HS Code 1512.19.10 — Sunflower-seed, safflower or cotton-seed oil and fractions thereof, whether or not refined, but not chemically modified: Marketed and supplied for use in the process of cooking

Get the “cooking use” qualifier wrong on HS 1512.19.10 and SARS will reclassify the entry, claim retrospective duty, and add penalties under the Customs and Excise Act — s78(2) up to R8,000 or treble the goods’ value; s80 up to R20,000 or treble the value or 5 years; s84 (false documents or declarations) up to R40,000 or treble the value or 10 years plus forfeiture; minor cases may be settled under the DA 70 admission-of-guilt procedure on top. In 2024 South Africa imported USD 186.1 million of sunflower, safflower and cotton-seed oil under heading HS 1512 across 187,287 tonnes (UN Comtrade, reporter ZAF, HS 1512, 2024, accessed 18 May 2026), with Bulgaria, Romania and Argentina supplying the bulk — and most of the so-called “Bulgarian” and “Romanian” volume is Ukrainian crop re-routed through Constanța and Varna after the Black Sea Grain Initiative collapsed.

What this HS code covers

HS 1512.19.10 sits inside heading 15.12, which covers sunflower-seed, safflower and cotton-seed oil and their fractions, whether refined or not, but not chemically modified. The heading splits at the 6-digit level into crude oils (1512.11 for sunflower/safflower, 1512.21 for cotton-seed) and “other” oils — refined, partly refined or otherwise processed (1512.19 for sunflower/safflower, 1512.29 for cotton-seed). The South African 8-digit line 1512.19.10 narrows that further to refined sunflower or safflower oil “marketed and supplied for use in the process of cooking food”. Its sister line, 1512.19.90, captures the same physical oil destined for industrial use — biodiesel feedstock, oleochemicals, lubricant blending.

The duty rate is identical on both .10 and .90, but the regulatory pathway, the Port Health treatment and the post-clearance audit risk are not. This is a use-declaration line, not a chemistry line.

South African trade picture

In 2024 South Africa imported USD 186.1 million of HS 1512 product, totalling 187,287 tonnes (UN Comtrade, reporter ZAF, HS 1512, 2024, accessed 18 May 2026). That is down from the 2022 spike of USD 279 million / 177,321 tonnes, when Black Sea logistics broke and the global sunflower-oil price ran sharply. Volume has actually grown 5.6% since 2022; the value drop reflects a roughly 37% unit-price unwind, not a demand contraction.

The 2024 source mix tells the more interesting story. Bulgaria sat at 61.9% (USD 115.3 million, 112,193 tonnes), Romania at 13.0% (USD 24.2 million), Argentina at 12.5% (USD 23.3 million), Netherlands at 7.9% and Ukraine at 1.6%. Russia, which featured heavily in pre-2022 commentary, is absent from the partner list entirely in 2024. The Bulgarian and Romanian volume is largely Ukrainian-origin crop processed and re-exported through the EU Black Sea ports of Varna and Constanța, where it picks up EU origin under the SADC-EU EPA rules of origin. Most of South Africa’s sunflower-oil supply is now sourced from an EU origin even though the seed grew in Ukraine.

On the export side, South Africa shipped USD 87.5 million of refined sunflower oil under HS 1512.19 in 2024, with 96% going to SADC neighbours — Namibia 42.8%, Botswana 34.9%, Lesotho 9.3%, Mozambique 6.9%, eSwatini 2.4% (UN Comtrade, reporter ZAF, HS 151219, 2024, accessed 18 May 2026). SA imports crude or refined oil from the EU and Argentina, bottles or blends locally, and re-exports under SADC origin. If you sell into the BLNS market, the duty-free SADC origin path is the structural play.

Duties and VAT

The General (MFN) duty on HS 1512.19.10 is 10% ad valorem (SARS Schedule 1 Part 1, Chapter 15, dated 15 May 2026). There is no variable-formula duty on sunflower oil despite the mechanism still applying to wheat and refined sugar — the chapter 15 entries are flat percentages.

