Introduction
Permit applications in Singapore are essential for traders and declaring agents to legally move goods across borders. They function as a necessary check to prevent illegal items from entering or leaving the country and to allow for the collection of duties and taxes. The application process also provides Singapore Customs (“Customs“) with the necessary data to monitor trade activities.
In recognition of the importance of permit applications and the responsibility of traders and declaring agents in this regard, Customs has issued Circular No: 09/2025 on “Full Declaration of Product Information in Permit Applications” (“Circular“). The Circular highlights that Customs expects all traders and declaring agents to provide comprehensive declarations of the product information in permit applications and provides guidance on key data fields.
The Circular demonstrates Customs’ heightened focus on import and export control. It builds on earlier circulars such as Circular 01/2025 on “Export Controls on Advanced Semiconductor and Artificial Intelligence Technologies”, which reiterated the need to comply with export controls, and encouraged businesses to implement a robust internal compliance programme and engage legal expertise for business activities involving controlled technologies. For more information, please see our earlier Legal Update on “Singapore Issues Advisory on Export Controls on Advanced Semiconductor and AI Technologies“.
Traders and declaring agents play an integral role in protecting supply chain security and reinforcing Singapore’s role as a trusted global trading hub. It is vital for trading parties to be aware of the relevant obligations and responsibilities in the import and export processes, as breaches – inadvertent or otherwise – may lead to severe sanctions including fines, imprisonment, and forfeiture of goods.
This Update highlights the key features of the Circular and the guidance provided therein.
Circular on Full Declaration of Product Information in Permit Applications
The Circular states that traders and declaring agents must submit accurate and full information of the goods in permit applications. This includes the following data fields, where applicable:
- Goods Description: The description should provide a clear indication of the goods and should not comprise of generic or uninformative details. For example, Harmonized System code descriptions and Competent Authority product descriptions are not to be abridged, and goods model numbers should not be provided without the description of goods.
- Brand Name: This refers to the tradename or brand of the goods.
- Model: The model number or name of the goods declared should be clearly indicated to identify the characteristics of the goods that distinguishes them from similar goods.
- Supplier/Manufacturer Name: This refers to the name of the company or individual who has supplied or produced the goods.
- End-Use Description: This should describe the ultimate use of the goods, and whether it is for a further assembly of goods and the information related to the further assembly.
- General Remarks/Traders Remarks: Any additional information related to the goods or shipment declared should also be included.
The Circular further reiterates the need to comply with all applicable laws and regulations. It specifically highlights Circular 01/2025 on “Export Controls on Advanced Semiconductor and Artificial Intelligence Technologies”, which reminds businesses to be aware of Singapore’s export control regime as well as the implications of other countries’ export controls on their international business activities. The Singapore Government does not condone businesses deliberately using their association with Singapore to circumvent the export controls of other countries, and action will be taken against those engaged in dishonest practices to evade applicable export controls.
Concluding Words
Compliance with import and export controls has become increasingly complex in light of the rapidly changing national controls and regulations in today’s global trading landscape. Traders and declaring agents may face challenges in staying on top of the applicable regulations and restrictions, and in ensuring compliance with the relevant applications and processes.
Traders and declaring agents should note that inaccurate, incomplete or misleading trade declarations may constitute offences under the Customs Act 1960 and the Regulation of Imports and Exports Act 1995 and can attract significant penalties such as fines and imprisonment.
Businesses looking to assess their compliance measures and their conformity with procedure may wish to contact our Team set out on this page, who will be happy to assist with any queries.
Disclaimer
Rajah & Tann Asia is a network of member firms with local legal practices in Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. Our Asian network also includes our regional office in China as well as regional desks focused on Brunei, Japan and South Asia. Member firms are independently constituted and regulated in accordance with relevant local requirements.
The contents of this publication are owned by Rajah & Tann Asia together with each of its member firms and are subject to all relevant protection (including but not limited to copyright protection) under the laws of each of the countries where the member firm operates and, through international treaties, other countries. No part of this publication may be reproduced, licensed, sold, published, transmitted, modified, adapted, publicly displayed, broadcast (including storage in any medium by electronic means whether or not transiently for any purpose save as permitted herein) without the prior written permission of Rajah & Tann Asia or its respective member firms.
Please note also that whilst the information in this publication is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as legal advice or a substitute for specific professional advice for any particular course of action as such information may not suit your specific business and operational requirements. You should seek legal advice for your specific situation. In addition, the information in this publication does not create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on the information in this publication.
