Export Controls in Singapore

Singapore defines export controls on strategic goods that are related to the development, manufacture and utilization of nuclear, biological and chemical weapons. The export controls also cover missiles that have can operationalize weapons of such nature. The regulations also define controls on conventional arms and on military equipment. It must be noted that the regulations also cover specific dual-use articles. Dual-use items are products that can have potential for both commercial and military use. Other types of items that are covered by the regulations include products that can be used as part, components or precursors for WMDs (Weapons of Mass Destruction).

Quick Facts about Strategic Goods Control in Singapore:

  • The Strategic Goods Control laws aim to restrict trade on products that can end up in use of WMDs
  • The Schedule to the Strategic Goods (Control) Order 2019 lists the goods that are in scope of the controls
  • Any other goods and technology that are intended or likely to be used for WMD proliferation purposes is also controlled
  • A permit is required before a trader can do any of the following activities with goods in scope of control:
    • export
    • transshipment
    • brokering
    • re-export
    • bringing in transit
    • intangible transfer
    • electronic transfer

What is the intangible transfer of technology?

This refers to any transfer of technology through means such as email, phone call, internet transfer, or fax. It also includes the act of making the technology available on a computer or server in Singapore in a way that makes it available to an individual in a foreign location.

Intangible transfer can include (but not limited to) the following:

  • Blueprints, drawings, diagrams, charts, formulas, models and data
  • Information shared through teleconferencing meetings with participants in foreign countries on platforms such as Teams, Zoom, Skype or WebEX
  • Uploading information on shared servers such as Google Drive or Drop Box

What are the controls on brokering?

Brokering activities refer to the act of negotiating, arranging or facilitating a contract for the procurement or acquisition of any products or technology in scope of controls of the regulations.

Brokers must be registered with Singapore Customs if they intend to do any brokering activity involving the arms and explosives listed in the Strategic Goods (Control) (Brokering) Order 2019.

The Strategic Trade Scheme or STS

The STS scheme provides for 2 types of strategic control permits:

  1. Bulk permit: This allows for the trader to be pre-approved to export multiple goods in scope of control to multiple countries or for the trader to be pre-approved to export multiple products to multiple end users or consignees
  2. Individual permit: Approved on transactional basis

How to apply for an STS permit?

Registered traders with Singapore Customs who have a clean compliance record, have maintained an effective compliance program and have achieved a minimum of “Enhanced” band under the TradeFIRST scheme can apply for STS permits.

A final note

Singapore’s bulk permit system makes it convenient for traders involved in trading Strategic goods to get the require approvals from Singapore Customs. However, they must attain the Enhanced status in the TradeFIRST system in order to be able to do so. This requires the trader to design and implement a good internal compliance programme. The requirements of an ICP are reasonable to meet even if a company is not involved in strategic goods control.

Leave a Reply