The Electrical Contractors’ Association of South Africa (ECA(SA)), representing a national membership of registered electrical contractors and industry stakeholders, hereby submits its formal objection to the preliminary determinations published by the International Trade Administration Commission of South Africa (ITAC) under Government Gazette No. 54420 dated 27 March 2026, recommending an increase in import duties on lithium-ion batteries and related renewable energy components, including measures affecting inverters, under Notice 3864 of 2026.
ECA(SA) notes that no final determination has yet been made and submits these representations within the four-week comment period provided. We urge the Commission to give full weight to the concerns raised herein before finalising its recommendations to the Minister of the Department of Trade, Industry and Competition (DTIC).
- Industry Representation and Public Interest Role
ECA(SA) is a national contractors’ association representing registered electrical contractors across South Africa. Our members are directly involved in the deployment of small-scale embedded generation (SSEG), battery energy storage systems (BESS), and grid-support solutions. This submission is made not only from an industry perspective, but in the broader public interest, including considerations of safety, compliance, affordability, and energy security. - Impact on Electrical Infrastructure and Grid Stability
South Africa’s constrained electricity supply necessitates rapid and widespread deployment of distributed energy resources. Battery storage and inverter technologies are critical in:
•Supporting grid stability
•Enabling peak shaving and load shifting
•Reducing pressure on Eskom infrastructure
The proposed duty increases will directly inhibit the rollout of these technologies, delaying critical support to the national grid at a time when deployment cannot afford to slow. - Affordability and Compliance Risk
Increased equipment costs will not only reduce adoption rates but may also lead to unintended consequences, including:
•Increased use of non-compliant or uncertified equipment
•Growth in informal and unregulated installations
•Compromised electrical safety standards
ECA(SA) is particularly concerned that higher costs will drive consumers toward unsafe alternatives, undermining the objectives of SANS 10142 and national electrical safety regulations. - Misalignment with Energy Policy Objectives
The preliminary determinations appear misaligned with South Africa’s stated policy direction, including:
•Accelerated renewable energy adoption
•Expansion of embedded generation
•Just energy transition commitments
Policy instruments should reduce barriers to entry for enabling technologies, not introduce additional cost burdens that slow the very transition they seek to support. - Precedent: The Solar PV Module Experience
South Africa’s experience with the 10% import tariff on solar PV panels introduced in July 2024 provides a relevant and cautionary precedent. Rather than stimulating local manufacturing at scale, the measure primarily translated into higher system costs and slower project rollout, with limited domestic production capacity able to respond in the short term. The OECD’s 2025 Economic Survey of South Africa similarly noted that import tariff increases on photovoltaic equipment risked mainly producing higher costs and supply shortages, rather than the intended manufacturing development.
ECA(SA) is concerned that without demonstrated and competitive local manufacturing capacity, the proposed duty on lithium-ion batteries — and the procurement and consignment measures affecting inverters — will produce the same outcome: increased costs passed on to end-users, with no commensurate benefit to domestic industry in the near term. - Premature Protection of Local Manufacturing
While ECA(SA) supports localisation and industrial development in principle, current domestic manufacturing capacity for lithium-ion batteries and advanced inverter technologies remains limited in scale, technology maturity, and cost competitiveness. Implementing duty increases ahead of proven and competitive local capacity risks distorting the market and creating supply constraints without viable alternatives for contractors and consumers.
ECA(SA) notes that Preliminary Determination 3 in the Gazette itself acknowledges this principle, providing that the discontinuation of the solar PV rebate should only occur once domestic assembly capability reaches 50% of domestic demand. We submit that the same standard of evidence should apply before implementing duty increases on lithium-ion batteries. - Economic and Employment Impact Across the Value Chain
The electrical contracting sector is labour-intensive and supports thousands of skilled and semi-skilled jobs. Reduced installation volumes will directly impact contractors and installers, suppliers and distributors, and technical support and compliance professionals. Any policy that suppresses demand in this sector risks amplifying unemployment at a time when job creation remains a critical national priority. - Cumulative Cost Burden on Consumers
End-users are already facing escalating electricity tariffs and significant cost-of-living pressures. Additional duties on energy-enabling technologies will extend payback periods for solar and storage systems, reduce the investment attractiveness of private energy solutions, and slow private sector participation in addressing South Africa’s energy challenges. - Recommendation
ECA(SA) respectfully recommends that:
•The preliminary determination recommending a 15% ad valorem duty on fully assembled lithium-ion batteries be withdrawn; or
•Any such duty be deferred until independently verified local manufacturing capacity can meet a substantial and competitive portion of domestic demand — consistent with the 50% threshold already embedded in ITAC’s own Preliminary Determination 3 regarding solar PV;
•The procurement and consignment measures proposed for inverters be similarly deferred pending an evidence-based assessment of their impact on the contractor sector and end-users.
Further, ECA(SA) strongly supports Preliminary Determination 6 — the establishment of a Committee comprising industry role players under Section 23 of the International Trade Administration Act 71 of 2002. We welcome the opportunity to participate in such a structure and advocate for its early convening. - Conclusion
The preliminary determinations, while intended to support localisation, risk the unintended consequences of reducing renewable energy deployment, increasing safety risks through the use of non-compliant alternatives, constraining economic activity across the value chain, and undermining national energy resilience.
ECA(SA) urges ITAC to adopt a balanced and evidence-based approach — one that supports both industrial development and the urgent need for accessible, safe, and scalable energy solutions across South Africa. We appreciate the opportunity to engage in this process and remain available for further consultation.
Date: 20 April 2026
Submitted by:
Grant Seeman
National Technical Advisor
Electrical Contractors’ Association of South Africa (ECA(SA))
Tel: 012 342 3242 | Email: grant@ecasa.co.za
