Customs Licensing – Importer Exporter Code

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.

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.

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.

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.

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.

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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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.

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

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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Customs Licensing – e-Filing Relationship Management

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 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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Customs Licensing – Migration to e-Filing

Did you know… SARS Customs e-Filing Migration has Begun? SARS Customs have begun the process to migrate existing clients to e-Filing.

New Customs clients can be registered by Customs Tax Practitioners directly on e-Filing. Practitioners can also re-register existing clients on e-Filing.

Migration to e-Filing

SARS Customs e-Filing migration can be described as a re-registration of an existing client on e-Filing.

The re-registration is similar to a new application. Therefore, all documents must be supplied as-if one is applying for a new license.

All documents submitted must be fresh, i.e. they must not be outdated.

Migration is taking place in a staggered approach:

  • Firstly, Clearing Agents are being requested to migrate
  • 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.

License and Registration Types

Here is a list of the Major Customs Licensing and Registration types:

  1. Importer Exporter Code
  2. Bond Store Registration
  3. Rebate Manufacturing Store
  4. Clearing Agents License
  5. Deferment Accounts
  6. Remover of Goods in Bond
  7. Customs Road Consignor Bond
  8. Drawbacks of Duty Registration
  1. Company Name Change
  2. Foreign Registered Entities
  3. Trade Agreement Registrations
  4. Excise Rebate Manufacturing Stores
  5. Migration to e-Filing and Re-Registrations
  6. e-Filing Relationship Management, and
  7. RCG (Reporting and Conveyance of Goods).

Not all of these License and Registration types are on e-Filing.

Our Consultant and Managing Director, Graeme Lennie is a SARS Registered Customs Tax Practitioner.

We therefore have the unique ability to manage and submit SARS e-Filing registrations with approval from our clients.

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.

← Back

Thank you for your response. ✨