Mr. Speaker, the Workers’ Party supports the intent of this Bill. Climate change is an existential threat to our island nation. As I argued during the Budget debate in February, our transition to Net Zero must be backed by rigorous, effective action that is both technically sound and socially just. We must ensure that our green ambitions do not inadvertently place an unfair burden on our SMEs and lower-income residents.
1. Addressing the "Digital Removal" of SME Listings
Mr. Speaker, I would first like to turn to the new provisions regarding the "digital removal" of non-compliant products from online platforms. While we must prevent the entry of energy-guzzling appliances into our market, we must consider the "SME Squeeze" in the e-commerce space.
Unlike large multinational corporations with dedicated compliance departments, our local SME retailers often lack the resources to navigate complex technical test reports for every niche product they list. If a listing is flagged and "digitally removed" due to a documentation error or a delay in NEA registration, the loss of sales momentum and search algorithm ranking can be devastating for a small business.
How will the Ministry ensure that these digital enforcement powers do not unfairly penalize local SMEs who may inadvertently fall victim to automated takedown algorithms? Will there be a "grace period" or a simplified verification pathway for local micro-enterprises to ensure they are not crowded out of the digital marketplace by larger players with deeper pockets for compliance?
2. Ambiguity in the "Circumvention" Threshold for Consumers
Mr. Speaker, I would like to raise a concern regarding the new Section 78, which targets the "circumvention" of registration requirements. This Bill expands the Act to cover goods imported for "own use." While this closes a loophole for traders, it creates a grey area for individual consumers.
Many Singaporeans often sell items on online platforms like Carousell that are almost brand new—perhaps a gift they cannot use, or a high-end appliance bought for a renovation that was later aborted. Under this Bill, if a resident imports a non-compliant appliance for "own use" but later decides to sell it because they have changed their mind, do they suddenly become an "unregistered supplier" subject to prosecution?
I have three specific clarifications for the Minister:
- First, the Scope of Marketplaces: Are all listings on peer-to-peer sites like Carousell now subject to these digital removal laws? If so, how will the NEA distinguish between a genuine second-hand sale by a resident and a commercial trader masquerading as an individual to offload non-compliant stock?
- Second, the Evidentiary Threshold: What criteria will NEA officers use to prove "deliberate evasion" versus a "genuine change of mind"? Without clear guidelines, we risk a situation where an innocent individual selling a gift is caught under the same heavy penalty framework as a rogue trader.
- Third, Protecting the "Gift Economy": How does the Bill apply to those who receive an imported appliance as a gift and wish to sell it? We must ensure that our drive for energy efficiency does not inadvertently criminalize the legitimate second-hand "gift economy".
3. Addressing the "Software-Defined" Energy Gap
Mr. Speaker, while this Bill focuses heavily on "regulated goods" as physical hardware, we must acknowledge that in 2026, energy efficiency is increasingly governed by software. We are certifying the "physical engine" but ignoring the "digital driver."
I am concerned that the Bill remains silent on "software-driven energy degradation." There is a growing risk that a product’s registered efficiency—the very basis of its NEA approval—can be remotely altered post-purchase. This may happen in three ways:
First, Firmware Throttling. Manufacturers can push Over-the-Air (OTA) updates that "cap" performance to protect hardware longevity at the expense of efficiency. In the Tesla battery litigation in the US, linked to the 2019 Hong Kong incident (Rasmussen v. Tesla, 2021) and the 2024 Norwegian Court of Appeal case, we saw disputes over allegations that Over-the-Air updates throttled capacity and charging speeds to manage hardware longevity post-sale. If an industrial battery or EV charger is registered at a certain efficiency, but a firmware update "throttles" it six months later, the original registration becomes a moot point.
Second, The "SaaS" Trap and Forced Telemetry. Companies like ABB now offer "Energy Optimization as a Service." These AI-driven systems predict load demands for industrial motors. However, how do we prevent the possible scenario that the hardware may revert to a high-consumption "baseline" mode if a local SME stops paying the subscription—even though the physical hardware is perfectly capable of running efficiently. We must ensure that energy efficiency is not held hostage by software subscriptions.
Third, Software Bloatware: The US Department of Energy found that Heating, Ventilation and Air Conditioning (or in short, HVAC) systems often prioritize warranty protection over energy saving. If a chiller's software detects a minor sensor error, it may default to a "Mechanical Safety" mode that consumes 30% to 40% more energy without alerting the owner. This "silent" degradation means a building’s energy audit may look good on paper, but the software is secretly wasting power.
I would like to ask the Minister:
- Does the definition of "regulated goods" under the Act extend to the firmware and software that control energy consumption?
- How does the NEA intend to monitor and regulate "software-driven energy degradation" once an item has been registered and cleared for use?
- Will the Government consider a "Software Integrity" requirement, where manufacturers must declare if their hardware requires a paid subscription to maintain its registered MEPS rating?
4. Quantitative Transparency and Impact Accountability
The proposed amendments in this Bill seek to encompass "own-use" imports and digital advertising within the regulatory framework. However, the absence of specific projections regarding expected energy savings or carbon abatement from these suggested additions prevent Parliament and Singaporeans from being able to value the efficacy of these measures or account for their performance.
Furthermore, there is a lack of clarity regarding whether the administrative burdens and costs placed upon the public and SMEs are truly proportionate to the actual carbon reductions achieved.
While the Bill closes existing regulatory gaps, could the Minister provide the specific annual energy conservation targets the Government expects to meet through these new "own-use" and advertising measures?
