COMPLIANCE HELP
South African Product Compliance Explained in Plain English
NRCS LOAs, ICASA approvals, test reports and import requirements can become complicated very quickly.
Start with your product or problem. We’ll help you understand what needs to be checked.
What do you need help with?
Choose the area that best matches your question:
Find out whether your product may require an NRCS Letter of Authority.
Check your product or pro forma invoice before you pay the supplier.
Applications, renewals, model grouping and common LOA questions.
Wi-Fi, Bluetooth, wireless remotes and Type Approval.
CB reports, IEC testing, model numbers and test laboratory requirements.
Goods stopped, NRCS inspections, records and embargo releases.
BEFORE YOU IMPORT
Have a Pro Forma Invoice? Send It to Us Before You Pay.
You have found the product. The supplier looks legitimate. The price works. The pro forma invoice has arrived.
This is an excellent time to check the South African compliance requirements.
ATS can review your proposed order, product specifications and supplier documentation before you commit to the purchase.
We can identify products that may require NRCS, ICASA, SAHPRA or other regulatory attention, examine what documentation the supplier already has, and tell you what still needs to be requested.
✓ Supplier quotation or pro forma invoice
✓ Product list or catalogue
✓ Datasheets and specifications
✓ Product and nameplate photographs
✓ Certificates and test reports
Send us what you have and we’ll tell you what else is needed.
Read the article: Before You Pay Your Supplier — Check the Compliance First.
DO I NEED AN LOA?
Does My Product Need an LOA?
Not every imported product requires an NRCS Letter of Authority. The requirement depends on the actual product, its construction, electrical characteristics, intended use and the scope of the applicable compulsory specification.
Does every electrical product need an LOA?
No. Many electrical and electronic products fall within South African compulsory specifications, but not every product requires an NRCS Letter of Authority.
A description such as “charger”, “motor”, “LED light” or “power supply” is not always enough to determine the requirement. The actual product and its specifications need to be considered.
My supplier says the product is CE certified. Does that mean I don’t need an LOA?
No. CE marking relates to requirements for the European market and does not replace applicable South African regulatory requirements.
However, the supplier’s existing documentation may still be useful. Before asking the manufacturer to arrange new testing, send us the certificates and reports they already have.
The same product is already sold in South Africa. Can I import it too?
Do not assume so. An apparently identical product being sold locally does not establish that your importation is covered by the necessary approvals. The exact model, product configuration, applicant/importer and applicable regulatory requirements need to be checked.
Not every electrical product needs an LOA.
Whether an LOA is required depends on the specific product and the compulsory specification that applies to it.
CE marked?
That doesn’t automatically answer the South African question.
Already sold locally?
That doesn’t automatically mean your import is covered.
Not sure?
Send us the model, datasheet, photographs and supplier documents.
Send us the product datasheet, model number, photographs and whatever supplier documentation you have. We can establish what needs to be checked before you commit to the purchase.
NRCS & LOA QUESTIONS
Understanding Letters of Authority
From applications and renewals to model grouping and existing approvals, these are some of the NRCS LOA questions we are asked most often.
What is an NRCS Letter of Authority?
A Letter of Authority (LOA) is an approval issued by the National Regulator for Compulsory Specifications (NRCS) for products that fall within the scope of applicable compulsory specifications.
For electrotechnical products, the NRCS evaluates evidence of conformity submitted with the application. This normally includes a valid test report from an appropriately accredited and internationally recognised testing body.
An LOA is therefore not simply a general certificate for an electrical product. The approval relates to the product or model family covered by the application and the applicable compulsory specification.
How long is an LOA valid?
An NRCS LOA is valid for three years.
If the product will continue to be imported or manufactured after the LOA expires, a renewal application is required. NRCS describes renewal as a further application, so it should not be treated as an automatic extension of the existing certificate.
Do not leave the review until the LOA is about to expire. Supporting test documentation, product construction and the applicable regulatory requirements should be checked early enough to identify anything that needs to be updated.
Can several models be covered together?
Potentially, yes.
NRCS expressly refers to approval of a model or family of products, and individual compulsory specifications may contain their own requirements for what constitutes an acceptable product family.
Models should therefore not be grouped merely because they share a brand name or look similar. Their construction, ratings, components, test coverage and the requirements of the applicable compulsory specification need to be considered.
This is worth assessing before new testing is commissioned. Correct family planning may avoid unnecessary duplicate testing and applications.
Can I use somebody else's LOA?
No.
NRCS states that an LOA may not be sold, traded or ceded to anyone other than the applicant named on the certificate, and that each importer is responsible for obtaining its own approval.
If a supplier tells you that the product “already has an NRCS LOA”, ask for a copy. It can still be useful for identifying the product and its regulatory history, but do not assume that another company’s LOA authorises your importation.
