Draft Policy on Scrap Metal: DTIC briefing, with Minister & Deputy Minister

Meeting report

The meeting began with the adoption of the amended programme for the third quarter.

Minister’s opening remarks
Mr Ebrahim Patel, Minister of Trade, Industry and Competition (DTIC), said that the Department appreciates the opportunity that the Committee has given it and that the Committee was able to adjust the programme and allow their presentation to be put on the agenda for that day. The Executive is busy applying its mind to helpful measures and it would be helpful to hear the comments of the Members before the measures are finalised.

The Minister showed a news segment from the SABC on the difficulties that South Africans face when cables are stolen and they are left without electricity. He said that this was just a snippet of the kinds of experiences that South Africans have across the country. Many have experienced the challenges of cable and metal theft. The challenge is well understood. The presentation will summarise what they know about the challenge, as well as the measures that will be implemented to deal with it.

DTIC Presentation
Minister Patel gave the presentation.

South Africa faces a serious challenge from theft of metal and the associated impairment and destruction of infrastructure. Theft of scrap metal, especially copper cable, imposes costs far beyond the actual value of the material taken. These costs, mostly in the form of disruptions to rail transport and electricity, effectively cut production, inhibit economic growth and service delivery.

South Africa has 25 000 km of railway lines and Eskom's’ network comprises of 33 158 km of transmission and 391 784 km of distribution lines (total of 424 942 km network made of copper, aluminium and steel). The widespread theft of infrastructure is driven by high demand for copper scrap and other forms of scrap metal, particularly for the export market. The estimated theft total from Transnet, PRASA, Eskom and municipalities for 2022 is R46.5 billion. Additional costs, such as those businesses and road maintenance, are expected to be high but further research is required. Other costs, such as risks to safety of communities and workers not able to make it to work due to transport and infrastructure interruptions, are also significant.

Measures have previously been implemented to deal with this issue, such as a price preference system (2013), temporary prohibition on exports (2020) and an export tax (2021). However, these have not been sufficient in eradicating the issue.

The Department proposes a three-phase approach to limit demand and facilitate policing. Some of the main measures include:
-reducing demand by imposing a temporary (six-month) prohibition on the export of waste and scrap metal
-facilitating policing by developing a system to make it easier to focus on an export permit system for semi- finished metal products, and
-the creation of an import permit system for furnaces and various other scrap transformation machines
Interested parties were given 21 days (to 26 August 2022) to comment on the draft policy as well as the draft directives and notices.

(For more details, see the presentation).

Discussion
Mr M Cuthbert (DA) said that while the DA agrees with the impact and urgency needed to attend to this serious issue, they believe it is a law enforcement issue and not a trade policy issue. The facts are that the Second-hand Goods Act has not been properly implemented, SAPS is under resourced to tackle this crime and local governments are fighting this battle alone. He has been on the ground personally in the municipalities that the DA governs to see what the effects are first hand and this is exactly why the DA put forward a proposal to stem the tide of vandalism and theft of public infrastructure. The DA has also put forward a request for an urgent debate which will be taking place on 1 September 2022.

If one looks at the data over the last couple of years, there has been a 74% drop in the export volumes of ferrous scrap and a 92% drop in the exports of volume of copper. There is an increase in the volumes of blister copper from 0.5% to 76% in export volumes. This is because, in his view, people are going out with scrap metal to table top furnaces and melting it down and trying to dodge the tariff quota on exports. It’s not as if they are necessarily exporting the scrap in its raw format. It is being melted down by people who have not yet been targeted by SAPS and law enforcement, and then being exported. This particular ban being proposed does not cover any of these facts. If this ban is to go ahead, there is going to be a R21 billion loss in aluminium if it is implemented. It has been seen that Kenya implemented a ban earlier this year and they quickly rescinded it because it failed to address the theft and vandalism of infrastructure. There were also economic consequences for local jobs. There was a three-month ban in South Africa in 2020. Before the ban, used beverage cans were R9 per kilogram and were collected by waste pickers. Once the ban had taken effect they were R3 per kilogram. Nobody wanted to pick them and the cans piled up. Hoedeman (spelling unconfirmed) actually approached the DTIC because it was not being collected and they required the feed stock for their own production of goods.

