Singapore Customs Reinforces Trade Compliance and Declaration of Country of Origin

Introduction

Trade compliance has been a major focus in the field of international trade, especially in the current climate of tariff expansion and changing trade agreements. In light of Singapore’s role as a major regional import and export hub, particularly for the transhipment of goods, much attention has been placed on whether traders may be misrepresenting the origin of goods moving through Singapore in order to get around tariffs or trade restrictions.

On 9 June 2025, Singapore Customs issued Circular No: 06/2025 (“Circular No. 6“), which reminds all traders and declaring agents (“DAs“) to accurately declare the “Country/Region of Origin” field in Singapore’s import, export and transhipment permit applications (“Permit Applications“). Circular No. 6 provides further guidance on what qualifies as Singapore-originating goods, both for preferential tariff treatment under a Free Trade Agreement (“FTA“) and for non-preferential scenarios.

Singapore Customs and the Ministry of Trade and Industry also issued a joint media release on “Trade Compliance: An Integral Part of Singapore’s Economic Competitiveness“, highlighting the importance of complying with customs regulations and rules of origin criteria. The media release directed traders and DAs to observe Circular No. 6, stating that enforcement action will be taken against non-compliant entities.

The above issuances demonstrate heightened attention on trade compliance, particularly in the area of rules of origin. Traders and DAs should ensure that they are duly advised on the relevant rules and regulations in order to avoid inadvertent breach, which may attract serious penalties and reputational consequences.

This Update provides a summary of the key guidance in Circular No. 6 on how to accurately declare the “Country/Region of Origin” in Permit Applications.

Country/Region of Origin

Singapore Permit Applications require traders and DAs to declare a “Country/Region of Origin” field for the goods being imported, exported or transhipped. This refers to the country/region in which the goods were wholly obtained or substantially transformed to their final form.

Circular No. 6 reminds traders and DAs that when declaring the “Country/Region of Origin”, the goods must meet the prevailing rules of origin of the country/region where the goods are produced or manufactured.

Parties dealing with Permit Applications should thus ensure that they are advised on the rules of origin of the relevant country/region before making the Permit Application, particularly because rules of origin may differ according to jurisdiction.

Qualifying as Singapore-Originating Goods

Singapore-originating goods may enjoy advantages in international trade due to a variety of FTAs that Singapore has entered into with trading partners to obtain preferential treatment. Singapore-originating goods may also be subject to fewer trade restrictions on account of Singapore’s generally friendly political and trade relations.

Circular No. 6 reminds traders and DAs that they may declare “Singapore” as the “Country/Region of Origin” in Permit Applications only for goods that meet the applicable origin criteria:

1. Preferential treatment under FTAs: To qualify as Singapore-originating goods for preferential tariff treatment when goods are exported from Singapore to an FTA partner country/region, the goods must meet the specific origin criteria set out in the relevant FTA.

2. Non-preferential treatment: To qualify as Singapore-originating goods that are not seeking preferential tariff treatment under any FTA, the goods must meet Singapore’s non-preferential origin criteria. The goods must:

• • be wholly grown or produced entirely in Singapore; or
  • have undergone substantial transformation in Singapore by meeting any of the following criteria: (i) manufactured in Singapore with minimum 25% of Local Content based on the ex-factory price of the finished goods; (ii) attained a change in tariff classification at the six-digit level; or (iii) undergone a chemical reaction.

Circular No. 6 also provides the following guidance for accurately declaring the “Country/Region of Origin”:

1. Minimal processing: Goods which have only undergone minimal processing in Singapore would not qualify as Singapore-originating.

2. Transshipment: Singapore exporters exporting goods manufactured in Country A to Country B cannot declare the country/region of origin as Singapore.

3. Compulsory field: Even for goods that are not seeking FTA preferential tariff treatment, the “Country/Region of Origin” field cannot be marked as ‘N/A’.

4. Goods processed in multiple countries: For goods that have undergone processing in two or more countries, parties may wish to take into consideration the “substantial transformation criterion” for origin determination.

5. Substantial transformation: There are three major criteria to express a substantial transformation: (i) the value added of a good increases up to a specified level; (ii) the good is classified in a chapter, heading or subheading different from all non-originating materials used; or (iii) the good has undergone specified manufacturing or processing operations.

6. Supporting documents: The typical documents required to prove origin include: (i) manufacturing records; (ii) cost statements; (iii) manufacturing process flowcharts; (iv) invoices for purchase of raw materials; (v) supplier declarations; and (vi) import/export documentation.

Offences for Incorrect/False Declaration

Circular No. 6 highlights that customs declarations are required to be accurate and truthful under the Customs Act and Regulation of Imports and Exports Act 1995. An incorrect declaration may amount to an offence and result in penalties. Parties must maintain a record of documents relating to the purchase, import, sale or export of goods for at least five years from the date of permit application approval.

Singapore Customs has stated that it will not hesitate to take enforcement action against non-compliant entities. Penalties imposed may include notices of advisory, composition sums and prosecutions in court.

Concluding Words

Against a backdrop of tariffs and trade restrictions, it should be noted that there is now an enhanced monitoring of trade compliance, particularly regarding the origin of goods being imported, exported or transhipped. This may also lead to heightened enforcement against incorrect or false declarations.

Traders and DAs should ensure that they exercise due diligence in their Permit Applications, particularly for the “Country/Region of Origin” field. For goods that have undergone processing in two or more countries, or goods that have undergone a degree of processing in Singapore, the assessment of whether they constitute Singapore-originating may be more complex, requiring application of the “substantial transformation criterion”. Parties may thus wish to seek further advice to avoid inadvertently committing any offence.

For further queries on these issues, please reach out to our Team members set out on this page.

Click on the following links for more information:

• Circular No: 06/2025: Accurate Declaration of “Country/Region of Origin” Field in Import, Export and Transhipment Permits”
• Trade Compliance: An Integral Part of Singapore’s Economic Competitiveness