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Customs Licensing – Importer Exporter Code

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There is so much confusion in industry about “Customs Licensing – Importer Exporter Code”.

At the same time there are so many Customs clients who are in-fact registered, but still not Onboarded to e-Filing.

In this blog we will clarify who must register and when one is required to be registered.

We will also discuss the consequences of not being properly registered with Customs, and also e-Filing challenges.

What is a Code 70707070?

A Code “70707070” or simply Code 70 is a First Time Importer or Exporter Code.

This is a general Customs code which is allowed to be used as a once-off code only. It is used when declaring goods into or out of South Africa.

The Code 70 in essence replaces a registered Customs Code. With this code one may declare goods on a Customs Clearance Declaration without registering at Customs.

Code 70 though is not without its pitfalls. When one uses a Code 70 it means that you do not declare your name or company name to SARS. SARS therefore does not know or understand “who” you are.

The result of this is that many imports or exports becomes automatically queried or stopped for inspection purposes. SARS may verify who you are and what you are importing.

Who is “Not” Required to Register?

The following persons are not required to register or license with SARS Customs:

  1. Natural persons who imports or exports for a total value not exceeding R 150,000.00 during a calendar year in one or more consignments
  2. People who import or export Household or Personal Effects
  3. A person who is not a South African citizen who exports a motor vehicle to a non-SACU country.

These persons may all use the General Customs Code 70.

Anyone not complying with paragraph numbers 1 – 3 must register or license with SARS Customs.

Who Must Register?

Conversely, and to make it clear, the following persons or companies must register or license with SARS Customs:

  1. Anyone who is not a natural person (i.e. a company)
  2. Anyone who imports or exports for commercial purposes or commercial gain
  3. Anyone who’s imports or exports exceed R 150,000.00 over a calendar year, even a natural person (i.e. a boat or vehicle exceeding R 150,000.00)
  4. Anyone who exports scrap metal
  5. Anyone who is involved in other Customs activities such as Rebates, Bond Stores, Trade Agreements, etc.
  6. Anyone who is required to make an advance payment via the APN (Advance Payment Notification) process.

If you are required to register or license with SARS Customs, then please Contact us for a quotation.

We can take allot of pain out of the process. You do not need to re-invent the wheel.

Exemptions from Customs Licensing – Importer Exporter Code

The following persons are exempt from Licensing with SARS Customs:

  1. Persons importing or exporting Human Remains
  2. Goods which in the opinion of the Commissioner for SARS are of no commercial value (i.e. samples which are mutilated or destroyed)
  3. Goods of a value “not” exceeding R 500.00, and on which no export duty is payable.

These persons are allowed to use the so called “Simplified Clearance Declaration” form “DA 306″. These are generally used at ports or airports and do not require any professional assistance.

e-Filing Challenges when Registering or Licensing

Most but not all license types are required to be performed on SARS e-Filing.

But e-Filing is not without its challenges. The following aspects may be problematic during the licensing process and may prevent one from proceeding.

Examples of e-Filing Challenges:

  1. Registered Representative issues
  2. Individual Profile issues
  3. Customs Agent issues
  4. Tax Type Merger issues
  5. APN (Advance Payment Notification) issues
  6. Company Income Tax issues
  7. User Rights issues.

Almost all of these issues can result in one not being able to proceed with the e-Filing application.

One is advised to seek professional help during the licensing or Onboarding process. We find that clients simply do not manage to resolve many of these e-Filing challenges by themselves.

These challenges may take a day or two to resolve. They may even take a month or two if not attended to properly. In some extreme examples one can wait up to 3 – 6 months or even longer to resolve.

Incidentally, Customs clients who are registered but not yet Onboarded to SARS e-Filing have become suspended.

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Consequences of Not Registering or Licensing

Here is a list of consequences of not been properly licensed with SARS Customs:

  • Firstly – one can attract a penalty of R 5,000.00 per incident, i.e. per SAD 500 Clearance Declaration
  • Secondly – Customs will query and stop the consignment for physical inspection, resulting in additional costs and delays
  • Thirdly – Customs can audit your books going two years back and “Schedule” you for past contraventions.

Types of Customs Licenses

See our Services page under RLA (Licensing, Registration & Accreditation) for information about the types of licenses.

Contact Us

Please Contact us for advice or a quotation for Customs Licensing and Registrations.

We will help you with:

  1. Application Process and e-Filing Procedures
  2. Supporting Documents and Templates
  3. Overcoming any e-Filing challenges.

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SARS Customs AEO Accreditation

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The Customs AEO (Authorised Economic Operator) Accreditation is better than its predecessor, the PTA (Preferred Trader Accreditation) Program.

  1. The AEO offers real tangible benefits
  2. With a little help, the Application Process is simpler, and
  3. The Audit Requirements are less stringent than before.

Also, the AEO Accreditation takes into account one’s relative company size during the vetting process. For example, even SMME’s now qualify to apply.