What is not wanted locally is then exported. Columbus issued a note earlier this week stating that they are no longer purchasing aluminium scrap because they have it in excess. Where is all this scrap going to go, if it is not being exported and there is no local demand? Scrap is currently trading below the PPS price, yet the export volumes have continued to fall. Where is the scrap being exported to in the great extent that the Minister has said it has? If the ban was to proceed with all the listed tariff codes, there will be over a R31 billion economic loss over a year and R50.5 billion over six months. That would be coupled with the fact that South Africa would lose R46 billion (in his view it is closer to R187 billion) from this kind of crime. All together it would be a loss of over R200 billion. This ban is not going to work in fighting the scourge. They need to law enforcement on the ground and to make sure that people who are illegally trading are prosecuted.

What does the Minister base his comment on that the previous ban caused minimal harm to the industry? That is not the view that the data indicates. Waste pickers will collect glass, paper and plastic and if they are not collecting metal, it means that there is no value and there is no incentive to collect. Things like wheelbarrows and stoves won’t be collected. These are exactly the kind of products that are exported for international consumption. How are they going to compensate for the loss in the income of waste pickers? It was indicated in a DTIC document that between R300 million and R750 million has been saved by landfills because of waste pickers.

What will happen with all the scrap and where will it physically go if this ban is to be instituted? The premise of this ban is due to the lobbying of the Minister by his working group. They want to ensure that they get the kind of trade policy that they want, that will benefit their own businesses and make sure that the IDC funding that they have received is safe, and that they will be able to “make a buck” off of it. This requires either private sector investments in infrastructure or government expenditure in infrastructure. The private sector is currently on an investment strike. If one looks at the percentage of GDP spent on infrastructure over the past 12 years, it has been steeply declining. Where exactly is all of this steel going to be used in an infrastructure drive? It cannot justifiably be said that there is an infrastructure drive, when as a percentage of GDP it has declined significantly. If the export of scrap metal has declined but the export of blister copper has increased, could the Minister explain why this phenomenon has occurred? With other matters of this nature, they’ve had stakeholder engagement where they have allowed for all members of the community to present their view. It is premature to rely on the fact that there has only been 21 days to comment. They need a formal process where all members of the value chain, from the top to the bottom, are able to provide their views to the Committee so that they can provide an informed opinion to the Minister. They have been too hasty and the economic consequences that may be wrought on the South African public have not fully been calculated yet. Whilst the DA urges the government to take action, they need to make sure that they are directing the necessary resources to law enforcement and making sure that the NPA has sufficient prosecuting capacity. They have had relevant legislation in place to root out this scourge. All the necessary steps need to be taken and they need to make sure that they are able to protect the economy. If they fail to do so, then South Africa is in serious trouble.

Mr F Mulder (FF+) said that he was privileged enough to serve in the Gauteng legislature. When he served on the Portfolio Committee for Community Safety, they performed investigations into the same issue. That was almost fifteen or twenty years ago. Since then, nothing much has changed for the better and they are now facing a huge problem. Scrap metal is a well-known hot commodity, almost in the same league as diamonds, liquor or drugs. If one looks at the devastation that drugs and the misuse of alcohol has caused in society, this issue of metal theft calls for extraordinary measures. Bans on any type of trade or industry will have a serious impact and detrimental effect on the economy. This can be seen by the alcohol bans implemented during Covid-19. There will be unintended consequences, which Mr Cuthbert referred to. They will not be able to sort out this issue in isolation, such as only focusing on laws. There are two other areas that need to be focused on as well. The first is imposing legislation. One could restrict but this will certainly have unintended circumstances. There also needs to be a proper policing system, especially crime intelligence. Not just crime intelligence in the police, but crime intelligence in the DTIC. There should be a crime intelligence department within every Department. State capture and corruption are big issues and this would help. A similar occurrence is happening within the diamond industry and it will be the same with the illegal trade in scrap metal. They also need to focus on moral regeneration in South Africa. One can impose as many Acts and rules as they want to, but if there is not proper policing and there are no morals or moral regeneration, there will be no progress. He recommends that the DTIC focus on moral regeneration and law enforcement, and be very careful with any restrictions and bans because of its effects on the economy.

