Jurisdiction - Singapore
Singapore – Latest Changes to Strategic Trading.

16 September, 2014


Legal News & Analysis – Asia Pacific – Singapore   Regulatory & Compliance


The Act

The Strategic Goods Act (Control) (the “Act”) was implemented in 2003 to safeguard security against proliferation of weapons of mass destruction, by regulating trade in strategic goods and technology. The Act prohibits any export, transhipment a or bringing in transit of any strategic goods into Singapore, unless an appropriate permit has been obtained or the goods fall within recognised exemptions.

Currently,there are are exemptions from obtaining permits for transhipment and transit of strategic goods under the Strategic Goods (Control)Regulations (the “Regulations”).Within these exemptions is a list of goods set out in the Fourth Schedule of the Regulations that that do not benefit from the exemptions. The latest changes to the Act seek to tighten the regulations,by expanding the types of strategic goods which moving forward will require permits under the Act.

This short update provides a quick snapshot of the changes.

Latest Changes (1 January 2015 onwards)

Amendments made made on on 1 September 2014 broaden the scope of strategic goods that will now require permits where they are transhipped through Singapore. Such goods include lithium isotope separation on facilities, cholorine facilities, cholorin triflouride (ClF 3), machine tools and their specially designed software, certain pressure sensors and their related technology.

The amendments also introduce a new. This new Fifth Schedule requires permits to be obtained even when such goods are brought into Singapore in transit. The new Fifth Schedule deals more with military type items, as well as sensitive dual-use items, including arms, ammunitions, military vehicles, special fissile materials, etc.

Having limited the scope of  exemptions available  i.e.making more goods subject to permits,the amendments nevertheless  introduce one relaxation. Information security systems, equipment, components and test, inspection and production equipment will be deleted from the Fourth Schedule. This means that permits for transhipment will no longer be required for strategic goods falling under these categories.

The changes take effect from 1 January 2015.


Persons who issue the bill of lading or air waybill for transit and transhipment of strategicgoods should take note of the enlarged cope of goods that require permits. Non-compliance with the Singapore order will result in severe criminal and civil liability. Businesses which do regular export or simplytranshipment or bringing goods into Singapore in transit must review their business and ensure compliance protocols are updated.


Rajah & Tann


For further information, please contact:

Kala Anandarajah, Partner, Rajah & Tann 

[email protected]

Dominique Lombardi, Partner, Rajah & Tann

[email protected]

Tanya Tang, Rajah & Tann
[email protected]


Shuhei Otsuka, Rajah & Tann
[email protected]

Kimberly Tan, Rajah & Tann
[email protected]

Marcus Teo, Rajah & Tann
[email protected]

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