Smaller companies do not need a team of qualified corporate governance officers to draw-up highfalutin policies to prove compliance. Off-course, one does within reason, to demonstrate some level of compliance to the Customs legislation.

How to Demonstrate Compliance

  1. Supply of Standard Operating Procedures
  2. Proof of Financials and a Good Financial Track Record
  3. Passing the Customs CSK (Sufficient Knowledge Test).

There are two Levels of AEO Accreditation

Level 1 – Compliance

Level 1 has to do with one’s Record of Compliance, Logistical Systems, Sufficient Knowledge, Financial Resources and Domestic Taxes. This level may be viewed as internally focused.

Level 2 – Safety and Security

Level 2 builds on Level 1 Accreditation. In addition, it focuses on:

  • Security of Buildings and Premises
  • Business Partner Security
  • Crises Management and Recovery
  • Information and Confidentiality
  • Personnel Security
  • Cargo Security
  • Education and Training
  • Communication with SARS, and
  • Good Corporate Governance.

This level may be viewed as both internally and externally focused.

The Benefits of AEO Accreditation

There are varying benefits between Level 1 and Level 2 Accreditation. The below listed benefits are a consolidation of the primary benefits for both Levels 1 and 2.

Benefits Include:

  1. Access to a Customs Client Relationship Manager
  2. Prioritisation of Applications (Licensing and Clearance Related)
  3. Reduced Security Amounts (i.e. Guarantees for Bond Stores, Rebate Stores, and Deferment Accounts)
  4. Reduced Inspections and the ability to Inspect Cargo at Premises (i.e. Embargo’s).

The Customs AEO Accreditation is a far better instrument for Trade Facilitation than its predecessors.

The benefits are far reaching. They will help Importers, Exporters, Customs Clearing Agents and Transporters to expedite Customs formalities, and to reduce costs.

Contact Us

Please Contact us for advice or a quotation for the Customs AEO Accreditation.

We will help you with:

  1. Application Process and e-Filing Procedures
  2. Supporting Documents and Templates
  3. Compliance Verification Requirements and Guidance
  4. Preparation for the CSK (Customs Sufficient Knowledge) Test.

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Customs Licensing Deadline – 31 March 2023

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Did you know that the Customs licensing “renewal” deadline is 31 March 2023?

All Customs clients must re-register or migrate to Customs e-Filing, on time.

This is not merely an update of information. This is a complete re-registration of each license type to e-Filing.

How to License before the Customs Licensing Deadline – 31 March 2023

We assist all Importers, Exporter, Customs Clearing Agents, and Transporters in South Africa with Customs licensing.

Our qualified Customs Tax Practitioner knows how to overcome Customs Licensing and e-Filing challenges.

In a recent notice to trade, SARS indicated that Customs licenses not renewed on time will be canceled (end 2024).

Do you need our assistance?

Or do you have a client who may need our assistance?

Because of our vast experience and qualifications in this field, we have the means to facilitate this frustrating process.

You are welcome e-mail us, or set-up a Teams call to discuss your license requirements with us.  

License Types

We provide the following Customs Licensing and Registrations, and more:

  1. Importer Exporter Code
  2. Bond Store Registration
  3. Rebate Manufacturing Store
  4. Clearing Agents License
  5. Deferment Accounts
  6. Dual EDI Registration
  7. Remover of Goods in Bond
  8. Road Consignor Bond
  9. Drawback Registrations
  10. Name Changes & Updates, Bond Changes
  11. Foreign Registered Entities
  12. Trade Agreement Registrations
  13. Excise Rebate Manufacturing Stores
  14. Migration to e-Filing and Re-Registrations
  15. e-Filing Relationship Management, and
  16. RCG (Reporting and Conveyance of Goods).

Contact Us

Please Contact us for advice or a quotation.

We can help you with:

  1. Application Process and e-Filing Procedures
  2. Supporting Documents and Templates
  3. Overcoming any e-Filing challenges
  4. Excise Rebate and Manufacturing Applications.

Excise applications may include wine and fermented beverages, spirits, perfumes and similar products.

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Customs Rebate Manufacturing Stores

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Reduce your import duty and VAT costs with a Customs Rebate Manufacturing Store.

That’s right, reduce or completely rebate your import Customs duties by registering a Customs Rebate Manufacturing Store. You may never have to pay import duties again.

The requirements for managing a Rebate Manufacturing Store are not so difficult, provided you understand some basic criteria.

For example, you need to understand:

  1. How to qualify for a Rebate of duties
  2. What is required to manage a Rebate Store, and
  3. If there are any Permits required.

We specialise in identifying opportunities for Importers to qualify for Rebates of duty.

More About Customs Rebate Manufacturing Stores

A Rebate Manufacturing Store is a Customs facility designed to “permanently rebate” the full or partial import duties.

In some cases, taxes (such as VAT) may also be “exempted” at time of importation. This would apply for companies who import, manufacture, and re-export goods.

The physical store must be owned and situated on the import manufacturers premises.