Can I ship the goods while my LOA application is being processed?
Shipping regulated goods before the required approval has been issued creates a significant risk.
NRCS states that products falling within the applicable compulsory specifications require approval before they enter the South African market.
If the goods arrive while the LOA application is still unresolved, the importer may face a port-of-entry stoppage and will need to deal with the regulatory position before the goods can proceed normally.
Our advice is therefore simple: establish the applicable requirements and obtain the necessary approval before shipping regulated goods to South Africa.
LOA AT A GLANCE
Issued by
National Regulator for Compulsory Specifications (NRCS)
Validity
3 years
Product specific
The approval must properly cover the product/model being imported.
Test documentation matters
New applications require appropriate full test reports from an accredited testing facility, and NRCS currently states that these must not be older than 36 months.
Renewals need planning
Don’t wait until the LOA is about to expire before checking whether the supporting documentation is still suitable.
Similar models may sometimes be grouped efficiently, but this should be assessed before unnecessary duplicate testing is commissioned.
ICASA & WIRELESS QUESTIONS
Wireless Products and Type Approval
Wireless functionality is easy to overlook when assessing a product for South African compliance. Wi-Fi, Bluetooth, cellular connectivity and wireless remote controls can introduce ICASA requirements even when the main product is something completely different.
The equipment, radio technology, operating frequencies and existing approvals should therefore be checked before importing.
My product has Wi-Fi or Bluetooth. Does it need ICASA approval?
Wi-Fi or Bluetooth functionality should trigger an ICASA assessment.
ICASA requires equipment used or intended for electronic communications to be Type Approved unless it is specifically exempted. The exact requirement depends on the equipment, the radio technology it uses, its operating frequencies and the applicable technical standards.
This can easily be overlooked where wireless connectivity is only one feature of a larger product — for example, an appliance, controller, machine or monitoring device.
Do not assess only the main function of the product. The wireless functionality needs to be considered too.
What about 433 MHz wireless remotes and other short-range devices?
Short-range wireless devices should not be ignored simply because they operate on a commonly used frequency.
Equipment such as wireless remotes, receivers, sensors and control devices may still need to be assessed against ICASA’s requirements for radio equipment.
It is also important to distinguish between use of radio-frequency spectrum and Type Approval of the equipment itself. Operation in spectrum that does not require an individual spectrum licence does not, by itself, establish that the equipment requires no Type Approval.
Send us the operating frequency, technical specifications and any radio test reports supplied by the manufacturer so that the equipment can be assessed correctly.
Can a product require both an NRCS LOA and ICASA approval?
Simple answer: Yes.
A single product can potentially fall within more than one South African regulatory regime.
For example, a mains-powered product containing Wi-Fi, Bluetooth or another radio function may need its electrical safety requirements assessed for NRCS purposes while its radio or communications functionality is considered separately under ICASA requirements.
An approval from one regulator does not automatically satisfy the requirements of another.
This is why ATS assesses the complete product rather than looking only at its most obvious function.
The same model has already been approved by ICASA. Do I need to start again?
Not necessarily.
ICASA provides a Simplified Type Approval process for equipment that already appears on its Type Approval Register.
The important condition is that the equipment being submitted must be identical to the equipment that has already been Type Approved.
Under the Simplified Type Approval process, ICASA does not require the test reports to be submitted again, although the Authority may request a representative sample.
If your supplier says the model is already ICASA approved, send us the exact manufacturer and model number together with any existing ICASA certificate or approval details so that this can be checked against the register.
What documents should I ask my supplier for?
Start by asking for enough information to identify the equipment and its radio functionality clearly.
Useful documents include the manufacturer and exact model number, product datasheet, user manual, photographs and nameplate details, together with information showing the wireless technologies and operating frequencies used.
For a new product requiring Standard Type Approval, ICASA requires appropriate test reports demonstrating compliance with the applicable technical standards. Its published requirements also include product photographs, installation and user information, a functional description, schematic diagram and PCB layout, with additional supporting documents requested where necessary.
If the supplier already has radio, EMC, safety or other compliance reports, send us those before arranging any new testing. We can first establish what is usable and what may still be missing.
DON’T FORGET THE RADIO
Wi-Fi & Bluetooth
Wireless functionality should be identified and assessed.
Wireless remotes
Short-range devices should not be ignored simply because they use a commonly used frequency.
Cellular
SIM-enabled equipment introduces cellular radio functionality that must also be considered.
Already ICASA approved?
Equipment already on ICASA’s Type Approval Register may qualify for the Simplified Type Approval process if the equipment is identical.
A product’s radio spectrum use and its equipment Type Approval are related regulatory issues, but they are not the same thing.
TEST REPORTS & CERTIFICATES
“It’s Certified.” Excellent. Certified to What?