Specifically, how will these regulations contribute to our national target of peaking emissions at sixty thousand kilotonnes of CO2 equivalent by 2030, and what methodology will the NEA employ to track and report these savings to the public?
5. Impact on Lower-Income Families
Mr Speaker, I am also concerned that the Bill’s restrictions on "own-use" e-commerce imports may inadvertently raise the "entry price" for essential appliances. While high-efficiency models offer long-term savings, the upfront "green premium" may potentially create a financial barrier for lower-income households. We must ensure that these regulations do not unfairly burden those who currently rely on budget-friendly direct imports. Will the Ministry consider top-ups to the Climate Friendly Households Programme (CFHP) or other social equity measures to ensure lower-income families are not priced out of the appliance market by these stricter import controls?
6. Technical and Financial Barriers for SME Compliance
Mr Speaker, for an SME importing a single piece of specialized industrial equipment for "own-use," the administrative process of mapping foreign laboratory data to NEA-specific registrations is a significant hurdle. Unlike large retailers who spread these costs over thousands of units, small enterprises face a "compliance tax" that creates a literal barrier to modernization.
Without a simplified registration pathway, the high cost and complexity of compliance may pervert the Bill’s intent. Local firms may find it "cheaper" to keep older, less efficient machinery in operation longer rather than navigating the new regulatory hurdles to import updated, high-efficiency technology.
While the NEA recognizes test reports from MRA-accredited labs, the actual data submission for single-unit imports remains administratively heavy for SMEs. In the spirit of the Singapore-Australia Green Economy Agreement (SAGEA) and our APEC and ASEAN commitments, will the Minister consider a “Fast-Track” or “Deemed Compliant” registration pathway for own-use imports?
Such a move would ensure that compliance costs do not inadvertently discourage our local enterprises from adopting the latest energy-saving technologies.
7. Addressing the Exclusion of High-Frequency Goods (Lighting)
While the Ministry has prioritized larger appliances like refrigerators and chillers for the "own-use" import regime, it has specifically excluded lighting for the time being. However, the cumulative energy footprint of inefficient lighting imported via direct e-commerce remains significant. A phased approach that leaves out these high-frequency items allows a continued influx of sub-standard bulbs and tubes, which may undermine our overarching goal of reducing aggregate household demand.
What is the specific data-driven justification for excluding lighting from the "own-use" import regulations at this stage? Furthermore, can the Minister provide a definitive timeline or roadmap for when these and other low-consumption, high-frequency goods will be included to prevent a prolonged regulatory vacuum?
8. Beyond Incremental Loopholes: The Industrial Elephant
Mr. Speaker, while this Bill closes necessary retail loopholes, we must not lose sight of the bigger picture. Since 2013, our most energy-intensive facilities have been tracking data under this Act. Yet, for a number of years, the needle on actual efficiency did not move much.
At the debate for the second reading of the 2017 amendments for the Energy Conservation Act, the then Minister for the Environment and Water Resources, Mr Masagos Zulkifli, noted that while ECA companies saw efficiency gains of 0.4% and 0.6% in 2014 and 2015, meeting our climate pledge requires doubling or tripling these rates to 1%–2% annually, in order to match leaders like Belgium and the Netherlands.
While the 2017 amendments introduced mandatory management systems and audits, they seemed to stop short of requiring companies to actually implement the energy-saving opportunities they identified, provided they met the MEPS for their equipment. The 2024 amendments mandated the minimum energy efficiency standards ( MEES) which are more prescriptive regarding actual performance levels.
Can the Minister provide an update: for facilities under this regime for over a decade, what is the actual aggregate energy reduction achieved to date? Is the Ministry satisfied that these incremental, system-by-system mandates will hit our 2030 targets in time?
Mr. Speaker, in Mandarin:
议长先生，工人党支持这项法案的宗旨。气候变化对新加坡是生存威胁，但在追求净零目标的进程中，我们也必须兼顾政策的公平性与透明度。
第一，我担心中小企业的负担。我担心新的“数字删除”规定和复杂的注册程序，对资源有限的小商家来说是一项“合规税”。政府应该提供“快速通道”或简化程序，不要让繁琐的文书工作 阻碍企业 采用 节能科技。
第二，二手市场的灰色地带。很多居民会在 Carousell 等网站卖掉闲置的电器或礼物。如果法律 定义 不清楚，普通百姓会不会因为卖掉一个“非合规”的礼物而变成“非法供应商”？我们必须保护合法的二手经济。
第三，软件导致 的 能源损耗。现在很多电器的效率是由 软件控制的。如果厂家在卖出产品后，通过远程更新 减低了 节能 效果，或者因为用户 没付 软件月费 就让 设备 变回 高耗能 模式，那当初的节能注册就失去意义了。政府必须监管这些“隐藏”的能源浪费。
第四，照顾低收入家庭。限制 网购 廉价 电器 可能会 提高 生活成本。政府应该增加“气候友好家庭计划”(CFHP)的津贴，确保弱势群体不会因为买不起高价的节能电器而被 排挤。
议长先生，虽然我有上述几点担忧，但我依然支持这项法案。
Conclusion
Mr. Speaker, the Workers’ Party believes in a green transition defined by transparency and accountability. We must implement changes in this Bill with operational integrity and the "Just Transition" protections our people and our SMEs deserve. Notwithstanding the clarifications I have sought, I support the Bill.
