Unravelling the compliance issues in the industry

– and taking corrective action.

It is becoming harder to discern the truth from the untruth.

While we are not here to compare past and present circumstances in the industry, it is important to recognise a system if it works. Previous systems have fallen flat, and because of this, we are no longer able to prepare when a product arrives in our ports.

In the past there was access to global databases that listed all the tested products meant for shipping to South Africa. We knew what product was arriving and when it would arrive. We also knew the customs codes and fees. The system was effective and streamlined.

Safehouse Regulatory Practices and Industry Engagement.

Safehouse approaches the managing of regulatory practices by ensuring industry
engagement. The NRCS is reluctant to conduct impact assessments due to their financial
restraints, leaving the implementation of new specifications and amendments in a
complicated situation. There is an ongoing need to foster industry communication and
education on regulatory matters.

Retailers are becoming more aware that Safehouse plays an important and necessary role
in providing guidance on regulatory matters.

Safehouse is not the last resort; it’s the ‘first stop’ for industry information.

Unravelling the compliance issues in the industry – and taking corrective action

How are retailers educated about compliance, and where can they access information?

The open-door policy disappeared, leaving consumer and retailer questions unanswered. Safehouse is starting to open the conversations again. The industry is beginning to understand that the communication channel has shifted towards Safehouse to educate everyone about regulatory best practices and industry procedures.

The NRCS has told companies not to talk to Safehouse but to go to the NRCS. If a company asks, “Do I need an LoA for this product?” The answer is always an emphatic yes.

The NRCS makes financial decisions and does not tell the retailer if the product is covered by the specification or not. Wasting the retailers time and money. The NRCS these days seems to stand for National Regulatory Collection Services.

It has become all about collecting levies. They no longer have the funds available to amend and review specifications and cannot afford to do impact assessments on amendments and new specifications, as required by the WTO Agreement on Technical Barriers to Trade (TBT).

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WTO Agreement on Technical Barriers to Trade (TBT)

This agreement has established the rules and procedures with regards to the development, adoption, and application of voluntary product standards, mandatory technical regulations, and the procedures used to determine whether a particular product meets the standards or regulations.

The agreement aims to ensure product regulation standards on safety, quality and health and are not obstacles to trade. The TBT agreement is integral to the WTO Agreement to which South Africa is a signatory.

When the NRCS writes a new compulsory specification, part of the process must be an impact evaluation and impact assessment as specified in regulation R924, section 10. The 2010 regulation states when there are new specifications or amendments, there must be an impact assessment.

Product tracking and customs management concerns.

  • General Service Lamps New Specification by 2026.
The luminous flux of general service lamps must increase from 90 lumens per watt to 105 lumens per watt. Importers now have one year left to increase the light output of their lamps, as stipulated in May 2024. Importers may overlook the new specification, which is a concern. SANEDI (South African National Energy Development Institute) handles the markings on the packaging of ‘energy efficiency bar coding’. The published barcoding is incorrect, resulting in importers using incorrect barcoding. There is no amended version in sight.
  • General Service Lamps Life Test
General Service Lamps required a life test and an endurance test to determine the lifespan of lamps, as well as the reduction in light output over time. This test takes up to twenty-one weeks to conduct. The compulsory specification VC9109 and VC9110 are simpler life tests as opposed to the comprehensive IEC international standards, which takes measurements throughout the life test at intervals to see how the lumen depreciation takes place over that span of time. The NRCS is not accepting companies that have the IEC life test, even though it is more comprehensive, as such companies are forced to redo the test only to complete a more simplified test. There is no logic behind the ruling. A lamp can, in a live test, drop in light output at the beginning of the test and then stabilise and have a low light output, within limits, until the end of the test, where a good lamp will start with high light output but a very slow reduction over time. The simplified life test will not pick it up.
  • Tubular Fluorescent Lamps
Tubular fluorescent lamps are not covered by the new compulsory specifications even though LED tubular lamps replaced mercury vapour lamps. It was an automatic transition, which happened without intervention from the NRCS, and is a perfect

Safehouse aims to ensure compliance standards:

  • ✔ Proper sample management.
  • ✔ Retailer education on compliance standards.
  • ✔ Effective use of international databases for tracking products.
  • ✔ Proactive customs management.
  • ✔ Regulatory framework accountability.
  • ✔ Consumer safety awareness.
  • ✔ Maintaining Compulsory Specifications and Standards in South Africa.
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Conclusion

Together we ensure compliance! Contact us for access to a network of like-minded
businesses.
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