Harmonised Trade: Key Compliance for Traders and Declaring Agents in Singapore

Singapore’s economy is deeply intertwined with global trade and relies heavily on the seamless movement of goods to retain its status as a leading financial and logistics hub. Singapore Customs plays a pivotal role in maintaining this efficiency by enforcing compliance with trade regulations to uphold the transparency and integrity of this ecosystem. 

The Singapore Customs Circular dated 08.04.2025 (updating the 19 July 2021 Circular)  introduces and clarifies key compliance obligations for traders and declaring agents (DAs) involved in the import, export and transhipment of goods.

This blog post highlights the key requirements based on the Circular, though it is not exhaustive.

Key Compliance for Traders and Declaring Agents in Singapore

Declaration of Harmonised System (HS) Code

HS Codes are 8-digit standardized numbers used by authorities worldwide to classify export trade products. Traders must declare the correct 8-digit HS code for each item, based on a detailed description of the goods. Any shipment with multiple items (even if they are from the same supplier) must be listed as a separate line item in the declaration if it has different HS codes.

A search tool is available at TradeNet® to determine whether the product falls under controlled items.

Penalty: Fine up to $10,000 and/or up to 2 years imprisonment

Compliance Tip: Do not rely on internal product names or prior declarations. Align descriptions precisely with commercial documentation and Customs guidance to provide correct HS code. Ensure regular HS code reviews.

Checklist:

• Use TradeNet HS/CA tool.
• Verify if goods are controlled items and obtain necessary permits.
• Declare accurate 8-digit HS Code.
• Use separate lines for different HS codes.

Accurate Goods Value Declaration

Goods value declared in Singapore dollars must be based on commercial invoices and not estimates or proformas. Supporting documents must substantiate the declared value. Values have to be declared for exports, imports and transhipment in the manner provided in the Circular.

Compliance Tip: Double check to ensure there are no missed costs (like royalties or packing). Internal SOPs should require finance to cross-check declared values.

Checklist

• Declare value in SGD based on commercial invoice.
• For imports declare CIF value + charges (e.g., commissions, packing, royalties).
• For exports declare FOB INCOTERMS.
• Use Customs exchange rates.

Penalty: Fine up to $10,000 and/or up to 2 years imprisonment.

Description of Goods

Traders and DAs must provide clear indication of the goods and avoid vague descriptions. The “Item Description” field should clearly reflect the product’s nature, specifications, and purpose, as shown on the invoice.

Compliance Tip: Train staff to describe items in precise, invoice- aligned terms

Checklist

• Clear, specific item descriptions.
• Match description to commercial invoice.

Penalties: Fine upto $10,000 and/or up to 2 years imprisonment.

Correct HS Quantity and Unit

Each HS code has a designated unit and has to be declared accordingly. Examples for this are provided in the Circular.

Compliance Tip: Mismatch between invoice units and HS requirements can result in rejections or delays. Keep a reference table mapping internal units to HS Code units to prevent errors.

Checklist

• Quantity declared should match the prescribed unit for the HS code (e.g. “MIL”, “VAL”).
•  Unit should match the commercial documents.

Country/Region Information

Traders and DA should declare the country of origin (COO) where the goods were produced or manufactured. It is also important to declare the country of final destination. This replaces the previous requirement to mention the consignee address which was available in the commercial invoice. For controlled goods, it is necessary that declarations comply with relevant Competent Authorities’ requirements.

Compliance Tip: Do not confuse “country of export” and “country of origin”. Maintain origin tracking procedures and track any changes in supply chain.

Checklist

• Declare COO declared based on where the goods are manufactured.
• Accurately declare country of Final Destination.
• Meet Competent Authority requirements for controlled goods.

Preferential Tariff Indicator for Free Trade Agreements (FTAs)

If you are exporting goods that qualify under an FTA, select Referential Indicator (“PRI”) and include a valid origin declaration or certificate on the invoice. Circular No. 12/2018 provides guidance on this.

Compliance Tip: Assess FTA eligibility before permit application. Keep records of self-certification.

Checklist

• Maintain list of FTA qualifying goods.
• Select “PRI” where applicable.
• Include Origin declaration or certificate in the invoice.
• Comply with Circular No. 12/2018 on self-certification.

