On 16 May 2025, ITAC published an important Gazette proposing Administrative Fees for processing various permits. This marks a significant development in how ITAC will recover costs related to its functions, including processing permits and certificates for imports, exports, and other trade-related activities. No fees are being proposed for access to any of the trade instruments like anti-dumping or tariff changes.

It is important to note that some products may incur different administrative fees depending on factors such as the number of tariff lines involved in the application or the specific type of permit or certificate required.

ITAC’s 2023/2024 Annual Report indicates that 39 145 permits were issued (19,558 import permits and 19,587 export permits)  during the year. At R339 per export and import permit, this translates to around R13 million in revenue which could be earned from the most basic and least expensive category of permits. More expensive permits, such as those for rebates, drawbacks, Export Promotion Certificates, Automotive Production Rebate Certificates, and scrap metal exports permits will cost from R2 000 to just over R5 000 each. The scrap recyclers honestly just can’t win. After no one wants to buy your product locally at a hefty discount, you will now need to pay for a permit to export the goods and then pay an export duty before the goods leave the country.

Unfortunately, information on the number of these other permits and certificates issued annually is not available in the annual report. If the permits were issued at the average price of R3 320 per permit, this would push permit revenue up to over R120 million, just a smidge over the R119 million ITAC received as funding from National Treasury in 2024. ITAC definitely needs more staff, so it’s not irrational for them to want more money and many other departments do something similar. Is this the best way to do it? South Africans already pay a staggering amount in taxes. Should this not come from the National Revenue Fund, instead of from companies who are forced to apply for permits because of the rules created by ITAC?

Why are administrative fees being introduced?

According to ITAC, ongoing budgetary constraints and a challenging macro-fiscal environment have necessitated the introduction of administrative fees to recover some of the costs it incurs in carrying out its statutory functions. Previously, ITAC did not levy fees for these services.

What does the notice cover?

The notice accompanies draft regulations published in June 2024, which provide the legal basis for levying these fees. The Guidelines attached to the 2025 notice explain how the fees will be applied, who will be affected, and the administrative procedures involved.

Key highlights include:

• Scope of Fees: Fees will be charged for processing applications for permits and certificates, such as import/export permits, rebate certificates, and certificates under the Automotive Production and Development Programme Phase 2 (APDP). Fees also cover other functions assigned to ITAC by legislation or the Minister. Annexure A from the Guidelines is included at the end of this post.
• Fee Calculation: Fees are directly linked to the costs ITAC incurs, including staff time and overheads for verifying application information. For import/export permits, fees may be charged per tariff line in an application.
• Phased Implementation: The introduction of fees will be gradual, starting with applications related to the APDP certificates to manage any initial operational challenges.
• Exemptions: Certain applicants or goods may be exempt from fees for good cause or public interest reasons. For example, non-profit organisations, humanitarian groups, researchers, or individuals importing personal property may qualify for exemptions. The Commission will also consider the broader economic impact, such as supporting emerging industries or vulnerable regions.
• Non-Refundability: Once an application is duly completed and accepted, the administrative fee is non-refundable, even if the application is later rejected.
• Fee Adjustments: Fees may be adjusted annually by up to the Consumer Price Index, or higher if approved by the Minister, with reasons published transparently on ITAC’s website.

Annexure A: Proposed fee schedule

The Guidelines include Annexure A, which sets out the proposed fee schedule.

*Import and export permit applications may incur multiple fees depending on the number of tariff (sub-)headings associated with any request for such authorisation.

You have until 30 May 2025 to submit your comments on the proposed permit fees.

Email us at info@xagta.com if you need assistance.