Mr Z Burns-Ncamashe (ANC) said that he agrees with Mr Cuthbert’s point about this issue coming to the Department as a consequence of that which ought to have been done at other levels. There is a paradoxical symbiosis between that which is characterised as black market trade and that as white and blue collar crime. This should be looked at in relation to the figures that the Minister referred to. These figures are not hundreds of thousands but are actually billions of rands. This shows that the industries involved here are not small enterprises – these are big businesses. If one looks at the ammunition that they use, it demonstrates that this is a well-orchestrated sophisticated network. They aim at nothing but economic sabotage. If this issue is looked at as an economic sabotage, one will have to concede advisability of a multi-pronged approach. A multi-pronged approach would involve inter-cluster meetings. Economic and security clusters would meet together to find the best possible solution that would be practically manageable for the Department. The solutions need to fit within a trade-regulated framework and operate within the legal framework. There is a lot of work that would have required an intervention at the level of the intelligence, hence the reference to the security cluster.

When it comes to exporting these illicit goods, the systems operating within South Africa need to be tightened. If South Africa is not very strong when it comes to border management, these goods may find a way to leave our borders and be exported elsewhere. While it is a matter that needs to be dealt with in South Africa, it must also be dealt with at the level of the region and the continent. These assets that are being stolen may be located in South Africa, but they also belong to the continent. These assets are there for the benefit of the region and the continent. Surely there is space for this within the existing frameworks, such as the African Continental Free Trade Agreement? Agreements such as these may have a role to play in rooting out illegal trade practices like this. He welcomes the presentation from the Minister but says that they should consider this as not only a South African problem. They also need to make sure that they strengthen the district development model to ensure that all of the spheres of government are able to work together. Some of the contributory elements fall within concurrent competency, apart from national exclusive competency. There are also those that will be within the municipal purview, hence the need for a cooperative governance system. Sections 40 and 41 of the Constitution already covers that. This is not just a matter of policy. When it comes to coordination, it is a Constitutional injunction. Government needs to be aware of this so that they are able to work together and achieve a common goal under a common purpose. This will ensure that they put a stop to the absolute haemorrhage of the economy and economic sabotage. 

Mr S Mbuyane (ANC) acknowledged that the matters raised in the presentation are very important. The presentation raised the fact that there is more than R400 000 kilometres of cable and copper theft, which amounts to billions of rands. The presentation mentioned the need to address a shortage of supply in the domestic market. The Minister said that a price preference system, a temporary prohibition and an export tax has been implemented. What is the view of ITAC on this matter? At one stage they used to regulate exports and imports in South Africa and foster economic growth. He supported Mr Burns-Ncamashe’s view about the importance of inter-governmental cooperation. How can the Department, the SAPS, SIU, DTIC, SARS, etc. engage with each other to try and deal with this issue? It is a broad syndicate and it involves a lot of criminals. What is the Department’s vision for this cooperation? They should also listen to the views of the community to see what can be done by Department to resolve this issue. They also need to investigate border agents and see how these materials are being exported out of the country.

Mr C Malematja (ANC) said that if they are not proactive when it comes to dealing with this issue, like the Minister is being, then they will always be reacting to the issue and this is not what they were elected for. The Executive has done a very good job in being proactive. The proposal cannot wait to be implemented any further. People lament that they cannot use the trains reliably. The Executive has been proactive to ensure that these people will not have to lament anymore. This action has been the result of these lamentations. This crime has caused havoc on the economy and people have been forced to rely on other forms of transport. We have a reliable and cheap mode of transport and it is being destroyed.

The Executive has come in with these solutions. Not every proposal has the intention of corruption. By assuming this, one is implying that the Executive of Cyril Ramaphosa is very corrupt because everything that has been brought forward to the Committee is questioned about its potential for corruption. These solutions are not potential spaces for corruption. These solutions are what the Department and the Members think will work best to resolve the issue and improve the economy. The Committee needs to understand that in the economy they are in it together, and that there is “no us or them.” They should not be playing politics when it comes to this issue. Certain people attempt to “derail” the government and then when it comes to 2024 they will claim that the government have “done nothing.” This example is similar to the issue of the Zama Zamas. The Committee knew about the Zama Zamas and yet they accused the Executive of not being proactive. The DTIC has done very well and it should proceed with these solutions to make the South African future better.

Minister Patel explained that the Department is facing an issue of enormous magnitude and it was faced with the task of how to deal with it effectively. All of the advice that they have relied on have all pointed to the same thing – that they need multiple measures to disrupt the crime syndicates. It is not one measure versus another, it is a combination of multiple measures. The Members’ comments were helpful and allows the DTIC to set out their solutions more clearly.

