Saber Desk · Free article

The MIM product declaration — who it actually affects

Published 3 September 2026 · Updated 3 September 2026 · 6 min read

What the requirement is

For products on a specific, appendix-listed set of HS codes, SASO requires an approved product declaration from the Ministry of Industry and Mineral Resources (MIM) to be attached to the technical file before a Shipment Certificate of Conformity can be issued in SABER. The mechanism is industrial policy plugged into the conformity system: the declaration exists so the ministry sees — and approves — flows of goods that compete with or feed local industry, and SABER enforces it by refusing the SCoC without it.

Two things follow. It is a shipment-level gate (it blocks the SCoC, not the PCoC), and it is list-driven: nothing about your product category in general matters — only whether your exact HS code is on the current appendix.

Who it actually affects

Overwhelmingly: importers of industrial and building materials. The appendix has grown wave by wave since 2022, and the pattern is consistent — construction inputs, pipes, steel, cladding, and similar categories where Saudi Arabia has local production to protect. Typical consumer electronics HS codes have not appeared on the appendix so far. That is a statement about the list as published to date, not a permanent exemption — which is why the check belongs in your classification routine.

The appendix waves (2022 → August 2026)

As compiled from SASO circulars by compliance publishers, the additions run:

EffectiveAdded to the appendix
July 2022Tissue rolls
May 2023Ceramic tiles
July 2023Ductile iron pipes
June 2024Reinforcing steel
April 2025Plastic pipes — with an April 2025 circular also covering cardboard, Formica sheets, baby diapers and clay pipes
September 2025Optical fiber cables
April–May 2026Scaffolding systems; cold-rolled flat products
June 2026A broader Appendix (1) expansion per the June 2026 SASO circular
August 2026Non-cellular plastics (HS 39219010, 39219090 — fiber/carbon/glass-reinforced and other non-cellular plastics)

The August 2026 addition is a useful warning for electronics supply chains: plastics sheets are an input many factories ship as spares or accessories. The lesson is not "electronics are next"; it is that adjacent HS codes can drift into scope, so borderline codes deserve the check.

The process when you are in scope

  1. Confirm the code is appendix-listed — via the current SASO circular or your Certification Body.
  2. Obtain the MIM declaration: the established route is an application to the ministry (the program's original process ran on an Arabic form submitted to the ministry's designated channel, returning a barcoded approval).
  3. Attach the approved declaration to the technical file of the SCoC request in SABER — SASO's circulars are explicit that shipment certificates "should not be approved" for listed products without it.
  4. Keep it per-shipment-ready: the declaration is checked at the shipment gate, so it belongs on the same pre-departure checklist as the SCoC itself.

How it is enforced

Two layers: SABER's issuance gate (no declaration in the file → no SCoC for listed codes), and random sampling — SASO has stated it samples issued shipment certificates to confirm the declarations are present, especially for newly added products. Treat a missing declaration as a certain stop, not a survivable gap.

The electronics angle

For a typical electronics importer the practical position in September 2026 is: your finished-goods HS codes are almost certainly not on the appendix — but check three places where scope sneaks in: accessories and spares shipped under material codes (plastic sheets, cable spools), borderline classifications where a code change (see the HS-code waves) lands you on a listed code, and mixed consignments where one listed line item stalls the whole shipment's paperwork. The check costs minutes at classification time; the miss costs a container at the port — the arithmetic of every customs trap.

Frequently asked questions

Does the MIM declaration apply to consumer electronics?

The appendix published to date targets industrial and building materials; typical consumer-electronics codes have not appeared. Check your exact HS codes anyway — the list grows in waves, and accessories or spares can ride on material codes that are listed.

Does it block the PCoC or the SCoC?

The SCoC. It is a shipment-level requirement: the declaration must be in the technical file of the shipment-certificate request for listed codes.

Where is the authoritative list?

Appendix (1) of the current SASO circular. Circulars update the appendix in waves; your Certification Body sees them first — asking them against your code list is the fastest reliable check.

What happens if a listed product ships without the declaration?

The SCoC should not issue at all — and SASO random-samples issued certificates for exactly this. With the January 2025 pre-arrival rule, that is a stopped shipment, not a fixable oversight.

Go deeper, in both languages

The free sample covers the prerequisite stack, PCoC basics and 3 of the 7 traps — one English PDF and one Arabic PDF. The full Compliance Guide has the whole enforced path, every fee and timeline, all 7 traps with fixes, the invoice-matching checklist and a first-year budget worksheet.

Saber Desk is an independent reference — not a certification body, and not affiliated with SASO. We do not issue certificates. Fees and processing times are the official figures published on saber.sa unless marked as observed practice; confirm HS codes and required standards for a specific shipment with your Certification Body. Edition: August 2026.