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Completing the various registration forms
Assistance with completing the registration forms
We at ExportHelp have tried to provide you with some assistance to help with completing the various SARS/Customs and Excise forms for registration as an exporter. Completing the forms is rather easy and in most cases, self-explanatory. The realy difficulty was identifying which forms to complete and the SARS documentation is as clear as mud about this! Nevertheless, we hope you find the following informaiton useful.
Completing form DA 185
This is the primary form that you need to complete in order to register as a client of SARS/Customs and Excise. Once you have submitted this form, Customs and Excise will register you and issue you with a customs client number. You will use this customs client number in all future correspondence and transactions with SARS/Customs and Excise.
Form DA 185 is not complicated and requires you to enter information that you should have readily available. Obviously, if you are an individual, then you would ignore the questions to do with companies/closed corporations/trusts, etc. The only 'complicated' section is the section entitled '4. CLIENT TYPES'.
If you plan to register as an exporter, then under the heading '4. CLIENT TYPES' and column '4.A REGISTRATION', you would tick the second item, namely: '4A2. Exporter: (Annexure DA 185.4A2)'. This is applicable to ALL exporters. If you do NOT plan to export under the AGOA, TDCA, SADC, SACU/EFTA or GSP agreements, then this is the only box you need to tick. On the other hand, if you plan to export under any of the above agreements, then you need to tick (one or more) of the corresponding tick-boxes. Ignore column '4.B LICENSING.'
If you plan to register as a manufacturer, then under the heading '4. CLIENT TYPES' and column '4.A REGISTRATION', you would also tick the fourth item, namely: '4A4. Manufacturer - Annexure DA 185.4A4 & DA 46A1.03 (Section 46)'. This is necessary even if you do not intend to export directly (for example, you plan to export through an export agent). It is also required in terms of exports under the AGOA agreement.
If you plan to register as a producer, then under the heading '4. CLIENT TYPES' and column '4.A REGISTRATION', you would also tick the seventh item, namely: '4A7. Producer - Annexure DA 185.4A7 & Form DA 46A.02 (rules 46A2.18)'. This is necessary even if you do not intend to export directly (for example, you plan to export through an export agent). It is also required in terms of exports under the GSP agreements.
Of course, you may want to register with SARS/Customs and Excise as one of their many other client types. You should tick the appropriate boxes now. This discussion, however, is only aimed at those wanting to register as exporters (including manufacturers and producers).
The form is an online PDF document. This means that you can either print it, complete it by hand, and fax it to SARS, or drop it off, or you can complete the form online. If you complete the form online, however, you cannot save the form with the information therein; you can only print it and similarly fax it or drop it off.
You can use this same form to amend any information you have submitted in the past that might have changed.
Once you have completed form DA 185, you will ALSO need to complete form DA 185.4A2 to register as an exporter; form DA 185.4A4 to register as a manufacturer; and form DA 185 4A7 to register as a producer. These forms have sub-sections to them that you may also be required to complete.
Downloading form DA 185 (PDF)
Completing form DA 185.4A2
Form DA 185.4A2 is slightly more complicated, but only because it requires you to indicate whether you are exporting in terms of one the following trade agreements, namely:
- AGOA (African Growth and Opportunity Act - a US law that seeks to provide African countries in sub-Saharan Africa with duty-free preference into the US market for a range of products, provided certain conditions related to governance, labour and rules of origin are adhered to)
- SADC (trade agreement between South African Development Community member states)
- TDCA (Trade Development and Cooperation Agreement with the European Community)
- SACU/EFTA (the South African Customs Union agreement with the European Foreign Trade Area), or
- GSP (Generalised System of Preferences with the EU, Norway, Switzerland, Russia or Turkey)
Assuming you are NOT exporting under the terms of one of these above-mentioned agreements, then you would simply place a cross in the 'Other exporter' check box that appears approximately in the middle of the front page (on the right-hand side) and leave the other check-boxes blank.
