What's changed for motor dealers and panelbeaters
The clearest confirmed move in the last year is on the labour side: MIBCO's Administrative Collective Agreement was re-gazetted and now runs from 22 December 2025 to 31 August 2028, replacing the previous agreement text. On the Second-Hand Goods Act and NRCS side, the underlying rules have not changed, but dealers should check current fees and processing times directly rather than relying on older figures.
Reviewed by TefCo Compliance Research — last verified 15 September 2026.
In short
- MIBCO's Administrative Collective Agreement was republished per Government Gazette 53822, Notice R.6924 of 12 December 2025, and runs to 31 August 2028.
- SAPS's Second-Hand Goods Act registration and renewal process (Forms SAPS 601 and 601(e)) remains the current mechanism — no repeal or replacement was found.
- NRCS continues to require a Letter of Authority before an imported, built or modified vehicle is registered and licensed, with its own guidance citing up to 120 calendar days for processing.
MIBCO's new Administrative Collective Agreement
MIBCO has republished its Administrative Collective Agreement as a replica of Government Gazette 53822, Notice R.6924 of 12 December 2025, covering the period 22 December 2025 to 31 August 2028. This is the current reference for scope of application, registration of employers and employees, returns to the Council and council levies — dealers and panelbeaters covered by the Main Agreement should be working from this version, not an older one.
Second-Hand Goods Act: still the same registration mechanism
SAPS's Second-Hand Goods Governance page continues to list Form SAPS 601 for new registration and Form SAPS 601(e) for renewal as the current forms, alongside the 2012 Regulations for Dealers and Recyclers made under section 41 of the Act. No repeal or substantive amendment to the registration and renewal mechanism was found in the sources reviewed.
SAPS periodically updates its process flows and standard operating procedures for second-hand goods registration. Check the SAPS Second-Hand Goods Governance page for the current version of a form before submitting.
NRCS Letter of Authority: confirm fees and timelines before relying on them
NRCS's published LOA1 requirements document sets out a non-refundable application fee and a processing time that can run up to 120 calendar days. Because NRCS revises its fee schedules and forms from time to time, a dealer relying on a Letter of Authority for an import programme should pull the current LOA1 form and fee schedule from NRCS immediately before applying, rather than budgeting off a figure quoted elsewhere.
Frequently asked
Does the new MIBCO agreement change the monthly return date?
The published FAQ position of returns being due on the 10th of every month has not changed with the new agreement's gazetting. Confirm directly with MIBCO if in doubt, since scope and levy detail can change even where the overall return date does not.
Has the Second-Hand Goods Act renewal fee changed?
SAPS's own guidance states that renewal applications are free of charge. Confirm this with your local SAPS Second-Hand Goods office, since practice notices are sometimes updated.
Sources
- MIBCO — Administrative Collective Agreement, replicating Government Gazette 53822, Notice R.6924 (12 December 2025)
- MIBCO — Frequently Asked Questions (returns, levies, registration)
- SAPS — Second-Hand Goods Governance (Act, regulations, forms and process flows)
- South African Government — Police on renewal of registration as a second-hand goods dealer
- Second-Hand Goods Act 6 of 2009 — Regulations for Dealers and Recyclers, 2012 (GN R285, GG 35220)
- NRCS — Automotive: Letter of Authority
- NRCS — Requirements for Application for Letter of Authority (LOA1)
TefCo Corporate Compliance (Pty) Ltd is a compliance management platform, not a legal, tax or advisory firm. This guide is general information, not advice. Fees, dates and thresholds change — confirm current figures with the regulator before you rely on them.
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