Singapore Clarifies Rules on Non-Preferential Origin Declarations

On June 9, 2025, Singapore Customs issued a media release clarifying the rules surrounding non-preferential country of origin declarations, emphasizing that such declarations must reflect the actual origin of the goods, not merely their place of shipment. The clarification responds to growing concerns over mislabeling and misuse in trade documentation, which can lead to regulatory breaches and trade disruptions.

By reinforcing the distinction between preferential and non-preferential origin rules, Singapore aims to enhance trade transparency and ensure compliance with international standards.

Distinguishing non-preferential origin from preferential origin

Non-preferential origin refers to the country in which goods are either wholly obtained or have undergone substantial transformation. Unlike preferential origin, which is tied to free trade agreements and grants tariff benefits, non-preferential origin is used for general trade declarations, trade statistics, labeling, and enforcement of trade remedies. These declarations are required by many countries for purposes such as anti-dumping duties, quotas, or country-specific labeling regulations.

Singapore’s clarification stresses that non-preferential origin must not be confused with the logistics of export. A product that passes through Singapore for re-export does not acquire Singapore origin unless it satisfies the origin rules under the substantial transformation test.

Key points from Singapore Customs' clarification

The June 2025 clarification reiterates that traders must not declare Singapore as the origin of goods unless the goods meet specific conditions. For goods to qualify as originating in Singapore, they must either be wholly obtained in Singapore or have undergone significant processing or transformation in Singapore, resulting in a new product.

Mere packaging, labeling, or assembling activities in Singapore — without substantial change to the product — do not qualify as origin-conferring. Using terms like “Made in Singapore” or “Product of Singapore” without meeting origin requirements may constitute a false declaration under the Regulation of Imports and Exports Act, potentially leading to penalties or permit suspension.

Example

A trading company in Singapore imports power tools manufactured in Vietnam. The goods are unpacked, relabeled with the company’s branding, and repackaged in Singapore before being exported to Europe. Although the final product originates from Singapore, the tools have not undergone any substantial transformation during their time in the country. Under Singapore Customs’ clarified guidance, declaring “Made in Singapore” in this scenario would be inaccurate and non-compliant. The correct origin remains Vietnam.

Responsibilities of exporters and traders

Exporters, manufacturers, and logistics providers must review their procedures for assigning country of origin in trade documentation. Origin must be determined based on actual production processes, not convenience. Singapore Customs has advised companies to reassess product classification, document processing steps, and verify origin at the point of declaration.

Businesses engaged in re-export or trading activities, particularly in electronics, medical devices, or consumer goods, must be especially careful not to issue misleading declarations for goods sourced and processed elsewhere.

Legal and commercial implications

Improper origin declarations can lead to serious consequences, both within Singapore and in destination markets. Misrepresentation of origin may result in shipment rejections, customs audits, or trade penalties abroad. In Singapore, such infractions can trigger enforcement actions, including administrative fines and revocation of trade privileges.

As a global trade and logistics hub, Singapore places significant importance on the accuracy of origin declarations. The clarification reinforces that even non-preferential declarations must be handled with the same diligence as those tied to trade agreements.

Improving compliance through internal controls

Given the commercial and regulatory risks, businesses should embed origin requirements into compliance systems to avoid unintentional misdeclarations. This includes updating standard operating procedures, training personnel on origin rules, and maintaining documentation that substantiates each claim.

Businesses should also conduct regular internal audits and supply chain mapping to ensure alignment between declared origin and actual production processes. With increased scrutiny expected from Singapore Customs, taking proactive steps is key to maintaining compliance and avoiding costly enforcement actions.

This article first appeared on ASEAN Briefing, our sister platform.