Earlier Mr Cuthbert raised the point that this is solely a law enforcement issue. He acknowledges Mr Cuthbert’s view and it is different to a large number of persons and institutions that they have consulted. They commissioned two research institutions. Both Genesis Analytics and TIPS believe that a comprehensive response is needed and the DTIC draws strongly from their insights. Department officials have also applied their minds to this matter and they have concluded that a number of different measures is required, in addition to policing. The police themselves have given the DTIC feedback and they believe that there is more that they can do, but that in addition to that, other measures are required. Ministries that are responsible for infrastructure and work every day with the realities of cable theft have consulted with their entities and their advice has been similar. It is true that policing must be an element of it. It is a necessary condition. On its own, with the current systems in place, it is not a sufficient condition. The reason for this is set out in the presentation. There are 600 000 kilometres of network (such as copper or steel cable), all of which is potential targets. There are hundreds of thousands of separate places, from a drain cover to a school window to a traffic light, all of which are also potential targets. To assume that the police can be asked to cover all of this is not a very viable solution. It may be an easy answer that is given, but when one governs, one needs to look at the reality of the problem. The current solutions by Transnet, Eskom, Telkom, and others are extraordinary and also involve security – what can be done with drones, cameras, patrols etc. Municipal offices and offices within public entities have been set up and given certain powers that would ordinarily be reserved for law enforcement agencies. All of these measures have been helpful but are not sufficient. It will be sufficient when additional measures are put into place. SAPS has been increasing their raids across the country and setting up infrastructure task teams deployed in hotspot areas. There will be a public launch by SAPS in September and police have made more arrests. More focus has also been placed on intel so that the police better understand the networks and will be able to address the nerve centres of these syndicates. However, while this is occurring, ordinary citizens are being encouraged to steal by these syndicates on the basis that they would make easy money. This is actually not easy money as the country pays an enormous cost for this. The DTIC agrees that law enforcement should be part of the mix, but this not only a policing issue. The facts don’t bear out this contention. Some of the solutions that they are contemplating will make policing easier, such as registers where the sale is required to be recorded. Legislation will also be implemented that will not permit cash transactions for scrap metal. These are measures that will take a while to be put into place. Mr Cuthbert will appreciate the law of demand and supply. When there is a massive demand, as there is with both domestic demand and exports, when the legitimate supply is low, then the price of genuine scrapped goods will go up. When the price goes up, then there is a greater financial incentive for people to act illegally. Mr Mulder made a good point about moral regeneration, which the Minister endorses. There needs to be a set of measures or a campaign to demonstrate the enormous cost of this kind of theft. For example, the issues that hospitals have when the electricity is cut off because a cable has been stolen.

Mr Cuthbert mentioned that the export volumes of ferrous metal had gone down, while semi-processed products have gone up. This shows that any measure that the Department is contemplating cannot work. The Minister pointed out that in paragraph 246 of the gazette, it says that “stolen scrap metal may be exported as scrap or transformed into either semi-finished or finished metal and then exported. In addition, traders often make false declarations for their exports. Copper scrap is often declared under a non-copper export HS code, EG steel, or another metal. Moreover, scrap metal is routinely exported under a semi-finished HS code, even when the product is still in scrap form and has not been processed into semi-finished product. Exporters utilise this tactic to evade the more stringent conditions currently applied to scrap exports, including the application of the price preference system and the export duties.” He said that in paragraph 249, it says that “another difficulty is that low-cost smelters or shredders can currently be purchased on international markets at comparatively low cost. Once the scrap has been melted into pellets, chopped and shredded, the original source of the metal cannot be identified. Thieves and syndicates can then operate in the open, openly storing, trucking and coordinating the buying and selling of shredded and melted metal, both locally and across the border.”