Certificates and test reports can look impressive, but the important questions are what was tested, which standard was used, which models are covered and whether the laboratory and report are acceptable for the South African application.
Before asking a supplier to arrange new testing, it is usually worth examining what they already have.
What is a CB certificate and test report?
A CB Certificate is issued under the international IECEE CB Scheme and is normally supported by a detailed CB Test Report covering the product that was tested.
For an NRCS application, the important document is not simply the certificate. The underlying test report, applicable standard, exact models covered and the testing or certification bodies involved all need to be checked.
A certificate on its own should therefore not be treated as proof that the documentation is sufficient for an LOA application.
What is the difference between a CB report and a regular IEC test report?
Both documents may show testing against an IEC standard, but they are not necessarily the same thing.
A CB Test Report is produced within the IECEE CB Scheme. It follows the CB Scheme’s prescribed format and is associated with an issuing National Certification Body (NCB). A corresponding CB Test Certificate identifies the product, applicable IEC standard and certification details.
A laboratory can also issue a test report showing that a product was tested against an IEC standard outside the CB Scheme. That may still be valid and useful technical evidence, provided the laboratory, its accreditation and scope, the standard used, the product coverage and the requirements of the particular regulatory application are acceptable.
So “tested to IEC 60335-1” does not automatically mean “CB tested”, and the absence of a CB Certificate does not automatically mean the IEC test report is unusable.
Send us the complete report and any accompanying certificate rather than relying only on the supplier’s description of it.
Does the model number on the test report matter?
Yes.
The product being submitted for approval needs to be properly connected to the product or model family covered by the supporting test documentation.
A different brand name, model number or product variant does not necessarily mean that completely new testing will be required, but the relationship must be properly established rather than assumed.
If the model you intend to import does not appear clearly in the documentation, do not immediately commission another test. First establish whether existing reports, model-family information or supporting confirmation from the manufacturer or laboratory can resolve the difference.
Does it matter which laboratory performed the testing?
Yes.
A technically impressive-looking report is not automatically suitable for a South African regulatory application.
For NRCS LOA purposes, the report must come from an acceptable accredited testing facility. The laboratory’s accreditation, scope and recognition may therefore need to be checked against the particular standard and testing involved.
Check the laboratory before commissioning new testing. Discovering afterwards that the report is not acceptable can mean repeating expensive work.
How old can a test report be?
It depends on the application.
Under the NRCS’s published LOA administrative procedure, a test report for a new application should be less than 36 months old, while the checklist provides for reports of less than 60 months for a renewal.
Report age should therefore be considered together with whether the application is new or a renewal, whether the applicable standard has changed and whether the existing documentation still properly covers the product.
Do not assume that every report becomes useless on its third birthday — but don’t assume that an older report will be accepted either.
My supplier says new testing is required. Should I tell them to proceed?
Not yet.
Before commissioning new testing, establish exactly what is required: the applicable standard, the models or product family that need to be covered, the required type of report and whether the proposed laboratory is suitable.
Also review the supplier’s existing certificates and reports first. Useful testing may already exist, or additional documentation may be enough to resolve a model or product-family issue without starting again.
Testing the wrong models, to the wrong standard or at an unsuitable laboratory can be an expensive mistake. Send us what the supplier already has before authorising new testing.
BEFORE YOU ORDER NEW TESTING
Check the exact model
The product being imported needs to be properly connected to the models covered by the test documentation.
Check the standard
A test report is only useful if it addresses the appropriate requirements for the product and application.
Check the laboratory
The laboratory and its accreditation or recognition need to be acceptable for the relevant regulatory process.
Check the report date
For new NRCS LOA applications, report age can matter.
Check what you already have
A supplier may already possess useful testing that can avoid unnecessary duplication.
Send us the reports and certificates you already have. We can identify what is usable, what is missing and what should be requested next.
IMPORTS & INSPECTIONS
When Your Goods Are Stopped
A regulatory problem can become expensive very quickly once the goods have already arrived in South Africa.
If the NRCS or another authority has stopped or inspected a shipment, the first step is to establish exactly why the goods were stopped, what documentation has been issued and what the regulator requires next.
What happens if my shipment arrives without the required LOA?
If a product requires an NRCS Letter of Authority and the necessary approval is not in place, the goods may be stopped while the regulatory position is investigated.
This does not mean that every stopped shipment will have the same outcome. What happens next depends on the product, the applicable compulsory specification and what the NRCS identifies during its inspection.
Possible regulatory action can ultimately include restrictions on the goods, return to the country of origin, confiscation or destruction where non-compliance is established.
The first priority is to establish exactly why the shipment has been stopped before deciding how to resolve it.
What is an NRCS inspection?
NRCS inspections form part of the regulator’s compliance and market-surveillance activities.
