PVoC CoC for the sample in the same way as for a commercial shipment. This adds cost and time to the sampling process but eliminates the risk of detention.
An alternative approach is to request that the supplier obtain a PVoC CoC for the sample before shipping it. Some suppliers who regularly export to South Africa already have SANS certifications for their products and can obtain a CoC quickly.
Importers who regularly import samples of regulated products should discuss sample import procedures with an SABS-accredited inspection body and with SARS Customs before the 20 September 2026 deadline.
After Sampling
CoC Vault for Sample CoCs
If a PVoC CoC is obtained for a product sample, register it on CoC Vault in the same way as a commercial shipment CoC. The verification URL can be included in SAD 500 documentation and shared with your clearing agent.
If the sample evaluation leads to a commercial order, the CoC for the commercial shipment will be a new document — the sample CoC does not cover the commercial shipment.
Do product samples need a PVoC CoC?
Not automatically, but regulated product samples are not automatically exempt. Whether a CoC is required depends on whether the product is regulated and whether any exemption applies. Confirm with SARS Customs or an SABS-accredited inspection body.
Are samples marked 'not for sale' exempt from PVoC?
Not guaranteed. SARS Customs may require a CoC for samples of regulated products regardless of whether they are marked 'not for sale'. Confirm with SARS Customs before importing.
Can I import a sample to test at a laboratory without a CoC?
Samples imported for testing at an accredited laboratory as part of the certification process may be exempt. Confirm this with SARS Customs before importing.
What is the safest approach for importing regulated samples?
Obtain a PVoC CoC for the sample in the same way as for a commercial shipment. This eliminates the risk of detention.
When does PVoC enforcement become mandatory?
20 September 2026. From that date, SARS Customs will check for valid PVoC CoCs on all regulated goods, including samples.
Continue Learning
Confirm Sample Import Requirements Before the Deadline
Regulated product samples are not automatically exempt from PVoC. Confirm requirements with SARS Customs or an SABS-accredited inspection body before the 20 September 2026 deadline.
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.