In order to address that in the context of theft, the proposals include not only dealing with the raw scrap metal but also semi-processed product. There are a range of proposals dealing with semi-processed products and the Department would like the views of the effected parties before finalising these proposals. There is no need for the Minister to speculate what the reason is. When there is a regulation that the syndicates believe will block them, they find ways to evade it. It happens all the time with all regulations. The tax system is replete with examples that the minute the Tax Commissioner has a provision in place, then people seek ways to avoid it. The DTIC has learnt from that and the measures that are being contemplated now are on semi-processed products and will go a long way in dealing with that. It will limit the ability of people to disguise the content of stolen products, and this is where the regulations on furnaces and other machinery come in. They will not be prohibited, just licensed and regulated so that they are able to see whether workshops are being used as chop shops to disguise the origin of metal. It is not the last issue that will attempted to be evaded. It is an ongoing battle and there are enormous profits to be made by scrupulous businesses at the expense of hard-working people who run ethical businesses. The Minister said that as a society, we need to make a choice. Are we going to make it easy for those who are benefitting from illegality? Or do we disrupt them? In any action that is taken, there will be consequences for others. These need to be as limited as possible and that is why they are not proposing a ten-year prohibition on exports. The proposed ban is meant to provide the Department with the space and the ability to reduce demand in the short term while they put other systems that are more effective and less onerous into place.

Mr Cuthbert mentioned Kenya’s ban. The government gazette addresses this. In paragraph 254, it says that “Kenya recently imposed a full prohibition on all trade and scrap metal. In 2010, Kenya implemented an export prohibition on scrap metal that was formulated into law in 2015. However, this was insufficient to stop the increase in metal theft. In 2022 the Kenyan government implemented the full prohibition on the trade of scrap metal which was only relaxed after the government had created a new trading regime which includes a host of local restrictions and licensing requirements.” Kenya has followed an interesting path which is not dissimilar to what is being proposed. They put a prohibition in place initially and then they developed a system. More details on this have been provided in the gazette.

Mr Cuthbert questioned where the products that have export bans on them end up. The presentation dealt with this question. The presentation took the Members through the work that has been done by external researchers. The ban has been proposed to be implemented for a six-month period. In that period, there is still a domestic market that services at least some of the products. When the system has been fully developed and designed, then genuine scrap will be able to be exported after that six-month period. Within that six-month period there will still be a local market for product. In policy, when choices need to be made, there are costs with any choices. If nothing is done, then there will be a massive cost to society. Focusing only on the police will leave a significant part of the market satisfied through illegal means. The cost of this on society is enormous. There is a cost to the measures contemplated in the gazette. There is no question about it and some players will pay this cost, even if it is just for a period. Policy is about weighing up the costs on the different players and the benefits that different players may have, and to look at how society as a whole benefits or loses. This task of weighing up options is what policy is about. Any decision comes after a careful weighing up of all the costs and benefits. Citizens do the same with daily choices and with every choice comes advantages and disadvantages. Simply to point to the cost without recognising the enormous benefit will lead to weak or no decisions being made. The gazette has been published for public comment. This will give affected parties the opportunity to share their views. There may be something that the Department has not taken into account. This is possible and the DTIC is not defensive about it. They will weigh this input and make a decision based on all the advice that is available.

Mr Cuthbert said that the true cost of the measures need to be identified and cited a loss of R187 billion because of theft. This figure has been estimated by some of the calculations that have been done. The presentation included figures provided to them by Genesis Analytics, a well-respected independent researcher. Genesis Analytics have not done a complete costing of all the damage done, such as the damage to businesses and to citizens who cannot catch reliable transport or have a reliable electricity source. The true cost is significantly above the R46 billion mentioned in the presentation. Extraordinary measures are required to combat these costs and the Minister appreciates that Mr Cuthbert helped him to make this argument. The cost on the society is not only financial and this should also be taken into account.

Mr Cuthbert said that waste pickers will be negatively affected and questioned why the presentation said that impacts were minimal. The Minister said that they have taken into account the disruption that any measure can have, across the board. Waste pickers do not only pick scrap metal. A lot of it is the collection of plastic and paper which are not affected by the measures. Measures are also proposed which will deal with the organisations, such as UNIDO that work with informal waste pickers. Waste pickers currently collect glass, plastic, and paper. There is a good opportunity for the waste pickers to formalise their work into businesses that can register and get the benefits of the trading regime that is being put into place. During that six-month period, there will still be a legitimate business in which steel minimals and foundries and mills utilise scrap metal.

Mr Cuthbert pointed out there was lobbying from industrial groups to the Minister to implement these measures so that they can benefit, such as South African producers who use scrap metal to produce products for South Africa’s infrastructure programme. The Minister said that he would be keen to hear their view. The products that they make are vital to South Africa. Without steel minimals and foundries, jobs would be lost. Furthermore, where will they find the infrastructure that these businesses produce? South Africa needs energy supply and power stations, and all of this requires the products from these foundries. If they have views, they need to be taken into account. However, they are not the originators of this proposal. This proposal comes from parties, including the police and a number of public entities, which have to deal with the theft of public infrastructure. The industrial interests are legitimate, and if they were behind this proposal, he would have no difficulty in admitting this. However, this is not the case.

