The Determination of the “Origin” of Products in South African and SADC Law

This article analyses the landmark case of Commissioner: SARS v. Levi Strauss SA (Pty) Ltd (hereinafter Levi), in which the Supreme Court of Appeal in South Africa decided on the issue of the “origin” of goods in international trade. In South Africa, this issue is regulated by the Customs and Excise...

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Main Author: C. Vinti
Format: Article
Language:English
Published: Publshing House V.Ема 2025-08-01
Series:BRICS Law Journal
Subjects:
Online Access:https://www.bricslawjournal.com/jour/article/view/1294
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author C. Vinti
author_facet C. Vinti
author_sort C. Vinti
collection DOAJ
description This article analyses the landmark case of Commissioner: SARS v. Levi Strauss SA (Pty) Ltd (hereinafter Levi), in which the Supreme Court of Appeal in South Africa decided on the issue of the “origin” of goods in international trade. In South Africa, this issue is regulated by the Customs and Excise Act 91 of 1964 (CEA). The origin of a product is easy to establish when a product is wholly produced in one country. But when the production of a good occurs across different countries, then the rule usually is that the origin of goods is determined based on the “last substantial transformation” of the product. However, in the Levi ruling, the court made this decision without any consideration of South Africa’s international obligations under the Agreement on Rules of Origin and misinterpreted the origin test set out in the Protocol on Trade in the South African Development Community. Moreover, the court also failed to adequately contextualise its reasoning in relation to the default position on the determination of origin in South African law under the CEA. This paper critiques the court’s approach in this regard and assesses its broader implications for origin determinations.
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spelling doaj-art-8bb5399e1e4d41628f1e8eb07ee9448a2025-08-20T03:45:15ZengPublshing House V.ЕмаBRICS Law Journal2409-90582412-23432025-08-011228811110.21684/2412-2343-2025-12-2-88-111353The Determination of the “Origin” of Products in South African and SADC LawC. Vinti0Oliver Schreiner School of Law, University of the WitwatersrandThis article analyses the landmark case of Commissioner: SARS v. Levi Strauss SA (Pty) Ltd (hereinafter Levi), in which the Supreme Court of Appeal in South Africa decided on the issue of the “origin” of goods in international trade. In South Africa, this issue is regulated by the Customs and Excise Act 91 of 1964 (CEA). The origin of a product is easy to establish when a product is wholly produced in one country. But when the production of a good occurs across different countries, then the rule usually is that the origin of goods is determined based on the “last substantial transformation” of the product. However, in the Levi ruling, the court made this decision without any consideration of South Africa’s international obligations under the Agreement on Rules of Origin and misinterpreted the origin test set out in the Protocol on Trade in the South African Development Community. Moreover, the court also failed to adequately contextualise its reasoning in relation to the default position on the determination of origin in South African law under the CEA. This paper critiques the court’s approach in this regard and assesses its broader implications for origin determinations.https://www.bricslawjournal.com/jour/article/view/1294originwholly obtainedlast substantial transformationagreement on rules of originsouth africaprotocol on trade in the south african development communitygatt 1994
spellingShingle C. Vinti
The Determination of the “Origin” of Products in South African and SADC Law
BRICS Law Journal
origin
wholly obtained
last substantial transformation
agreement on rules of origin
south africa
protocol on trade in the south african development community
gatt 1994
title The Determination of the “Origin” of Products in South African and SADC Law
title_full The Determination of the “Origin” of Products in South African and SADC Law
title_fullStr The Determination of the “Origin” of Products in South African and SADC Law
title_full_unstemmed The Determination of the “Origin” of Products in South African and SADC Law
title_short The Determination of the “Origin” of Products in South African and SADC Law
title_sort determination of the origin of products in south african and sadc law
topic origin
wholly obtained
last substantial transformation
agreement on rules of origin
south africa
protocol on trade in the south african development community
gatt 1994
url https://www.bricslawjournal.com/jour/article/view/1294
work_keys_str_mv AT cvinti thedeterminationoftheoriginofproductsinsouthafricanandsadclaw
AT cvinti determinationoftheoriginofproductsinsouthafricanandsadclaw