If you ARE exporting under the terms of one of these trade agreements, then you should indicate under which agreement you wish to register. There are additional sections ATTACHED to form DA 185.4A2 (as Sections A, B, C) that you will need to complete:
- AGOA - Complete Section A (also referred to as form DA 46A1.02)
- Approved Exporter Status EC/SA Free Trade Agreement - Complete Section B (also referred to as form DA 49A.02)
- GSP with EU, Norway, Switzerland, Russia or Turkey - Complete Section C (also referred to as form DA 46A.01)
Furthermore, in terms of some of these agreements, ADDITIONAL forms need to be completed. These are:
- AGOA - If you are a manufacturer, complete forms DA 185.4A4 and DA 46A1.03 (this last-mentioned form is PART of form DA 185.4A4) - see below
- GSP - If you are a producer, complete forms DA 185.4A7 and DA 46A.02 (this last-mentioned form is part of form DA 185.4A7) - see below
The rest of the required information on form DA 185.4A2 is self-explanatory. Note, that you will be required to support your application with copies of registration of business documents, proof of address, ID documents, etc.
Download form DA185.4A2 (PDF)
Completing form DA 46A1.02 - Exporter registration in respect of AGOA
This is a special form required ONLY for exporters applying for registration within the terms of the AGOA agreement. It is attached to form DA 185.4A2 as Section A.
This self-explanatory form is very simple and is really a more of a declaration stating that you agree to comply with the requirements of the AGOA agreement. It requires no special explanation.
Completing form DA 49A.02 - Approved Exporter Status for TDCA
This is a special form required ONLY for exporters applying for 'exporter status' in terms of Article 20 of the Trade, Development and Cooperation Agreement (TDCA) between the European Community and SA. It is attached to form DA 185.4A2 as Section B.
In this two-page form, you are required to answer a number of questions that really only you will know how to answer. There are two questions which may be a bit confusing; these deal with:
- 4-digit tariff headings - this refers to the Harmonised System (HS)
- conditions of origin criteria - this refers to the country of origin requirements that you will need to meet in terms of this agreement
Completing form DA 46A.01 - Exporter registration in respect of GSPs
This is a special form required ONLY for exporters applying for registration in respect of the GSP agreements with the European Community, Norway, Switzerland, Russia and Turkey. These agreements allow for preferential tariff treatment for selected SA goods to these markets.
Once again, this is a simple form to complete. You only need to indicate which country you will be exporting to and then make a basic declaration to abide by the rules of the agreement. The one-page form is self-explanatory.
Completing form DA 185.4A4 - Client type: Manufacturer
Customs and Excise make a distinction between an exporter and a manufacturer. Although many exporters are probably also manufacturers and many manufacturers may be exporters, it is possible to be an exporter but not a manufacturer (consider the case of an export agent or an exporter of services), or a manufacturer that does not export or does not export directly (perhaps your company imports only, or exports via a third-party such as an export agent).
For this reason, Customs and Excise have two separate registration categories ('client type 4A2 - exporter' and 'client type 4A4 - manufacturer' - in fact they have several other client types - see 'registration as a producer' below - but these two are important from our exporting point-of-view), and it is recommended that you register for both categories if both apply to you. If they don't then apply for the category (client type) that is appropriate to you (in fact, if you are currently a manufacturer but don't export directly, we suggest that you still register as an exporter with Customs and Excise as a matter of course).
This one page form (DA 185.4A4) is very simple to complete and the required information is self-explanatory. Note, that you will be asked to support your application with copies of registration of business documents, proof of address, ID documents, etc.
Attached to form DA 185.4A4 is a second-page entitled 'Section A - African Growth and Opportunity Act' (form DA 46A1.03). This page you do not have to complete if you are registering with SARS/Customs and Excise generally as a manufacturer. If, however, you intend to take advantage of the AGOA agreement, then you also need to complete this form in addition to form DA 185.4A4 - see the next section.
Download form DA185.4A4 (PDF)
Completing form DA 46A1.03 - Registration as a manufacturer for the purposes of AGOA
If you a manufacturer AND you plan to export to the US under the AGOA agreement, then, in addition to form DA 185.4A4 (see above), you will need to also register as a manufacturer for purposes of AGOA. This is where form DA 46A1.03 comes into play. It is attached to form DA 185.4A4 as Section A.
You will still need to register as a manufacturer for AGOA even if you are not the direct exporter of the goods under the AGOA agreement (for example, if a third-party export agent is marketing your goods in the US, then they would register as exporters of the goods and you would register as the manufacturer of the goods).
