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Understanding SARS’s New Diesel Refund System: Essential Q&A for Users and Sellers

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SARS has officially launched its new Diesel Refund System. This marks a major shift away from the old VAT-linked framework.

The new digital registration and relationship management portal is now live on e-Filing. Qualifying businesses must now re-register on this standalone platform.

Clients have been given an interim period to complete this registration and licensing process. This window allows businesses to onboard their profiles and set up supplier linkages.

Taking action now ensures that Users and Sellers are fully prepared for the next phases of implementation and ready for the claims go-live in 2027.

To help you to navigate these changes smoothly, we have put together a practical Q&A guide. It covers key registration rules, seller compliance, relationship links, and important operational milestones leading up to 2027.

Diesel Refund Users

QUESTION 1: Is the migration to the new Diesel Refund System automatic for existing users?

  • Answer: No. SARS has confirmed there is no automatic data migration from the old VAT-linked model. All existing diesel refund users must actively re-register on the new standalone digital platform via SARS e-Filing.

QUESTION 2: When did registration open, and what platform is used?

  • Answer: Registration officially opened on 18 September 2026. It is processed through a dedicated Diesel Refund Registration System interface on SARS e-Filing, separating it entirely from traditional VAT registrations.

QUESTION 3: Who is eligible to register as a Diesel Refund User under the modernised framework?

  • Answer: Any entity that purchases and uses diesel to conduct qualifying activities (such as primary farming, forestry, commercial mining, or offshore / onshore coastal shipping, as well as qualifying “wet contractors”) can register.

QUESTION 4: Can an entity register as both a Diesel Refund User and a Diesel Seller?

  • Answer: No. SARS regulations require a clear separation of roles; an entity cannot hold both User and Seller statuses under the same profile registration.

QUESTION 5: Must every location where primary activities take place be registered?

  • Answer: Yes, every location where primary activities (i.e. where farming takes place) must be fully registered against the User registration / license. In other words, you can have one license with multiple locations.

Diesel Refund Sellers

QUESTION 1: Must diesel sellers and fuel suppliers also register with SARS?

  • Answer: Yes. Fuel suppliers and diesel sellers are legally required to register on the new system.

QUESTION 2: Why is Seller registration critical for refund Users?

  • Answer: If a diesel User purchases fuel from an unregistered Seller, the associated diesel refund will not be processed or allowed. Users must ensure their suppliers are fully registered so that electronic supply chain validation can take place.

QUESTION 3: Must every location where Diesel is dispensed from be registered?

  • Answer: Yes, every location where Diesel is dispensed from (i.e. Depots or Tank Farms) must be fully registered against the Seller registration / license.

Relationship Linkage and Disclosures

QUESTION 1: What is the purpose of the Diesel Refund Relationship Management function?

  • Answer: Implemented on e-Filing alongside the registration portal, this function allows clients to formally declare, manage, and maintain operational relationships linked to their diesel profiles (i.e. User-to-Seller connections).

QUESTION 2: How do buyers link themselves to their respective fuel suppliers?

  • Answer: Once both the User and the diesel Seller are successfully registered on e-Filing, the user must establish and validate the relationship with that specific registered seller electronically.

Registration of Assets (Tractors, Tanks, etc.) and 2027 Go-Live

QUESTION 1: How does the current 2026 registration phase relate to the 2027 asset registration and claims go-live?

  • Answer: The 2026 rollout focuses strictly on foundational profiling, digital User / Seller onboarding, and relationship mapping. The upcoming phases, including granular asset-level tracking (such as tractors, storage tanks, and primary equipment) and the standalone claims platform are scheduled to roll out toward the 2027 go-live.

QUESTION 2: Do clients need to register individual assets (like machinery or bulk tanks) right now?

  • Answer: No, not yet. Asset-specific configuration and registration requirements are aligned with the subsequent implementation phases leading into 2027. However, clients should start compiling comprehensive asset registers and usage logbooks ‘now’ to prepare.

QUESTION 3: How are diesel refund claims handled in the interim period before the 2027 full claims go-live?

  • Answer: Despite the shift of registrations to the standalone e-Filing platform, the actual submission of diesel refund claims continues to be administered through the standard VAT system via the VAT201 return on e-Filing until the full claims module goes live.

Final Considerations

QUESTION 1: What preliminary steps should Users and Sellers take immediately to prevent compliance bottlenecks?

