Tax and SARS knowledge base
Excise registration for own-use manufacturing
Does a manufacturer need SARS Excise registration before making excisable goods for its own use?
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Direct answer
Possibly. SARS says relevant entities in South Africa must licence with SARS Excise before starting to manufacture or otherwise deal in products on which applicable Excise Duty or Levy has not yet been paid. SARS's current RLA material also lists a DA 185 annexure for a manufacturer of excisable goods solely for own use.
The practical question is whether the particular product and activity fall within an excise category. Do not assume that making something only for internal consumption removes the need for Excise registration or licensing.
What this means in practice
Excise is not limited to conventional retail sales. SARS describes excise duties and levies as applying to specified products, including categories such as alcohol, tobacco, petroleum products and various levy products. The exact product, tariff treatment, process, premises and whether duty or levy has already been paid can all matter.
For an own-use manufacturer, the first control is classification. The business should map what it makes, what inputs it receives, where production occurs, how the goods are used, whether goods move between premises and whether a licensed third party is involved. This prevents an operations team from treating a Customs or Excise question as a simple internal stock issue.
SARS says Excise registration and licensing activities remain manual. Its RLA page lists the DA 185 form and, for manufacture of excisable goods solely for own use, a DA 185 4A15 annexure. That is evidence of a possible process, not confirmation that every in-house manufacturer uses that annexure or qualifies. Confirm the relevant category with Customs and Excise before activity begins.
Step-by-step
- Describe the product and activity.
Prepare a plain-language product description, ingredients or inputs, process flow, production location, intended use, quantities and movement of the goods. Include technical specifications and photographs where useful. These records support a classification discussion.
- Check whether Excise may apply.
Use current SARS Excise material and obtain specialist classification guidance where there is doubt. Do not rely on how the business labels the product internally. A product's commercial name may not determine its Customs or Excise treatment.
- Confirm the client type and application route.
SARS says Excise registration and licensing is manual and lists DA 185 material. Ask the appropriate SARS Customs and Excise office which registration or licence category, annexure, supporting documents, premises records and security requirements apply to the actual activity.
- Do not start first and regularise later.
SARS says relevant entities must licence before starting to manufacture or otherwise deal in unpaid excisable products. Treat this as a pre-production control. Escalate an uncertain launch date rather than allowing operations to proceed on an assumption.
- Set up records and ownership.
Allocate responsibility for licence conditions, stock records, returns, duty calculations, movements and document retention. Link production records to the product classification and the relevant premises. Include this in the site's compliance calendar.
- Review changes before expanding.
A new product, new premises, increased volume, outsourced production or a different sales route can change the analysis. Review the Customs and Excise position before the change is implemented.
Documents and records to keep
Keep product specifications, flow diagrams, technical data, premises records, correspondence with SARS, DA 185 and any annexures, licence correspondence, production and stock records. Add a file note explaining the classification position and who approved it internally.
Important limits and exceptions
This guide does not decide that a particular product is excisable, identify a tariff heading, determine a duty rate or confirm a registration or licence outcome. Product-specific rules and facts matter. A registration process is not permission to operate until the required approval is effective.
Do not confuse Customs registration for importing or exporting with the separate Excise requirements for manufacturing. A business can need more than one Customs or Excise status.
When to get tailored advice
Obtain specialist Customs and Excise advice before launch where the product may involve alcohol, tobacco, fuel, sugary beverages, environmental levies or another regulated category. Also seek advice where the business makes goods at several sites, uses contract manufacturers or moves goods across borders.
TaxProof can help construct the product and document checklist. We cannot classify the goods, issue a licence or determine a duty liability.