April’s legal update has arrived — proving once again that while South Africans are digging out scarves, side-eyeing the first cold fronts, and pretending they’re emotionally ready for winter, the regulators are still fully committed to paperwork season.
Here’s what went down in the thrilling universe of environmental, health & safety and foodstuff laws this month:
- The energy sector now has categories. Lots of them. From miners to appliance manufacturers to basically anyone who’s ever looked at a plug point too intensely, government would quite like your energy data, thank you very much. If you use enough energy to power a small province, registration may soon become your new hobby.
- Carbon Tax got another tweak because apparently carbon legislation reproduces faster than load shedding schedules.
- The rhinos received a brand-new 10-year management plan. Honestly, the rhinos are now probably more strategically managed than most South African group projects.
- Water users who forgot to register, update, notify, substitute, amend, report, disclose or generally communicate with the Department since 1998 have officially been summoned. Borehole owners using water commercially are especially being side-eyed right now.
- In workplace safety news: engineers may soon need shiny new competency certificates, while the Compensation Fund kindly extended the third-party registration deadline to 2027 — because even government realised six months was optimistic by South African standards.
- Foot-and-mouth disease vaccination plans are under discussion, which means the livestock industry remains one cough away from a national panic.
- Mayonnaise regulations have been updated. Yes. Mayonnaise. Somewhere in Pretoria, a very serious meeting definitely took place about salad dressing compliance. Importantly, industry now has until April 2027 to emotionally prepare.
Municipalities also kept busy:
- Mbombela upgraded its waste by-laws with extra forms, tariffs, classifications and enough annexures to qualify as a university textbook.
- Buffalo City published an Air Quality By-law that will only take effect once Council decides it feels ready. No pressure.
- Prince Albert also entered the air quality chat.
- Nkosazana Dlamini-Zuma Municipality introduced new business licensing rules, presumably because paperwork builds character.
And finally, the standards people had the time of their lives:
- New rules for explosive atmospheres.
- New rules for flame arresters.
- New rules for arc-flash PPE.
- New respiratory equipment standards.
- New circular economy data sheets.
In short: if it can explode, emit fumes, breathe air, use electricity, contain mayonnaise, or touch water — there’s probably a new regulation for it.
Winter may be approaching, but the compliance officers will still be clutching red pens and regulatory annexures while the rest of the country fights over heaters, hot chocolate and whose turn it is to buy firewood for the braai.
You can read the detailed April 2026 newsletter below or download it here:
NATIONAL LEGISLATION
ENVIRONMENTAL LEGISLATION
1) National Energy Act
- Draft Regulations on the Mandatory Provision of Energy Data
Draft Regulations were published for public comment. Should they enter into force they will repeal the 2012 Mandatory Provision of Energy Data Regulations.
The category of data providers was extended and the draft Regulations now include:
- Category A: Holders of exploration or mining rights
- Category B: Holders of production rights to carry out the production of primary energy commodities, or to import and export primary energy commodities.
- Category C: Electricity generation under a licence; petroleum production under a licence; gas liquefication or regasification under a licence
- Category D: Transportation, transmission or distribution of any form of energy under a licence
- Category E: An industry association representing a collective of entities operating within the same industry
- Category F: An end user of energy, which includes an entity carrying out economic activities as classified according to the Standard Industrial Classification (SIC)
- Category G: An organ of state, research institution or academic institution
- Category H: An entity operating in the Industry Group 363 for household appliances under the SIC Code 36.
Categories A – E, H and data providers under F whose annual energy consumption exceeds 160 terajoules (TJ) must register within 90 days should the Regulations enter into force.
Reg 5 sets out the reporting requirements.
Annexure A contains various SIC codes for different industrial sectors.
2) Carbon Tax Act – Amendment
The Act was amended by the Rates and Monetary Amounts and Amendment of Revenue Laws Act, 3 of 2026, and the Taxation Laws Amendment Act, 5 of 2026. Legal register users can access the updated law where changes are indicated in red.
3) Biodiversity Act
- Biodiversity Management Plan for Black and White Rhinoceros in SA 2025-2035
The new management plan was released which replaces the 2013 and 2015 plans for black and white rhinos respectively.
4) National Water Act
- Notice to register Water Use
While it has been a requirement to register a water use since the Act was introduced in 1998 the notice published on 24 April 2026 (GN 7408 of 2026) calls on unregistered water users to register.
The notice defines an unregistered water user as:
- Water user(s) who bought property/properties from a registered water user(s) but never informed the responsible authority about the change for the substitution of the name.
- Water user(s) who acquired property/properties through the land restitution process, but the change of ownership was never reported to the Responsible Authority for the substitution of the name.
- Water user(s) who are leasing on the property of another water user and/or property owner, where the owner did not register the water use.
- Water user(s) who changed contact details (postal address, physical address, email address, landline, cell phone, fax number) but never informed the responsible authority about change.
- Water user(s) who change their registered name as appeared on their registration certificate but never informed the responsible authority for the substitution of the name.