  • Answer: Clients should:
    1. Contact The Customs Hub for a quotation for a smooth transition to the new e-Filing platform. We understand all the documentation requirements and know how to configure the e-Filing setup.
    2. Verify that all your diesel Suppliers are actively registering or already registered on the new system. Contact The Customs Hub should you require assistance with Supplier linking. 
    3. You can also discover more information about this at our Diesel Licensing page.

Contact Us

Ensure that your e-Filing profile is updated early to avoid disruptions to your cash flow.

We can help you with the following Diesel Refund Licensing Activities:
  1. Onboarding to e-Filing for Existing clients
  2. Application on e-Filing for New clients
  3. Supporting Documents and Requirements
  4. Registration of Facilities (i.e. Tanks) and Machinery (i.e. Tractors, Trucks, Vessels, etc.)
  5. Overcome Technical e-Filing challenges.

Contact us directly at this link, or submit the form below.

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Navigating Customs Rebates of Duties for Constrained Industries: A Strategic Guide for Importers and Manufacturers

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Navigating the complexities of South African Customs legislation often requires looking beyond standard tariff books.

For importers, manufacturers, and industrial consumers facing rising duties, Customs rebates of duties serve as a crucial relief valve.

Specifically, Rebate Item 460 provides temporary or specific Customs duty rebates on goods imported. These are designed to address critical supply constraints, structural shortages, or mitigating pressures from protective trade measures.

Many of these provisions require a specialised permit issued by ITAC (International Trade Administration Commission). Below, we explore the operational mechanics of these provisions, highlight key industrial sectors and product examples. We also explain how The Customs Hub can assist your business in unlocking these strategic cost-saving opportunities.

How Rebate Item 460 and ITAC Permits Operate

Rebate Item 460 is not a blanket exemption; it is tightly regulated and conditional. The operational framework functions through a collaborative process between two key state bodies. ITAC evaluates the economic justification and issues the permit. SARS Customs administers the entry of goods and applies the duty reduction upon presentation of valid credentials.

  1. The “Not Made in South Africa” Principle: To qualify, applicants must demonstrate that the product is not made in South Africa. Also, local production volumes must be inadequate to meet local market demand.
  2. The Application Process:
    1. Importers must be duly registered with SARS.
    2. An application detailing the precise product specifications, tariff subheadings, quantities, and justification must be submitted to ITAC.
    3. Once approved, ITAC issues a time-bound, quantity-restricted permit.
    4. At the time of import declaration, this permit is cross-referenced by SARS on the Bill of Entry, allowing the goods to enter at the rebated rate of duty rather than the standard rate.

With recent increases in Customs duties on steel and components, for example, these mechanisms are more critical than ever.

Key Industries and Product Examples

Here are eight distinct product types and industries that can benefit or have in the past benefited:

  1. Tyres (Specialised & Agricultural / Industrial): Tyres for agricultural or forestry vehicles and machines frequently face high protective duties. Item 460 mechanisms can provide relief when specific dimensions or tread patterns are unavailable locally.
  2. Solar Panels and Renewable Energy Components: Specific components utilised in renewable energy infrastructure have occasionally benefitted.
  3. Primary Steel and Specialised Alloy Profiles: Downstream manufacturers may benefit. These include unique structural steel grades, high-specification plates, or specialised profils.
  4. Chemical Precursors and Industrial Solvents: Chemical compounders frequently petition for temporary relief under Item 460.
  5. Automotive Components and Specialised Sub-Assemblies: Vehicle assemblers and Tier-1 / Tier-2 component manufacturers leverage specific temporary rebates.
  6. Mining Machinery and Specialised Drilling Implements: Heavy industrial and mining operations can target specific duty-reduction provisions.
  7. Packaging and Specialised Polymer Resins: Industrial packaging converters of specific food-grade or heavy-duty polymer resins look to ITAC-backed reliefs.
  8. Textile Inputs (Non-Agricultural Technical Yarns & Fabrics): Specialised technical fabrics intended for industrial or safety engineering applications benefit.

Minimal SARS Red Tape Compared to Other Rebate Provisions

One of the most attractive commercial features of Item 460 rebates is operational agility.

Unlike establishing a full-scale Customs and Excise Manufacturing Warehouse, many Rebate Item 460 provisions do not require physical facility licensing at SARS.

Because the relief is tied directly to the import transaction via an ITAC permit rather than long-term in-house bonded storage:

  1. You avoid warehouse accounting controls.
  2. The compliance burden shifts to documentation, permit quantity reconciliation, and end-use tracking.
  3. Importers can seamlessly clear goods through standard commercial channels.