Proper Use of UEN

Always declare the company’s valid Unique Entity Number (UEN). Generic UENs is limited to specific cases. Circular No. 11/2014 provides further details on this.

Checklist

• Valid UEN declaration.
• Generic UEN should be used as under only if applicable.
• 99991000000G – Transit through Singapore by Peninsular Malaysian companies.
• 99999000000N – Import/export of used household or personal effects.
• 99999990000C – Non-commercial imports/exports by individuals.

Supporting Documentation and Timely Responses

Submit approved permits and supporting documents to Customs promptly and respond within the stipulated time when required to do so. All trade documents and declarations should be retained for at least five years.

Compliance Tip: Businesses often lack centralized document storage. Invest in automated systems to streamline access and retention and compliance reminders.

Checklist

• Maintain all required documents (invoices, bills of lading/air waybills, packing lists etc.).
• Submit the required documents upon Customs request or as required by permit conditions.
• Store and retain documents for 5 years.
• Provide prompt response to queries from Customs.

Clearance Requirements

Ensure that all permits are approved before presenting goods at checkpoints for clearance. For controlled goods, all requisite licenses and permits must be approved by Competent Authorities.

Compliance Tip: Coordinate closely between trade compliance, warehouse, and logistics teams to ensure permits are in place to avoid delays.

Checklist

• Ensure Customs permits are approved pre-clearance.
• Secure required licences and approvals for controlled goods.

Permit Conditions  

Traders and DAs must meet all permit conditions such as presenting goods for clearance and second checkpoint clearance timelines.

Compliance Tip: Have SOPs and build automated alerts into your system to track permit timelines (for instance: that goods are cleared at the second checkpoint within 24 hours of clearance from the first).

Checklist

• Know and comply with permit terms.
• Present goods at checkpoints as required.

Permit Validity

Use the permit within its validity period. If not, apply for an extension or cancel and re-apply via TradeNet.

Compliance Tip: Use automated systems to monitor expiry and renewal of permits.

Checklist

• Monitor validity of permits.
• Apply for extension or cancel and re-apply as needed.

Summarising the Key Compliance for Traders and Declaring Agents in Singapore

The Customs circular underscores the importance of harmonised compliance for traders and DAs. Non-compliance with the obligations to provide accurate declaration, required documents or information within the prescribed timeframe will result in penalties under the Customs Act 1960 and the Regulation of Imports and Exports Act 1995. While the circular imposes clear obligations, Traders and DAs must adopt structured internal controls, automate compliance workflows, and train staff to prevent errors and stay proactive. Doing so not only ensures regulatory compliance but also provides a competitive edge in Singapore’s global trade ecosystem.

How Lexplosion can Help?

To help the traders and DAs in Singapore to navigate through the complex regulatory landscape under the Customs Act 1960 , Regulation of Imports and Exports Act 1995 and the advisories / directions of the Singapore Customs collectively, Lexplosion Solutions Private Limited offers a powerful compliance automation platform named Komrisk. Designed to simplify compliance management, Komrisk provides all applicable compliances in the form of actionable tasks and enables businesses to track, manage, and monitor all regulatory obligations in real-time, including those related to the automated alerts for declaration requirements, maintain a vast repository of all the essential forms/documents essential for audits. With features like automated alerts, compliance calendars, centralized documentation, and audit readiness tools, Komrisk empowers traders and DAs to proactively stay compliant, reduce legal risk, and respond quickly to regulatory changes.

Get in touch with us for a demo.

Authored by: Soumya Shuvra Das

Co-Authored by: Swapna Umakanth, Antara Dasgupta

Disclaimer

The information provided on this blog is for general informational purposes only and is not a substitute for professional legal advice. We are not a law firm and are not authorized to practice law in your jurisdiction. Laws and regulations are complex and constantly changing, and information that may be true in one jurisdiction may not apply in another. Before acting on any information you read here, you should consult with a qualified lawyer practicing in the relevant jurisdiction for your specific legal issues or concerns. While we strive to provide accurate and up-to-date information, we make no guarantees that the information on this blog is completely current or error-free. We disclaim any liability for any actions taken or not taken based on the information on this blog.