Once imported, the goods are stored in the Rebate Store. Thereafter they may be dispatched into production. The liability for duties (and taxes, if applicable) generally ends when manufacturing ends. In some cases, the liability for duties and taxes ends when goods become re-exported.

Goods may also be transferred between rebate stores when selling imported stock to third party manufacturers.

Outsourcing or subcontracting the manufacturing process is possible provided one obtains permission from SARS Customs.

Types of Customs Rebate Manufacturing Stores

Broadly speaking, there are two types of Rebate facilities available:

Industrial Rebates

These are designed for specific purposes for example, for local distribution of goods after manufacture. Goods may also be re-exported.

General Rebates

These are designed for a multitude of purposes and circumstances. Many of these require the imported goods to be manufactured and re-exported to qualify for a rebate of duties.

Physical Store Requirements

The physical store requirements are largely about good governance, for example:

  • Clean and tidy, no “stuff” lying around
  • Stock clearly marked
  • Stock packed well in proper bays
  • Provision for quarantine areas (i.e. broken or damaged stock)
  • Health and safety, fire hydrants and fire extinguishers
  • Security (i.e. armed response, CCTV), and so forth.

ITAC Permits

In some cases, a Rebate Facility requires a permit to be issued by ITAC before the commencement of production.

While some rebate provisions require a permit for specific products, most do not require a permit.

Time Periods

Goods may be stored in a Rebate Manufacturing Store for up to two years.

If one has not manufactured within this time frame, then one is compelled to bring duties and taxes to account.

Extensions of the two-year period are allowed, provided one applies in advance of the expiry date.

Contact Us

Please Contact us for advice or a quotation for a Customs Rebate Manufacturing Store.

We will help you with:

  1. Qualification of Import Goods for Rebate Purposes
  2. Application Process and the Customs Inspection
  3. Supporting Documents and Guidelines
  4. Permit Applications (if applicable).

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Customs Licensing – e-Filing Relationship Management

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Did you know… SARS Customs intends to manage the Customs supply chain (in part) through e-Filing? Correct, they intend to do so via the “Relationship Management” portal on e-Filing.

  • What does this mean?
  • Why are they doing this?
  • How will it impact you?
  • When will it become enforced?

e-Filing “Relationship Management”

Firstly, lets understand the concept. “Relationship Management” on the SARS Customs e-Filing portal requires that all clients to become linked to the Clearing Agent.

Similarly, ‘clients’ of other Customs license types too will become linked on the e-Filing system, i.e. ‘clients’ of Bonded Warehouses, Removers of Goods in Bond, Customs Licensed Depots, and so forth.

As an importer or exporter of goods, you must be linked to all of your Logistics Service Providers on e-Filing.

Examples include:

  • Customs Clearing Agents
  • Bonded Warehouses
  • Removers of Goods in Bond
  • Customs Licensed Depots
  • And so forth.

Soon, you will not be allowed to trade with Customs if you are not linked to a Logistics Service Provider.

Similarly, Logistics Service Providers will not be allowed to trade through Customs if they are not linked to their clients.

The onus will be on the Logistics Service Provider to link or invite their clients.

‘Clients’ of Logistics Service Providers will need to accept the “linkage” invitation from the Logistics Service Provider. This is a pre-requisite for the link to become active.

Rational of Customs “Relationship Management”?

“A rotten apple in the Customs supply chain is likely to lead to another rotten apple in the same chain.”

In other words, a company linked to a dishonest entity may become suspected of being a dishonest role player. Therefore, Relationship management is a a risk management tool.

The concept of Customs supply chain Risk Management stems from Global Customs Supply Chain policy. Global policy instruments were developed as a result of the September 2011 attacks on the US. One policy instruments is the SAFE Framework of Standards. Another is the Revised Kyoto Convention. They contain a strong element of Customs supply chain security.

Global Customs policy is created by the World Customs Organisation and the World Trade Organisation, to mention a few.

Linked to this are the various Customs Accreditation models adopted around the world. Examples include:

  • PTA (Preferred Trader Accreditation) (South Africa)
  • AEO (Authorised Economic Operator) (Europe, Africa and now South Africa)
  • CTPAT (Customs Trade Partnership Against Terrorism) (United States).

When will it become Enforced?

The first 100 Customs Clearing Agents were requested the start the process in 2022. Initially, the requirement to link will be a ‘soft’ approach requested by SARS. In time to come, one will become legally obligated to do so.

Migration and Linking is taking place in a staggered approach:

  • Firstly, Clearing Agents are being requested to migrate to the e-Filing platform
  • Secondly, Clearing Agents must “link” to their clients. Off-course, client acceptance on e-Filing is required
  • Thirdly, Importers, Exporters and Other Client Types will be requested to migrate to e-Filing
  • Fourthly, linking will at some point in the future become a legal obligation.

Please Contact Us

Please Contact us for advice or a quotation for Customs Licensing.

  1. Tax Type Mergers
  2. Access Permissions and Rights Issues
  3. APN (Advance Payment Notification)
  4. Registration of Registered Representatives.

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