I've imported for 10 years without ever hearing about a CoC. What changed?

What the gazette actually says

On 20 March 2026, the Department of Trade, Industry and Competition published Government Gazette No. 54374, formally establishing the SABS Pre-Export Verification of Conformity (PVoC) programme for Phase 1 product categories imported from Mainland China. The gazette sets 20 September 2026 as the enforcement date — the point at which SARS Customs and the Border Management Authority are authorised to refuse clearance to any Phase 1 shipment that cannot present a valid CoC issued by an accredited inspection body.

Before this gazette, CoCs existed as voluntary quality documents. Importers could obtain them, and some did, but there was no statutory requirement and no enforcement mechanism at the border. The gazette changes both of those things simultaneously.

Why 10 years of importing without one is not evidence that you don't need one now

The absence of a requirement in the past is not evidence that the requirement doesn't exist today. South African trade law has changed materially before — the introduction of NRCS compulsory specifications, the LoA regime, the various SARS tariff reclassifications — and each time, importers who had operated successfully under the previous regime had to adapt. This is the same pattern.

The specific mechanism that makes this different from previous compliance changes is the point of enforcement. Previous requirements were typically enforced post-clearance, through NRCS market surveillance or SARS audit. The PVoC programme is enforced at the border, pre-clearance. Your clearing agent cannot submit the SAD500 for a Phase 1 shipment without a valid CoC reference. There is no post-clearance remedy.

Which products are in scope

Phase 1 covers five product categories imported from Mainland China:

• Solar PV products (panels, inverters, lithium battery cells)
• Furniture (office chairs, mattresses, upholstered products)
• Cosmetics (general cosmetic products, including hair-relaxer and skin-lightening formulations)
• Children's toys and plastic kitchenware
• Electrical appliances (general household appliances, LED lighting, small appliances)

If your imports fall outside these five categories, or if your supply chain is entirely outside Mainland China, Phase 1 does not currently apply to you. Phase 2 expansion has been announced but not yet gazetted.

What the CoC must contain

A valid CoC for PVoC purposes must be issued by one of four accredited inspection bodies: CCIC (China Certification and Inspection Group), SGS, Intertek, or Bureau Veritas. It must be issued at the source — at the factory or port of departure in China — before the bill of lading is signed. It must reference the applicable South African National Standards (SANS) for the product category. A CoC issued after goods arrive in South Africa is not valid for PVoC purposes.

What certificatesofconformity.co.za does

The inspection body issues the CoC. We handle the documentation layer: SHA-256 hashing the CoC PDF to create a tamper-proof digital fingerprint, registering it on a permanent verification URL that SARS Customs can check in seconds, and retaining it for the 5-year period required by Section 101 of the Customs and Excise Act, 1964.

Your clearing agent needs a verification URL they can include in the pre-clearance documentation. That's what we provide. The inspection body relationship is between you and CCIC, SGS, Intertek, or Bureau Veritas — we don't replace that.

Verify with official sources: Government Gazette No. 54374 (20 March 2026), SABS PVoC programme documentation, NRCS compulsory specifications register. This article reflects the regulatory position as at 30 April 2026 and should not be relied upon as legal advice.