- Water user(s) who has/have boreholes and are using it for commercial purpose but the borehole(s) is not registered.
- Water user(s) who registered their agricultural water use but never registered their resulting industrial water use(s).
This notice, however, only affects the following water use(s):
- Taking water from a water resource (i.e. river, borehole, dam etc.) (section 21(a) of the Act)
- Engaging in a stream flow reduction activity contemplated in section 36.
The following water users are exempted from registration:
- A water user who falls under the area of operation of the water user association. If the water user has a borehole and is using it for commercial purpose the water user must register the borehole with the Responsible Authority.
- Schedule 1 water users as defined in terms of the Act.
HEALTH AND SAFETY LEGISLATION
5) Occupational Health and Safety Act
- Draft Regulations concerning the Certificate of Competency
These draft Regulations describe how the certificate of competency for a competent person for general machinery must be issued. They further state that a person to whom the certificate was issued shall be deemed to be a certificated engineer as contemplated in Reg 1 of the General Machinery Regulations.
- Delay in the implementation of Third-party Registration
The initial deadline of six months for third parties transacting with the Fund was extended to 1 January 2027 (the previous deadline was 23 July 2026).
FOODSTUFFS AND AGRICULTURAL LEGISLATION
6) Animal Diseases Act
- Draft Scheme relating to Foot and Mouth Disease Routine Vaccination
The above draft Scheme was published for public comment.
7) Agricultural Product Standards Act
- Regulations relating to the Classification, Packing and Marking of Mayonnaise, Salad Cream, Salad Dressing and Salad Oil Dressing intended for sale in the Republic of South Africa
These new Regulations replace those from 2000 (GN R 636 in GG 21313 of 30 June 2000) but will only enter into force on 24 April 2027.
PROVINCIAL LEGISLATION
No relevant provincial legislation was passed this month.
MUNICIPAL LEGISLATION
8) City of Mbombela Local Municipality
A new version of the 2017 Refuse (Solid Waste) and Sanitary By-laws appeared in the Mpumalanga Provincial Gazette. While it seems as if the by-law text is the same, various annexures were added (schedule of fines, tariffs for 2025/26 [sic], various forms (including an application for waste picker integration), event waste management, waste stream classification form, solid waste management activity database registration, waste generator application).
9) Fezile Dabi District Municipality
The municipality published its new Municipal Health Services By-law. The 2009 Municipal Health Services By-law was repealed at the same time.
10) Buffalo City Metropolitan Municipality
The Air Quality Management By-Law, 2024 [sic], was published, although it only takes effect on a date to be determined by the Council, in other words when the municipality finally decides to do so.
11) Nkosazana Dlamini-Zuma Local Municipality
The Business Licencing By-law was promulgated.
12) Prince Albert Local Municipality
The municipality released its Air Quality Management By-law.
SANS AND OTHER STANDARDS
13) SANS 59040:20XX Ed 1 (DRAFT)
This is a draft published by the SABS for comment.
Circular economy – Product circularity data sheet. Establishes a general methodology for information exchange supporting the interoperability of circular economy related information, based on the use of a product circularity data sheet (PCDS).
14) SATR 63491:2026 Ed 1 (new standard)
Live working – Guidance for end users for the selection of personal protective equipment against the hazards of an electric arc. Provides guidance for the selection, use and maintenance of electrical arc flash personal protective equipment.
15) SANS 80079-49:2026 Ed 1 (new standard)
Explosive atmospheres – Part 49: Flame arresters -Performance requirements, test methods and limits for use. Specifies the requirements for flame arresters that prevent flame transmission when explosive gas-air or vapour-air mixtures are present.
16) SANS 60079-14:2026 Ed 6 (amended standard)
Explosive atmospheres – Part 14: Electrical installation design, selection and installation of equipment, including initial inspection. Contains the specific requirements for the design of electrical systems, selection, installation and the required initial inspection of electrical installations of Ex Equipment in, or associated with, explosive atmospheres including requirements for documentation and personnel competency.
17) SANS 60079-17:2026 Ed 6 (amended standard)
Explosive atmospheres Part 17: Electrical installations inspection and maintenance. Applies to users and covers only those factors directly related to the inspection and maintenance of electrical installations specifically designed for hazardous areas, where the hazard is caused by explosive atmospheres.
18) SANS 277:2026 Ed 2 (amended standard)
Respiratory equipment – Compressed gases for breathing apparatus. Specifies requirements for the quality of compressed gas supplied for mixing or use in respiratory protective devices and hyper- and hypobaric operations.
19) SANS 50143:2026 Ed 3 (amended standard)
Respiratory protective devices – Particle filters – Requirements, testing, marking. Specifies particle filters for use as replaceable components in unassisted respiratory protective devices (RPD) with the exception of escape devices and filtering face pieces.
If you have any questions, please feel free to contact us — we’re here for the law, the logic, and the occasional legislative surprise.
Kind regards
MARK DITTKE AND TEAM