Pre-Export Certificate of Conformity required for certain unregulated goods imported from China

The Department of Trade, Industry and Competition of South Africa published a Ministerial Directive in March 2026 on the ‘Implementation of a pre-export verification of conformity programme for certain unregulated products imported from the People’s Republic of China’. The programme requires that, from September 2026, certain Chinese imports be accompanied by a Certificate of Conformity (CoC) confirming their compliance with South African National Standards (SANS), primarily on quality and safety.

The Directive was issued in terms of the country’s standardisation and quality control legislation (the Standards Act No.8 of 2008) to promote “consumer protection, safety, and quality assurance”.  The South African Bureau of Standards (SABS), an entity established by the said legislation and a custodian of SANS, is mandated to run conformity assessments in cooperation with its Chinese counterpart, China Certification and Inspection Group (CCIC).  CCIC will conduct physical inspections of the relevant goods in China to ensure compliance with SANS before their shipment to South Africa and issue CoCs.

The programme will apply to a wide spectrum of products across multiple industries, which have been grouped in 25 categories, including cosmetics and skincare products; feminine and hygiene products; automotive components; building and construction materials; plumbing components; solar panels; toys; school supplies; furniture and homeware; and mattresses and foam.

Why Chinese imports? SABS’s publication on the Directive explains that China is the first country to be subject to the programme as “it is South Africa’s largest import partner and represents a significant portion of high-risk consumer goods”.  In addition to the quality and safety objectives, SABS expects the CoC requirements to make notable inroads in tackling the scourge of counterfeit goods originating from China. Infringers may be deterred from exposing their products to assessments; moreover, if non-compliant goods are imported, the CoC programme will be an added mechanism for detecting and seizing those goods before they enter the South African market.

While the main risks of non-compliance are not expressly set out in the Directive, the South African Revenue Service (Customs Division) and the Border Management Authority (BMA) have been tasked with the enforcement of the Directive within the scope of their statutory mandates. The relevant legislation governing customs and border management empowers customs and border control officials to seize and detain goods until required documents are submitted; order the destruction of goods; administer monetary penalties and fines; and pursue criminal prosecution against offenders, among other enforcement actions in cases of non-compliance. Further, according to SABS, relevant products will be flagged by the customs risk management automated system upon arrival in South Africa, and the CoC will be required before shipments are cleared.  Thus, the arrival of non-compliant goods or goods without the required CoC will likely expose the owner to the aforesaid risks, which may ultimately cause significant financial loss.

Businesses that are subject to the Directive, including importers in South Africa and/or exporters in China, are urged to consult the SABS website at www.sabs.co.za for comprehensive information on the products subject to the programme, including the applicable SANS, to ensure compliance.