As the International Trade Administration Commission of South Africa (ITAC) continues its quest for a comprehensive review, another actively identified industry is steel products.
On 19 March 2025 ITAC issued Notice 3061 of 2025, as published in Government Gazette No. 52347. The notice relates to ITAC’s intended review of a wide range of steel pipes, tubes, fittings, flanges and related components classified under Chapters 72, 73, 82 and 83.
ITAC’s Notice seeks to determine whether the existing tariffs remain appropriate in the current local business landscape and whether there is a need to increase customs duties. The notice also considers whether a permit system or alternative protective measures should be implemented to support the domestic steel industry.
Our firm has been advising and representing a group of importers and distributors of specialised steel piping products in response to this process. Of note, our clients do not engage in further manufacturing or processing of these goods; rather, they supply essential components for critical infrastructure, mining, and industrial projects nationwide.
As part of our representation, Andersen filed formal objections to the proposed measures in April 2025, raising concerns about unintended economic consequences, including:
- Increased costs for downstream industries;
- Disruption to legitimate, compliant supply chains;
- Risks of substitution away from steel to alternative products such as plastic, undermining the broader steel value chain; and
- Potential impacts on employment, infrastructure development, and fiscal contributions.
The submitted objections have largely been grounded in both commercial realities and legal precedent, including the case of Mining Pressure Systems (Pty) Ltd v SARS, which affirmed that product classification and trade policy must reflect actual market conditions and product usage.
Progress on Targeted Relief
Following our initial objection, ITAC further invited submissions, which included formal motivations for the creation of rebate provisions or exclusions for certain products.
In collaboration with SARS, Andersen has since made submissions to propose targeted rebate wording designed to protect key product categories where no suitable local alternatives exist, including:
- Large bore seamless pipe;
- Small bore seamless pipe;
- Galvanised welded pipe; and
- Large bore ERW pipe.
The proposals are aimed at preserving uninterrupted access to the identified specialised products while supporting ITAC’s broader policy objectives.
Outlook and Next Steps
While we welcome the constructive approach shown by both ITAC and SARS thus far, we remain mindful of the potential risks that poorly targeted trade measures pose to compliant, tax-contributing businesses that play a critical role in national infrastructure and industrial development.
Without appropriate relief mechanisms, increased tariffs and import controls could inadvertently erode the tax base, threaten jobs and drive up costs for public infrastructure and mining projects.
Andersen remains committed to engaging with both regulators and industry stakeholders to promote fair, commercially sound trade policies that align with South Africa’s economic and developmental objectives.