The Executive has to exercise the power and responsibility that it has, as outlined in the Constitution. The Executive is obliged to act on the problem. They want to take into account the opportunity of the various stakeholders, so they have given them the opportunity to make comments. It is also very helpful to hear the view of Members of Parliament, even though ultimately the Members will be responsible for any oversight of measures that are implemented. The more the Department hears, the better the ultimate decision-making will be. Sometimes it will reinforce their view, or it will challenge them and force a re-evaluation. These views are helpful but as the Executive they need to do what is within their Constitutional duties, and that is to act swiftly on problems that is brought to their attention.

The Minister thanked Mr Mulder for his insight into the work that he has done previously around this issue. He said that the Member had made an interesting point by saying that some products in society require regulations and limitations and that scrap metal has now become one of those products. He agrees with his point about moral regeneration and that communities need to act against metal theft by reporting such instances. This will be a symbol of refusing to support those that have done harm to South Africa. The law is only one element. Years ago, Parliament agreed to the massive stepping up of measures to deal with metal theft by increasing the sentencing to 30 years, by limiting bail conditions, and by creating a punishable offence. However, there is only so much that policing can do and other measures are needed to disrupt these syndicates. The Minister urged Mr Mulder to support the DTIC in the wide range of measures that have been taken, given the damages that have been caused by this crime and the effect that is felt by the constituents.

The Minister said that Mr Burns-Ncamashe made a good point about regional cooperation. The DTIC has already briefed Trade Ministers in SACU countries of the challenges that South Africa faces and indicated that South Africa will be seeking their support in both law enforcement and coordination to deal with the cross-border aspects of this trade.

He thanked Mr Mbuyane for his comments about the damage of theft. Government has taken measures previously to address the shortage of supply in the domestic market. They found that those measures were adequate, fit-for-purpose and even though there had been some public criticism of the price preference system and the export tax, they worked. They helped to supply raw material to domestic producers and allowed for South Africa to meet its climate change goals better. When scrap metal is processed in foundries, the energy intensity is lower than when iron ore is used. The new proposed measures are not intended to address this issue because these measures have been successful in creating a local supply. ITAC is part of the team of entities that have been advising the Department. Not only are they responsible for trade administration, they also have experience with the price preference system. ITAC will await a trade directive. A draft trade directive has been published for public comment. After the public comment is concluded, decisions will be made and ITAC will adjust their administrative systems accordingly.

Very large businesses have been built on cable and metal theft. There have been reports of special training facilities that have been set up. A sophisticated network has found the opportunity to plunder and destroy public infrastructure and make money out of it. For enterprises like this who have created a business model out of turning a blind eye or actively encouraging theft, the proposals in the government gazette is bad news. It will disrupt their business model and make it difficult to monetise the value of the stolen product that they have. For ethical lawful businesses, they will find that beyond the six-month period, they will adjust their business model to the measures that the DTIC will put into place. Many businesses are affected by this type of theft or even close, such as those that are left without electricity or whose workers arrive late because the trains aren’t working. These businesses would welcome the proposed measures. The Department may strengthen or loosen some of these measures based on the input they receive from the public. The matter needs to be dealt with urgently. When the President addressed the nation on the energy crisis, it was about government moving in to an expedited mode on any matter relating to energy. This theft does affect energy supply.

Mr Malematja made the point that there is a complaint about the impact of metal theft in many cases. These complaints need to be followed by measures which will fix the issue. These two facts need to have a relation – there needs to be a mindset of ‘because we have this problem, we need to do things differently.’ Effective policing is needed and there is currently widespread action by the police. The police themselves have said that other measures are also required.

Concluding remarks
The Chairperson noted that Ms N Motaung (ANC) supported the proposed measures, and that she was unable to share this because of a technical issue. She informed Mr Cuthbert that stakeholders have until the end of the week to comment on the draft proposals. She urged Mr Cuthbert to make sure that the parties that he felt were not being represented voice their views.

Mr Mbuyane said that he supported the proposed measures because this issue hugely impacts the economy. The measures proposed in the gazette will assist the country in moving forward.

The Chairperson thanked the Minister and his team.

The meeting was adjourned.