The NRCS may inspect products, examine documentation, take samples and arrange testing where necessary to assess compliance with applicable compulsory specifications. Inspections can take place at the point of import as well as elsewhere in the supply chain.
An inspection does not by itself mean that the product has been found non-compliant. It is part of the process used to establish the compliance position.
What is an NRCS Inspection Record?
An Inspection Record records information arising from an NRCS inspection and can be one of the most important documents for understanding why goods have been stopped.
It may identify the products inspected, relevant shipment or importer information and the issue noted by the inspector.
If you receive an Inspection Record, keep it and send us a complete copy together with the product and shipment documentation.
An Inspection Record should not automatically be treated as the same thing as an embargo notice or directive. NRCS’s own current performance documentation distinguishes between Inspection Records, directives and embargo notices.
Read what the inspector has actually recorded before deciding what action to take.
What does it mean when goods are placed under embargo?
In practical terms, goods placed under embargo are not free to be dealt with normally while the regulatory issue remains unresolved.
The precise restrictions and next steps depend on the notice or instruction issued and the circumstances of the case. NRCS enforcement procedures provide mechanisms to keep affected products under control while their compliance status is addressed. Where non-compliance is established, further action can include recall, return to the country of origin, confiscation, destruction or another action determined by the regulator.
Do not sell, distribute, alter or otherwise deal with goods contrary to the NRCS instructions applying to them.
What is an Embargo Release Notice?
An NRCS Embargo Release Notice may allow detained cargo to be released from the border or shipping environment to the importer while the goods remain under embargo.
This is an important distinction. Release of the cargo to the importer does not necessarily mean that the underlying compliance problem has been resolved or that the goods may now be sold or distributed.
The conditions applying to the goods must still be followed while the regulatory issue is dealt with.
“Released to the importer” and “released from embargo” are not necessarily the same thing.
How can an embargo or compliance problem be resolved?
There is no single solution.
The appropriate response depends on why the goods were stopped and what the NRCS has identified.
In some cases the issue may be resolved by providing an existing LOA or other acceptable compliance documentation. In others, corrective action may be required — for example removing an affected component, arranging its destruction, correcting a compliance issue, obtaining the necessary approval or taking another action accepted by the regulator.
NRCS’s enforcement framework provides for different outcomes depending on the circumstances and the compliance status of the goods.
Do not assume that the solution is automatically a new LOA or new testing. First establish the problem, then establish what the NRCS requires to resolve it.
My goods have already been stopped. Can ATS help?
Yes.
Send us the Inspection Record, embargo notice or other documentation you have received, together with the commercial invoice, packing list, product information and any existing LOAs, certificates or test reports.
Include any correspondence received from the NRCS, SARS Customs, your clearing agent or other authority relating to the stop.
We can review the information, help identify the regulatory issue and establish what documentation, compliance evidence or corrective action may be needed.
Don’t start ordering new testing or making assumptions about the solution until the reason for the stop has been properly established.
Does NRCS check products after they have been imported?
Yes.
NRCS compliance activities do not end when a shipment clears Customs. The regulator also conducts market-surveillance and enforcement activities on products that are already being supplied in South Africa.
For legitimate importers, this means that obtaining an LOA should not be treated as the end of the compliance process. The products actually being imported and sold should continue to correspond with the approved models and the supporting compliance documentation.
Changes to the product, manufacturer, construction or other compliance-related details may need to be assessed before further shipments are made.
A product clearing the border does not necessarily mean that its compliance will never be checked again.
IF YOUR GOODS HAVE BEEN STOPPED
Send us the Inspection Record
If the NRCS has issued one, this is one of the first documents we want to see.
Send us the shipment documents
Commercial invoice, packing list and relevant shipping or Customs documentation.
Send us the product information
Exact models, datasheets, photographs and nameplate information.
Send us the compliance documents
Existing LOAs, test reports, certificates and other approvals.
Send us the correspondence
Include relevant emails or notices from NRCS, Customs or your clearing agent.
Establish why the goods were stopped first. The correct response depends on the product, the regulatory requirement and what issues or problems the inspection has actually identified.
COMPLIANCE DOESN’T END AT THE BORDER
NRCS enforcement also takes place after products have entered the South African market.
Obtaining the approval is one part of compliance. Maintaining it is the other.
Read: Why Surprise Raids Alone Won’t Stop Non-Compliant Goods in South Africa →
STILL NOT SURE?
You don’t need to know which regulator to ask.
That’s our job.
If you’re unsure whether your product involves NRCS, ICASA, SAHPRA or another South African compliance requirement, send us what you have.
Before ordering? Send us the quotation or pro forma invoice.
Already ordered? Send us the product details and supplier documentation.
Goods stopped? Send us the Inspection Record and regulator correspondence.
010 157 4243
Send us an Email
Stay compliant. Avoid delays. Protect your business.