South Africa is moving towards a more connected enforcement model for illicit and non-compliant goods. The May 2026 South African Revenue Service (SARS) and National Consumer Commission (NCC) Memorandum of Understanding (MoU) established a framework for information sharing, joint investigations and coordinated enforcement, particularly around non-compliant imports, customs and tax compliance and consumer protection. The latest development takes this a step further, SARS and the NCC are planning a smartphone-enabled track-and-trace system targeted for rollout in 2028, under which consumers will be able to scan a unique barcode on participating products and obtain information about their legitimacy and supply-chain provenance.
Cosmetics are vulnerable to counterfeiting, grey-market distribution, unauthorised imports and online sales, while consumers may have difficulty distinguishing legitimate products from sophisticated replicas. The proposed system represents a potentially important future product-stewardship and market-authenticity tool for beauty products marketed in South Africa.
For legitimate cosmetic manufacturers, the opportunity is significant. A traceable supply chain can make it easier to distinguish an authentic product from a counterfeit, identify where diversion has occurred and support enforcement against unauthorised traders. It can also strengthen a company's ability to demonstrate responsible product stewardship should a consumer complaint or safety concern arise. In a market where legitimate manufacturers carry the costs of formulation, testing, regulatory compliance, quality control, customs and distribution, better enforcement against illicit products can help restore a more level competitive playing field.
This direction is reinforced by a second policy lever, the South African Bureau of Standards (SABS) and the Department of Trade, Industry & Competition (the dtic) have been developing a Pre-Verification of Conformity (PVoC) framework for certain unregulated high-risk imported products, including cosmetics. Although implementation of the programme has subsequently been paused pending further consultation, its underlying policy objective remains instructive. PVoC was designed to introduce conformity assessment before export for specified products, signalling a potential shift towards greater scrutiny of high-risk imports before they reach the South African market.
Taken together, these developments suggest that border control, product conformity and consumer protection are increasingly being connected rather than treated as separate regulatory questions. For legitimate cosmetic manufacturers and brand owners, that could ultimately be positive: stronger controls can narrow the competitive advantage currently enjoyed by operators who avoid the costs associated with legitimate manufacture, regulatory compliance, customs duties, quality assurance and traceability.
The strategic consequence for beauty companies is that product authenticity is becoming part of product stewardship. A company should be able to demonstrate not only what its product contains, but also that the product is genuine, where it was manufactured, who imported it, how it moved through the supply chain and whether the entity placing it on the South African market is authorised to do so.
Cosmetic companies should use this period to stress-test their import, authenticity and distribution controls. Customs documentation, invoices, HS classifications, importer details, product registrations or notifications where applicable, batch information and supplier records should be consistent and readily retrievable. Companies should also strengthen batch and lot traceability, authorised-distributor controls and mechanisms for identifying suspected counterfeit products, particularly across e-commerce and informal distribution channels.
For brands with significant IP exposure, trademark portfolios and customs enforcement arrangements should also be reviewed. The objective should be to ensure that when counterfeit products are detected, the company can establish ownership, authenticity and legitimate supply-chain provenance quickly enough to support regulatory or enforcement intervention.
The PVoC pause should similarly be viewed as time to prepare, not a reason to disengage. If a conformity-assessment regime is reintroduced in a revised form, companies with robust technical files, supplier documentation and conformity evidence will be better positioned to absorb the requirements without disrupting supply.
Bottom Line Take-Out
South Africa appears to be building a layered enforcement architecture around illicit and non-compliant imports i.e. customs intelligence through SARS, consumer protection through the NCC and potentially stronger pre-border conformity controls through SABS and the dtic. The PVoC programme may currently be paused, but the policy signal is difficult to miss.
For cosmetic companies, authenticity, traceability and conformity are becoming competitive assets, not merely compliance obligations. The brands best prepared for this environment will be those able to prove, quickly and convincingly, that the product entering the country is exactly the product they manufactured, legitimately imported and authorised for sale.
