How good is your memory? In the context of this column, this depends on whether you are a regular reader.

How long does it take the International Trade Administration Commission of South Africa (Itac) to conclude a tariff application? That depends on who you ask. Now, for your recall, according to Itac’s ‘Tariff Investigations’ booklet: “The commission carries out its investigations speedily and with rigour. “The timelines have been revised to ensure speedy delivery of the instruments. It now takes the commission generally four months for sectors in distress and six months for normal investigations.”

However, according to the Engineering News & Mining Weekly edition published on September 23, 2025, on average, tariff investigations take 27 months to complete.

The latest Itac tariff application is for a “review of the tariff structure for input material, components and final goods used in the renewable energy value chain”. Stakeholders have been invited to submit comments by no later than April 24. This explains the headline of this piece, which is extracted from the last part of a famous quote attributed to social critic George Carlin: “Electricity is really just organised lightning.”

Itac published the initial tariff application for a period of four weeks for interested parties and cited three reasons for the review. The first is that global decarbonisation commitments are presenting new opportunities for the growth of a strong South African supply base of renewable energy components and finished products, battery storage units, as well as green consumer goods. The second is that the domestic demand trajectory, the raw material resource base, technological capacity and manufacturing experience place South Africa in a potentially strong position to become a key player in regional and international supply chains. Thirdly, if carefully balanced, an improved tariff structure will increase the demand for, as well as the supply competitiveness of, locally manufactured products and components. This will further enable export market opportunities and enhance the competitiveness of the local renewables value chain.

Fast-forward to the recent publication – “in excess of 45 submissions” were received from interested parties, and these ranged from requests for duty increases, consideration of certain products for possible relaxation of import controls, consideration of specific products for inclusion under local content requirements, a review of the list of products authorised for importation under the staged consignment policy, and other general comments on the potential impact of the review on the renewable energy value chain.

Based on these submissions, as well as analysis of the evidence before Itac, the following six preliminary determinations have been made to the Minister of Trade, Industry and Competition.

• That ordinary customs duties on the specified tariff lines be increased to their respective World Trade Organisation (WTO) bound rates, where policy space exists, and subject to further assessment during the investigation.

• That the ‘general’ rate of customs duty on fully assembled lithium-ion batteries be increased to the WTO-bound rate of 15% ad valorem, by way of creating a new eight-digit tariff subheading.

• That a phased approach be taken for the possible discontinuation of Rebate Item 460.16/8541.43/01.06, which will continue to apply in the interim and will only be discontinued once the domestic solar PV assembly capability reaches 50% of domestic demand.

• That solar panels, single-axis trackers, inverters, fasteners and tower sections be considered for designation under the Public Procurement Act of 2024 for local procurement and local content requirements.

• That there is a need to exclude solar panels, single-axis trackers, inverters, fasteners and tower sections from qualification under the staged consignment policy, as some domestic manufacturing capacity exists in these subsectors.

• That a committee comprising industry role-players be established to advise Itac on trade measures related to the renewable energy value chain.

Trigger warning: Itac will make its final determination after considering the comments on its recent publication. How long will this take? Only time will tell – tick-tock!