If you are involved in the manufacture and import of iron and steel, or articles made of these materials, as well as articles made of base metal, then you may want to consider responding to an invitation for comment from the International Trade Administration Commission of South Africa (Itac) that closes on April 16.

The invitation was published in the Government Gazette on March 28 and relates to Itac’s review of the tariff structure and investigation into the possible introduction of an import surveillance system for steel products.

The review covers products classifiable under Tariff Chapter 72 (iron and steel), 73 (articles of iron and steel), 82 (tools, implements, cutlery, spoons and forks, of base metal, and base metal parts), and 83 (miscellaneous articles of base metal).

Itac gave three reasons for its investigation: the worldwide steel production overcapacity, coupled with increasing trade protectionist measures by some countries and resulting trade diversions occurring globally; the serious sustainability challenges facing South Africa’s steel value chain, which are undermining the country’s socioeconomic objectives; and persistent local conditions of slow economic growth and depressed demand, which are exacerbated by energy and freight logistics challenges.

While several initiatives are being implemented through the Steel and Metal Fabrication Masterplan, additional trade policy instruments may be necessary to ensure the achievement of South Africa’s industrialisation objectives and socioeconomic goals, which aim to support the country’s domestic steel production capabilities and jobs. Additionally, South Africa’s local downstream industry possesses capabilities to manufacture and be competitive in a broad array of products covered by tariff chapters 72, 73, 82 and 83. However, the South African industry faces numerous challenges, including an influx of low-priced and often substandard imports, which negatively affect the country’s socioeconomic goals.

Itac has invited interested parties to submit comments on a number of issues, including a possible increase in the rate of customs duty to the respective World Trade Organisation bound rates; the extent to which the challenges faced in relation to the influx of low-priced imports arising from global structural overcapacity constitute an ‘emergency’ situation; the necessity for emergency action, including under Article XIX (Emergency Action on Imports of Particular Products) of the General Agreement on Trade and Tariffs; the suspension, in whole or partially, or withdrawal or modification of any tariff concession, to the extent and for such a time as may be necessary to prevent or remedy further harm; the desirability of raw material input support measures to improve the cost competitiveness of domestic steel producers in overcoming price disadvantages arising from global structural overcapacity and incomparable scale economies found in countries of origin for competing products (such measures would include those aimed at reducing input prices on scrap, iron-ore, coking coal and any other feedstock material used in the production of steel); and the potential discontinuation of the following rebate provisions owing to their unintended negative consequences on the domestic manufacturing industry: Rebate Item 460.15/7210.61/01.06, Rebate Item 460.15/7210.70/01.06 and Rebate Item 460.15/7225.99/01.06.

Comments are also invited on the possible creation of rebate provisions for the importation of targeted input products used in manufacturing activities, classifiable under chapters 72, 73, 82 and 83 of the Customs and Excise Act, 1964; consideration of ‘alternative’ measures to ad valorem customs duties, including, but not limited to, tariff rate quotas, minimum import or reference pricing, and specific or formula duties, inter alia; the possible introduction of import controls (which would involve the issuance of a permit – for environmental, safety and other reasons – by Itac prior to the importation of specific categories of products); the possible introduction of an import surveillance system to assist in addressing, among other things, circumvention of import duties, customs fraud, misdeclaration, under-invoicing and other unlawful activities; and proposals on the identification of additional high-risk steel products to be prioritised in the development of compulsory specifications and standards in collaboration with the National Regulator for Compulsory Specifications.

As part of your preparation, you might want to review ‘The South African Steel and Metal Fabrication Master Plan 1.0’ (https://www.thedtic.gov.za/wp-content/uploads/Steel_ Industry_Master_Plan.pdf), South Africa’s WTO bound rates. (https://www.wto.org/ english/thewto_e/countries_e/south_africa_e.htm, and the South African Customs Tariff (https://www. sars.gov.za/wp-content/uploads/Legal/SCEA1964/Legal-LPrim-CE-Sch1P1Chpt1-to-99-Schedule-No-1-Part-1-Chapters-1-to-99.pdf).

The obvious question is whether Itac intends to initiate similar reviews of the remainder of the tariff chapters; if not, why?