Tax and SARS knowledge base
What evidence supports a customs tariff-classification decision?
What records should an importer keep to support a tariff code?
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Direct answer
A tariff code should be supported by a product-specific record, not just a supplier description or an old broker entry. SARS says commercial import and export commodities must be classified under an appropriate tariff heading on Customs declarations. It also says an importer needs a proper description of goods before import because the tariff code must be inserted on the Customs declaration.
The classification question is about what the goods actually are at importation. Commercial names such as "kit", "part", "sample" or "machine" can be too vague. Keep the product description and the source material used to describe the goods, then review the current tariff wording. SARS says that where goods could fall under two headings or there is no clearly identifiable heading, the importer should approach the local SARS office for a written tariff determination.
What this means in practice
The person entering the declaration needs accurate, stable product information. A supplier may provide a tariff heading, but that is evidence to be evaluated, not a conclusion that binds SARS. A broker may have used a code previously, but an old declaration does not prove that the product, tariff wording, origin treatment or procedure remains the same.
Think of a classification file as a controlled technical record. It should answer:
- What is the product, in observable and technical terms?
- What is it made of and what does it do?
- Which model, version or component configuration is being imported?
- What current tariff wording and interpretive reasoning support the selected heading?
- Does the commercial invoice and declaration describe the same product?
Classification and customs value are separate, although both affect duty exposure. A correct value does not make an incorrect classification acceptable. Preferential origin, import permits, anti-dumping measures, excise treatment and VAT can also require separate assessment. Avoid a single spreadsheet column labelled "tariff" becoming the only record for several distinct Customs decisions.
Step-by-step
- Open a product file before the first import.
Obtain the product description used for procurement and declaration, together with available technical information such as a catalogue, manufacturer data, model details or a supplier specification. Store it against a stable internal product code. The purpose is to be able to demonstrate what the goods are, rather than to create a generic document bundle.
- Check the product against the current tariff material.
Use the current Tariff Book rather than a copied historical rate table. Read the heading, subheading, applicable notes and any procedure or origin conditions that could matter. If the goods could fit more than one heading or no appropriate heading is clear, use the written tariff-determination route described by SARS before relying on an internal conclusion.
- Record the reasoning, not only the code.
Write a short classification note that identifies the product description relied on, current tariff source consulted and any written determination or specialist advice obtained. Link it to the source documents. This makes future review possible if the product changes or SARS asks questions.
- Align suppliers, purchasing and brokers.
Give the broker the reviewed product description and internal product reference, rather than only a purchase-order line. Ask purchasing to alert Customs compliance when the product description, model, set contents or product function changes. Each change can make a prior conclusion unsafe.
- Review each declaration before and after clearance.
Compare the declaration product description, tariff code, quantities and values to the invoice, packing list and product file. Record corrections promptly through the appropriate Customs process. Keep the final entry and assessment as part of the evidence file.
- Maintain a change-control routine.
Re-review classifications whenever the tariff schedule changes, the product is redesigned, components are substituted, bundled goods change or the business changes import procedure. Do not rely on a year-old decision simply because the trade name is unchanged.
Documents and records to keep
Retain the product description, available technical sheets or catalogues, invoices, packing lists, shipping papers, declarations, assessments and broker instructions. Keep the current Tariff Book extract, classification note and any written tariff determination or specialist advice.
The core record is the classification memo, including its date, reviewer, source documents, current tariff extract and assumptions. Keep a change log that identifies when the code was reviewed and why. If the business obtains a formal determination or specialist opinion, file it with its precise scope and effective facts.
Important limits and exceptions
This guide does not classify a product or recommend a tariff code. It does not decide an origin preference, permit requirement, anti-dumping exposure or tax rate. The applicable schedule and facts can change, so the current official material and specialist advice must control a high-risk decision.
Do not describe goods inaccurately to match a desired duty rate. An internal name, supplier code or marketplace listing is not enough where it conflicts with actual product characteristics. Do not treat a Customs clearance outcome as permanent approval for a redesigned or differently configured product.
When to get tailored advice
Get Customs advice before import where the goods are novel, technical, multi-function, bundled, incomplete, related to a controlled industry or exposed to a meaningful duty difference. Get a new review after a product redesign, a supplier or manufacturing change, a tariff amendment or a SARS query.
TaxProof can help assemble the evidence file and check that product, commercial and declaration records agree. We cannot issue a tariff classification or a binding Customs determination.