The Argentine line matters commercially: USD 23.3 million of imports in 2024, no preference. If you bring Argentine refined sunflower oil into South Africa you pay the full 10% — there is no Mercosur shortcut, no AfCFTA shortcut. The only structural duty relief currently in force is EU EPA or SADC origin.

VAT is 15% on the Added Tax Value (customs value plus a 10% mark-up under section 13(2) of the VAT Act 89 of 1991, plus customs duty), payable at clearance and recoverable if you are a VAT vendor.

Note on rebates: there is no general Schedule 4 rebate currently in force for sunflower oil under-supply. Item 460.03 in the current Schedule 4 covers meat and edible meat offal (poultry quotas), not vegetable oils (SARS Schedule 4, item 460.03, dated 13 March 2026). If local supply tightens, a rebate would require a fresh ITAC tariff-amendment application via NAMC or SAFOA — it is not a standing facility.

Documents and compliance

Clearance of refined cooking oil under HS 1512.19.10 is a foodstuff clearance, not a generic commodity clearance. SARS, Port Health and DALRRD will each want documents at entry, and SARS will return for end-use evidence in a post-clearance audit. Plan for both.

Typical document set:

• Commercial invoice with grade specification (RBD — refined, bleached, deodorised) and 8-digit tariff code
• Packing list
• Bill of lading or air waybill
• Certificate of origin — EUR.1 (EU) or SADC Certificate of Origin (SADC), to claim the free preferential rate
• Manufacturer’s certificate of analysis covering free fatty acid, peroxide value and moisture content (proves edible grade and supports the cooking-use classification)
• DALRRD import permit where applicable
• Port Health clearance under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972
• R.146 of 2010 labelling compliance evidence on pre-packaged retail consignments
• Certificate of Acceptability for the storage warehouse under R.638 of 2018
• SARS Customs Code (CCN) for the importer of record

For a post-clearance audit, SARS will typically ask for downstream sales evidence: customer invoices showing the channel of distribution, packaging artwork, and any blending or re-bottling records that tie the imported consignment to a retail or food-service end use.

Common mistakes

The single most common error is declaring the oil under 1512.19.90 (industrial use) to avoid Port Health, then selling the same consignment into a retail or catering channel. The Schedule 1 duty is 10% on both lines, so there is no MFN duty arbitrage — but the use mismatch is exactly what SARS post-clearance audits look for, and the reclassification carries penalties under the Customs and Excise Act — s78(2) up to R8,000 or treble the goods’ value; s80 up to R20,000 or treble the value or 5 years; s84 (false documents or declarations) up to R40,000 or treble the value or 10 years plus forfeiture; minor cases may be settled under the DA 70 admission-of-guilt procedure plus retrospective Port Health exposure under the Foodstuffs Act.

The mirror error is declaring crude oil under 1512.11.10 to cherry-pick the AfCFTA 4% rate when the consignment is actually refined and belongs under 1512.19.10 at 10%. Argentine-origin importers regularly assume a Mercosur preference exists — it does not for Chapter 15. EU-origin importers who skip the EUR.1 paperwork pay 10% on what should have been a free entry: that is a R1.8 million mistake on a USD 1 million consignment.

How JLog handles it

JLog clears refined sunflower, safflower and cotton-seed oil consignments at Cape Town Container Terminal and Cape Town International. We file the entry under the correct 8-digit line, verify the EUR.1 or SADC Certificate of Origin before lodging so the preference is not lost on a paperwork error, arrange Port Health clearance for cooking-use consignments under the Foodstuffs Act, and hold the end-use evidence file you will need if SARS comes back two years later for a post-clearance audit. We handle drums, IBCs, tanktainers and FCL.

If SARS has already queried a 1512 entry — or you want it filed right the first time — get a quote: jlog.co.za/get-a-quote