Contact Us

Identifying an opportunity under Schedule 4 is only half the battle.

Successfully navigating technical questionnaires, proving local non-availability, and reconciling permit balances requires expertise.

Our expert team assists clients by:

  1. Identifying Opportunities: Analysing your bill of materials and tariff subheadings to pinpoint potential duty-saving reliefs.
  2. Managing Requirements & Objections: Preparing watertight technical justifications and liaising directly with ITAC stakeholders.
  3. Executing Applications: Handling the end-to-end ITAC permit application process and aligning your SARS registration profiles for seamless execution.

Contact us directly at this link or submit the form below.

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Customs Licensing – Foreign Registered Entities

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The concept of Customs Licensing – Foreign Registered Entities may seem daunting at first.

In this blog we aim clarify who (and the naming of each) the parties involved in an Agency Agreement (i.e. Foreign Representation) are, the types of licenses, nomination, legal implications and responsibilities, and VAT implications.

First, the concept of an Agency Agreement is different from that of a Customs Clearing Agent.

Agency Agreement and the Parties Involved

Here is a detailed explanation:

  • A Customs Clearing Agent is a company who performs, amongst other things, import and export clearance declarations. These are performed on behalf of an importer or exporter. This must not be confused with a Registered Agent (discussed hereafter)
  • An Agency Agreement in the context of Customs is where a Local Entity represents a Foreign Entity. The Local Entity is the Registered Agent or Agency
    • The Local Entity must register with SARS Customs as a Registered Agent. They represent a Foreign Entity
    • The Foreign Entity must register with SARS Customs as a Foreign Registered Entity. They are represented by a Registered Agent.
  • A Registered Agent may be any locally registered company or private individual with a South Africa residency. It may include for example an Importer, Exporter, Customs Clearing Agent, Road Transporter, etc.

Therefore, a Customs Clearing Agent may, in addition to being a Licensed Clearing Agent, also be a Registered Agent. These are two separate Licenses / Registrations.

Nomination of a Registered Agent

A Foreign Registered Entity may be represented by multiple Registered Agents. They may also be represented by multiple types of Registered Agents.

Before any Customs business may be transacted between the parties, the Foreign Registered Entity must “Nominate” the Registered Agent. This will allow transactional business between the parties to be legally transacted. This will allow SARS e-Filing System, and the SARS Customs EDI Clearance Declaration System to work effectively.

The licensing and nomination procedures are somewhat complex. One must pursue these in a particular sequence together with the correct documentation to avoid disappointment.

Consult with us for the correct license categories, types, and e-Filing procedures for Foreign Entities.

Types of Customs Licensing – Foreign Registered Entities

There are five SARS Customs types of licenses which one may qualify for in an Agency Agreement.

Types of Licenses:

  1. Importer
  2. Exporter
  3. ROG (Remover of Goods in Bond)
  4. Carriers for Sea, Air, Road or Own Goods Carrier. This falls into the category of RCG (Reporting and Conveyance of Goods)
  5. Searchers for a Wreck.

Please visit our RLA (Registration, Licensing and Accreditation) page for more information.

Simply put, the local entity, namely the Registered Agent legally puts themselves into the shoes of the Foreign Registered Entity.

The Registered Agent thus assumes all roles, responsibilities, legal liability and compliance of the Foreign Registered Entity.

The Foreign Entity may also be termed, the Foreign Principal by the authorities.

Please be sure to pursue a clearly defined contractual agreement between the parties when entering into any Agency Agreement.

The Registered Agent may thus conclude contractual obligations on behalf of their Foreign Principal with SARS Customs.

These may include for example:

  • Submitting (via a Clearing Agent, or as a Clearing Agent), all import or export clearance declarations, refunds and drawbacks
  • Setting up Deferment Accounts for the payment of Duties and Taxes with SARS Customs. This includes setting up of a Bond or Bonds for the Deferment Facility
  • Setting up a Bond or Bonds as a Remover of Goods in Bond
  • Issuing transport documents and reporting for RCG (Reporting and Conveyance of Goods).

VAT Implications

Each company and each scenario are somewhat different from another.

Once is best advised to seek the advice of a properly registered and qualified Tax Practitioner. Someone who specialises in Cross Border VAT issues.

Please Contact us if you require the expertise of a Specialist Cross Border VAT Consultant.

Contact Us

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

We will help you with:

  1. Understanding the specific solutions required in the context of an Agency Agreement
  2. Application Process and e-Filing Procedures
  3. Supporting Documents and Templates
  4. Overcoming any e-Filing challenges.