Form DA 46A1.03 (section A) is extremely simple to complete and is self-explanatory. It is little more than a declaration on your part confirming that you will abide by the rules of AGOA.
You do not have to complete form DA 46A1.03 if you do not intend exporting to the US under the AGOA agreement. That is, if you intend registering as a general manufacturer with SARS/Customs and Excise, then you need only complete page 1 of form DA 185.4A4.
Completing form DA 185.4A7 - Client type: Producer
Customs and Excise make a distinction between an exporter and a producer (which is also distinct from a manufacturer). Although some exporters may also be producers (such as agrciultural producers) and some producers may be exporters, it is possible to be an exporter but not a producer (consider the case of an export agent or an exporter of services), or a producer that does not export or does not export directly (perhaps your firm imports only, or exports via a third-party such as an export agent).
For this reason, Customs and Excise have two separate registration categories ('client type 4A2 - exporter' and 'client type 4A7 - producer' - in fact they have several other client types - see 'registration as a manufacturer' above), and it is recommended that you register for both categories if both apply to you. If they don't then apply for the category (client type) that is appropriate to you (in fact, if you are currently a producer but don't export directly, we suggest that you still register as an exporter with Customs and Excise as a matter of course).
This two page form (DA 185.4A7) is very simple to complete and the required information is self-explanatory. It is primarily a declaration in which you confirm that the information you have provided is complete and correct. Note, that you will be asked to support your application with copies of registration of business documents, proof of address, ID documents, etc., and you need to confirm that you have the athority within your organisation to apply for registration. You are also expected to indicate in respect of which trade agreement you intend registering as a producer (namely, the SADC agreement, the TDCA agreement, or one of the GSP schemes - EU/Norway/Switzerland/Russia/Turkey).
Attached to form DA 185.4A4 SHOULD BE a second-page entitled 'Section C - Producer's Applicaiton for Registration ofr the purposes of GSP'(form DA 46A.02). However, we found no source for this document and umpteen calls to SARS also produced no Section C (it is also not clear what happened to Sections A and B???). Nevertheless, with the kind assistance of Mr Riaan de Lange from Tariff and Trade Intelligence, I managed to obtain a PDF copy of this form which can be accessed by means of the link provided at the bottom of the next section.
This page you do not have to complete if you are registering with SARS/Customs and Excise generally as a producer. If, however, you intend to take advantage of one of the GSP agreements with the EU/Norway/Switzerland/Russia or Turkey, then you also need to complete this form in addition to form DA 185.4A7 - see the next section.
Download form DA 185.4A7 (PDF)
Completing form DA 46A1.02 - Registration as a producer for the purposes of GSP
The last form that we discuss is form DA 46A.02. This is the form that you will need to complete if you intend registering as a producer in terms of one of the GSP agreements, namely with either the EU, Norway, Switzerland, Russia or Turkey. This form SHOULD be attached to form DA185.4A7 as Section C, but although we could find form DA185.4A7, no section C was attached to it andeven after umpteen calls to SARS/Customs and Excise, we could not get hold of this form. Nevertheless, with the kind assistance of Mr Riaan de Lange from Tariff and Trade Intelligence, I managed to obtain a PDF compy of this form which can be accessed by means of the link provided below.
You do not have to complete this form if you are registering with SARS/Customs and Excise generally as a producer. If, however, you intend to take advantage of one of the GSP agreements mentioned above, then you also need to complete this form in addition to form DA 185.4A7.
Form DA 46A.02 is extremely simple to complete and is self-explanatory. It is little more than a declaration on your part confirming that you will abide by the rules of the GSP agreements.
Download form DA 46A.02 (PDF)
Updated forms mentioned
As we said at the start, the SARS documentation is very unclear about which various forms need to be completed for what purpose. Nevertheless, we believe that the forms as indicated at the top of the page are all still relevant and required. There is mention made, however, in the SARS documentation and on their website of several other forms relating to registering as an exporter/manufacturer/producer and we have tried to provide some comment against each of these:
- DA 185.02 withdrawn and replaced with DA 185.4A2
- DA 185.14 withdrawn and replaced with DA 185.4A4
- DA 49A.01 withdrawn and replaced with DA 49A.02
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