The SAIT Customs and Excise Technical Work Group submitted comments on the Draft Taxation Administration Laws Amendment Bill, 2024, focusing on the proposed retrospective reclassification of fuel products under tariff heading 27.10. The submission addresses concerns regarding the reclassification of “light oils and preparations” from subheading 2710.11/12 to 2710.19, effective from 1 January 2002, which may require affected traders to retrospectively apply for manufacturing or storage licenses and import permits. SAIT highlights the potential compliance and licensing implications for industry stakeholders, especially given ambiguities around the application of subheading notes related to distillation thresholds. The group requests urgent clarification on how the reclassification should be interpreted and implemented, particularly where products do not meet the 210°C distillation requirement, and whether the broader 362°C threshold in Note 1(g) should guide classification under 2710.19.
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