Sir, the amendments to the Regulation of Imports and Exports Act (RIEA) have a twofold aim: to introduce a trade information certificate (TICs) regime, and to expand the scope of search authority for customs officials.
My honorable friend, Gerald Giam, has spoken on the importance of further empowering traders, especially smaller ones, through targeted assistance, as they navigate the new stipulations that they would have to comply with resulting from this proposed legislation.
On my part, I will take a step back and focus mainly on implications of Clause 3—which provides the framework for a more robust and comprehensive trade monitoring regime—on our international trading relations. Specifically, I will probe more into whether how TICs could improve our importing and exporting firms’ compliance with our international trade obligations, yet carry additional costs, without fully resolving certain concerns.
The purpose of rules of origin
Rules of origin (ROOs) have long been required to ensure that free trading agreements (FTAs) signed between contracting nations do not inadvertently undermine those that are not party to the same agreement.[1] Without ROOs, goods from, say, Türkiye that entered Singapore preferentially may then subsequently be exported to the Philippines tariff-free as a result of ASEAN, even though the latter did not agree to the rates set forth in the Turkey-Singapore Free Trade Agreement (TRSFTA).[2]
The problem, in essence, is that the proliferation of FTAs has contributed to a “spaghetti bowl” of messy, overlapping, and hard-to-enforce duties and barriers, which has been criticized by some as undermining the multilateral trading system.[3] Singapore has been more guilty than most, given our penchant for signing FTAs, resulting in our own char kuay teow of interweaving trade agreements, several times more than the average economy,[4] and incorporating a host of non-harmonized trading rules.[5]
Managing this web of interlocking trading relationships, therefore, necessitates a decisive system of monitoring and reporting ROOs. Singapore had previously implemented this administratively, using Certificates of Origin (CoOs). But such CoOs carried limited oversight and enforcement, were prone to error or differences of interpretation,[6] and relied on honest and accurate self-declarations.[7]
How the TIC regime may help, or how it may yet fall short
The statutory backbone provided by the TIC regime will undoubtedly make some headway in tightening ROOs, through elevated reporting and accountability requirements, along with expanded enforcement powers.
Still, ROOs may be circumvented under the revised legislation. For example, TICs cannot preclude a situation where an importer deliberately overstates the cost of local material or labor used to determine origin. This is fraudulent, of course, but detection would only be heightened under the new regime if there are additional resources also dedicated to effect random scrutiny of TIC submissions—perhaps with the use of AI-enhanced fraud detection methods.[8]
But slippages may result even when the intent is not nefarious. For instance, third party invoicing—the practice of using preferential CoOs issued by a third country that may not be a member of the FTA—have historically been accepted by Singapore Customs.[9] Still, there is no immediate assurance that the standards for ROOs applied by the third country would be as stringent as those here. In such cases, it would be helpful to understand how Customs plans to deal with these inadvertent violations of ROOs. The suggestion by Member Gerald Giam for a tiered enforcement framework may assuage concerns among those who fear excessive punishment for first-time offenses.
Similarly, Mr Giam has pointed to the need for technical and financial support to small traders that may be overwhelmed by their now more-burdensome reporting obligations. I would also suggest that the Ministry consider some form of streamlined submission or automatic reporting process for regular importers which bring the same set of goods, similar to how income tax reporting is more straightforward for wage income earners that have not undergone changes in jobs.
The balance between the two objectives—punishment for intentional misrepresentation, tempered by some degree of leniency for unwitting mistakes—will have practical implications not only for our traders and businesses, but also for how Singapore navigates its ongoing trade negotiations with the rest of the world.
After all, earlier this year, there were accusations that Singapore was being used as a transshipment hub to bypass sanctions,[10] resulting in our classification as a Tier Two nation for the purposes of access to AI technology from the United States.[11] This was a matter that was discussed in Parliament then,[12] but a thorough revision of the RIEA was not mooted then, with only a reference to the Strategic Goods Control Act. Notably, since that time, new reports have emerged to suggest that such illicit activity appears undeterred, as evidenced by firms such as Singapore-registered Megaspeed (and its Malaysian subsidiary Speedmatrix).[13]
Similarly, we know that trade in goods and services is accompanied by corresponding financial flows.[14] Over the past two years, this House has passed related legislation to further curb illicit financial flows,[15] yet it has not appeared to have deterred the activities of Cambodian businessman Chen Zhi and the Prince Group.[16]
It would be helpful to have a better understanding of how the Ministry now believes that the revised Certificates of Origin and Non-Manipulation will help avoid repeating such outcomes. Relatedly, will the decision by the United States’ to suspend the de minimus exemption[17]—which the Bill does not appear to address directly—require additional subsidiary legislation, or will the information to be reported in TICs be sufficient to ensure future compliance?
