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  • Writer's pictureLawtons Africa

Classification of the production of “hand sanitisers” and rebates for importers of ethyl alcohol

Authors: Riëtte Engels-van Zyl – Director & Henri Strydom – Candidate Attorney

SARS has provided clarity regarding the use of ethyl alcohol for the manufacture of hand sanitisers and whether this is classifiable under heading “disinfectants” as per the Harmonised Commodity and Coding System (Harmonised System) 38.08 of Part 1 of Schedule No.1.

Many queries have been received from traders regarding the classification of “hand sanitisers” and whether these items are subject to the imposition of ad valoremexcise duty. (Ad valoremexcise duty is an adjusted levy at a fixed percentage of the value of the commodity imported, as opposed to a specific tariff as set by the World Customs Organisation (WCO)) under Section B of Part 1 of Schedule 1 (Sch1P2B) of the Customs and Excise Act 91 of 1964.)

SARS has confirmed that “sanitisers” are grouped under the heading “disinfectants” as per the Harmonised System, refer to the relevant link from the SARS website: The use of ethyl alcohol in manufacturing hand sanitisers (31 March 2020)

In terms of the Explanatory Notes to the Harmonised System, “disinfectants” are classified under Chapter 38 of the Harmonised System, specifically tariff heading 3808.94. The tariff heading 3808.94 does not fall within the tariff headings as detailed under Sch1P2B.

Where any product of this nature cannot be readily classified or there is uncertainty of its nature and hence tariff classification, it is recommended that a formal application for a tariff determination be submitted to SARS.

SARS has also published an electronic temporary registration process for traders that intend to manufacture disinfectant classifiable in terms of tariff heading 38.08 of Part 1 of Schedule No.1 for the duration of the national state of disaster. The process is aimed at expediting the registration of the rebate users in terms of rebate item 621.08 to allow the relevant manufacturers to receive a rebate for the use in the manufacture of disinfectants upon importation of ethyl alcohol.

Schedule No.6 Part 1D has been amended by insertion after Note 4(d) of Note 4A in the Notes with the Tariff Amendment Notice R411 which was gazetted and published in the Government Gazette R43156 on 26 March 2020: Amendment of Schedule no.6 (NO. 6/1D/06)

Kindly contact our team for further information if your business qualifies for these rebate relief benefits or you require assistance with a submission to SARS for a directive and we will be happy to assist you:

Riëtte Engels-van Zyl



Lawtons Africa is a South African law firm. With roots that grew out of seeds sown in down-town Johannesburg in 1892, our history features various changes and different names. Our team of lawyers, including directors, consultants, associates and candidate attorneys is highly qualified, market-recognised and skilled. For further information, visit

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