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Customs Licensing – Trade Agreements

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Both importers and exporters can benefit from Customs Licensing – Trade Agreements.

Importers benefit from rates of duty which are lower than the General rates of duties at time of import.

Exporters benefit by positioning themselves as preferred suppliers for goods imported at destination countries. The benefits are import duties at lower rates.

While exporters from South African need to register for a Trade Agreement, importers into South Africa can benefit without registration. Importers merely need to produce the proof of origin to qualify.

This all seems fairly simplistic. In this blog we provide clarity on the inner workings of the ROO (Rules of Origin) and Trade Agreements.

Origin of Goods

But first, SARS Customs requires that the origin of the goods must be supplied or proven.

The origin of goods in this context is a separate issue from origin for Trade Agreements.

When it comes to “Origin”, the question simply is… “where do the goods come from?

The origin is understood from the Customs Act to be as follows.

Origin in the Customs Act

What is required?

  1. 25% of the materials produced or labor performed must be in that territory
  2. The last process in the production or manufacture of those goods must have taken place in that territory, or
  3. As otherwise determined by ITAC (International Trade Administration Commission) in respect of certain goods.

Why is the Origin of Goods Important?

The Origin of Goods is Important to Determine the following aspects:

  1. MFN (Most-Favored-Nation treatment) (i.e. for duty and non-duty benefits)
  2. Anti-dumping duties
  3. Safeguard measures
  4. Origin for physical marking requirements
  5. Trade statistics
  6. Import and export restrictions from specific countries, and
  7. Countervailing duties.

Proofs of Origin

Origin is normally proven by the supplier. The supplier must endorse the Commercial Invoice with the origin of the goods on it.

Certificates of Origin may also be supplied. These are normally issued by Chambers of Commerce, Government Departments or Statutory Bodies.

Where different rates of duty apply to goods originating from different territories or the extent of rebates under Schedule No. 3 (Industrial Rebates) is affected by the origin of the goods, then a COO (Certificate of Origin) must be produced.

Trade Agreements

A Reciprocal Trade Agreement means that the benefit of duty reductions flows in both directions. I.e., an agreement between South African and the European Union means that duties may be reduced in both countries.

A Non-Reciprocal Trade Agreement means that the benefit flows in one direction only. This is most prevalent when an MFN (Most Favored Nation) statis is conferred from one country to another. This is also known as a GSP (General System of Preferences).

The SACU (Southern African Customs Union) on the other hand is a Customs Union. Duties between the BELN (South Africa, Botswana, Eswatini – better known as Lesotho, and Namibia) are Free. There are also other dispensations and co-operative arrangements between Members States.

Reciprocal Trade Agreements in South Africa

These include for example:

  1. SADC (Southern African Development Community) – including about 15 countries in Africa and some adjacent islands
  2. EU (European Union) – South Africa and the EU States
  3. SACUM-UK (United Kingdom) – Southern African Customs Union, Mozambique and the United Kingdom
  4. EFTA (European Free Trade Area) – Iceland, Liechtenstein, Norway and Switzerland
  5. MERCOSUR (Common Market for the South) – Argentina, Brazil, Paraguay and Uruguay
  6. AfCFTA (African Continental Free Trade Area) – Most African Countries with the potential of being the largest in the world.

It is not uncommon for an importer under a Trade Agreement to by as much as 20% or more.

Non-Reciprocal Trade Agreements in South Africa

These include for example the GSPs (Gernal System of Preferences) with Norway, Turkey and Russia.

The AGOA (African Growth and Opportunity Act) is a legislation created in America. It is a MFN (Most Favored Nation) status is conferred onto African territories, including South Africa. Imports into America from South Africa may attract lower rates of duties.

Customs Licensing – Trade Agreements

Any exporter of goods from South African must license as an Exporter under each Trade Agreement to which it subscribes.

An exporter who is a Manufacturer of goods must also license as a Producer of goods. To be clear, an exporter who is also a manufacturer of goods must license for both, i.e. an Exporter and a Producer under each Trade Agreement. This entails two separate license applications and hence a separate license approval for each Trade Agreement.

I have seen too many Exporters, and their Consignees penalised by Customs. One must ensure full and proper registration.

Exporters who have not on-boarded to e-Filing yet must do so urgently to avoid becoming suspended. Suspensions are anticipated to take effect in mid to late 2024. Visit our RLA (Registration, Licensing and Accreditation) page for more information.

Contact Us

Please Contact us for advice or a quotation for Customs Licensing – Trade Agreements.

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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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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