Conclusion
While the new regime will impose a greater regulatory burden on our traders, it is also an important upgrade that will ensure that our nation continues to adhere to its international trading commitments. While the transition may initially be rocky, I believe that, in the longer run, our world-class trading and logistics sector will adapt, and new compliance services will emerge to support this endeavor. In a world where the rules-based order is being increasingly threatened, it is essential that Singapore continues to contribute toward sustaining the system that has served our small nation so well. For these reasons, I support the Bill.
[1] Strictly speaking, there are two types of rules of origin, non-preferential and preferential. The former is mainly used to determine a good’s origin country typically for the purposes of enforcing trade rules within the multilateral trading system, such as identification of most-favored-national treatment, or countervailing duties in the event of dumping. The latter, in contrast, enable the granting of favorable tariff treatment within the context of bilateral or regional free trade agreements. The discussion to follow applies to both classes of ROOs, and especially the interface between the two.
[2] The TRSFTA was signed in 2015 and came into force in 2017. See MTI (2017), “Turkey and Singapore Ratify Free Trade Agreement,” Press Release, Aug 21, Singapore: Ministry of Trade and Industry.
[3] Bhagwati, J.N. (1996), “Preferential Trade Agreements: The Wrong Road,” Law and Policy in International Business 27: 865–71.
[4] Singapore has a network of 27 bilateral and regional FTAs. Using the registry of preferential trading agreements at the World Trade Organization, there are 377 such agreements in force globally. Divided over 190 countries yields an average of about 5 per country, albeit this is subject to caveats since countries typically define such agreements differently, and overlapping memberships may exist.
[5] For instance, many bilateral trade agreements signed by Singapore stipulate a local content requirement of 25 percent, whereas the usual regional value content for regional trading agreements tends to be 40 percent.
[6] For instance, there are three possible calculation methods for establishing origin criteria: the change in tariff classification method, the regional value content method, and the process rule method. In principle, selection of one method over another may yield different conclusions about the substantive degree of transformation used to determine a good’s origin. See Singapore Customs (2025), Handbook on the Non-Preferential Rules of Origin, Singapore: Singapore Customs.
[7] Singapore Customs (2025), “Advisory: Accurate Declaration of ‘Country/Region of Origin’ Field in Import, Export, and Transshipment Permits,” Circular 06/2025, Jun 9, Singapore: Singapore Customs.
[8] Bao, Y., G Hilary & B. Ke (2022), “Artificial Intelligence and Fraud Detection,” in V. Babich, J.R. Birge& G. Hilary (eds.), Innovative Technology at the Interface of Finance and Operations 1, Cham: Springer, pp. 223–47.
[9] Singapore Customs (2021), Handbook on Rules of Origin for Preferential Certificates of Origin, Singapore: Singapore Customs.
[10] Norman, I.A. (2025), “Malaysia Probes Alleged Nvidia Chips Moved from Singapore, Vows ‘Necessary Action’ Against Local Firms Involved,” CNA, Mar 4.
[11] Chew, H.M. (2025), “Singapore Does Not Condone Businesses Who Use Local Ties to Bypass US Export Controls on AI Chips,” CNA, Feb 18.
[12] Hansard (2025) 95(152): Feb 18.
[13] Swanson, A.,T. Mickle, P. Mozur & M. Hvistendahl (2025), “A Mystery C.E.O. and Billions in Sales: Is China Buying Banned Nvidia Chips?”, New York Times, Oct 9.
[14] This is a consequence of the current account identity, which requires that the sum of the current, capital, and financial accounts be equal to zero.
[15] These were the Anti-Money Laundering and Other Matters Bill and Anti-Money Laundering and Other Matters (Estate Agents and Developers) Bill. See Hansard (2024) 95(138): Aug 6 and Hansard (2025) 95(162): Apr 8.
[16] Lok, J.W. (2025), “Singapore Police Seize Over $150m in Assets Tied to Cambodia Scam Syndicate Prince Group,” Straits Times, Oct 31.
[17] Trump, D.J. (2025), “Suspending Duty-Free De Minimus Treattment for All Countries,” Presidential Executive Order, Washington, DC: The White House.
