General Notice 3142 of 2025 published in the Government Gazette, 17 April 2025, relates to a proposed review – initiated by the International Trade Administration Commission of South Africa (ITAC) – of the tariff structure for input materials, components, and final goods in the renewable energy value chain.
The notice has been acknowledged by industry bodies SAPVIA and SAWEA and both are currently engaging with their respective members to gather input and prepare their responses for submission within the given deadline.
Dr Rethabile Melamu, CEO of SAPVIA, the South African Photovoltaic Industry Association, says, “Concurrently, SAPVIA has initiated direct discussions with ITAC to ensure our sector’s perspectives are fully considered.”
She adds: “While we plan to submit a detailed position in our formal submission based on our members’ inputs, we wish to highlight the following key concerns at this stage.” These are outlined below.
- The time provided for representations (four weeks) is too short to allow industry to make comprehensive submissions.
- The rationale provided for the tariff review does not clearly align with existing government strategies such as the South African Renewable Energy Masterplan, the Integrated Resource Plan, or our Nationally Determined Contributions.
- In our discussions with ITAC, it has been noted that the proposed tariffs are believed to support the creation of manufacturing-related jobs. However, most employment opportunities in the solar PV sector are generated during the deployment and installation phases of projects, not necessarily in manufacturing.
- For instance, a PV module assembly plant with a capacity of 500 MW typically employs only 60 to100 people, as the processes are largely automated. In contrast, the manufacturing of mounting structures can offer 10 times more jobs, with hundreds in the deployment of the technology.
- Any introduction of tariffs on solar components must be guided by a comprehensive value chain analysis, including a detailed assessment of employment potential across the entire PV value chain
- The discontinuation of the solar PV module rebate would be highly detrimental to the sector. Our view is that the current local manufacturing capacity is less than 15% of domestic demand and likely to decrease based on the project pipeline. Scaling to 50% or more will take several years and hinges on a stable electricity supply. In the light of our recent electricity challenges, investors may be cautious. In addition, the existing rebate system has already been constrained by limited administrative capacity within ITAC.
“SAPVIA remains committed to constructive engagement with government stakeholders to ensure that any tariff-related decisions support both industrial development and South Africa’s renewable energy transition. We will provide a full statement and data-driven submission in the coming weeks,” says Melamu.
From SAWEA’s perspective
Speaking for SAWEA, the South African Wind Energy Association, Chief Executive Officer, Niveshen Govender, says that while the association supports the government’s long-term vision to deepen localisation and expand local industrialisation capabilities where possible, it believes that it is essential to jointly determine the best options, avoiding negative impacts on the industry as both global and local energy markets evolve.
“As SAWEA, we are currently engaging with our members to fully understand and unpack the implications of this proposed tariff review. In continuing our efforts to advance wind energy in South Africa, we believe it is necessary to initiate a deeper investigation into the impacts of potential tariffs on the local industry, as well as the deployment of wind energy as part of the energy security plan, and the levelised cost of energy (LCOE) from wind energy.”
SAWEA encourages extensive consultation between government and industry to ensure that any adverse effects are avoided, and the right mechanisms are employed to support the South African localisation agenda. It will be important to ascertain a baseline understanding of the local supply chain and how SAWEA and the industry as a whole can support its continued and sustainable business operations.
As a long-time contributor and participant in the South African Renewable Energy Masterplan (SAREM), SAWEA believes that the industry should localise at a pace and scale that it can afford, with a focus on energy security.
“To fully support localisation at scale, it is important to first ensure consistent and continuous demand for wind energy so that local manufacturing concerns are supported and sustained in the long term,” adds Govender.
While SAWEA welcomes the differentiated approach in the gazette – to consider duty adjustments where local manufacturing is viable and exemptions where it is not – it cautions against the premature removal of existing import rebates or blanket local content mandates that do not reflect current realities in the wind sector.
“Instead, a flexible, incentive-driven framework, aligned with clear procurement pipelines and supported by industrial enablers, such as port reform, logistics coordination, and finance risk-sharing, is key to enabling sustainable localisation,” says Govender.
He reiterates that SAWEA remains committed to working with government, OEMs, and industry stakeholders to ensure that tariff reform balances the urgent need for energy security with the long-term goals of industrial growth, inclusive participation, and a just energy transition.
For more information visit: www.sapvia.co.za and www.sawea.org.za