In response to heightened scrutiny over country of origin declarations amid ongoing global tariff tensions, Singapore Customs issued Circular No. 06/2025 on 9 June 2025 (the “Circular“) to provide important clarification on the applicable preferential and non-preferential rules of origin when declaring the “country of origin” for importation into, exportation out of, and transshipments through Singapore.
General Principle
Singapore Customs emphasised that the “country of origin” of a good refers to the country in which the good is wholly obtained or substantially transformed into its final form. This determination is to be made in accordance with the prevailing rules of origin of the country where the goods were produced or manufactured.
- Preferential Rules of Origin
For goods intended to be imported with preferential tariff treatment under any free trade agreement (“FTA“), the country of origin of the goods must be determined in accordance with the specific rules of origin outlined in the relevant FTA. These rules vary across agreements and must be strictly adhered to when claiming preferential tariff treatment.
- Non-Preferential Rules of Origin
Where preferential tariff treatment is not sought, Singapore’s non-preferential rules of origin apply to determine whether a good produced or manufactured in Singapore qualifies as originating from Singapore. To qualify as a Singapore-origin good, the good must either:
- be wholly obtained in Singapore (i.e., wholly grown or produced entirely in Singapore); or
- has undergone substantial transformation in Singapore by meeting at least one of the following criteria:
- manufactured in Singapore with a minimum of 25% local content based on the ex-factory price of the finished goods;
- attained a change in tariff classification at the 6-digit level (i.e., change in tariff sub-heading); or
- undergone a chemical reaction (only for products under HS Chapters 27 to 40).
A good that has only undergone minimal processing (e.g., packaging, labelling, and simple assembly) in Singapore does not qualify as a Singapore-origin good.
For goods that are wholly manufactured outside of Singapore or partially manufactured in Singapore but do not meet the Singapore non-preferential rules of origin, the country of origin declared should be in line with the applicable rules of origin, in the country of manufacture. Where the goods are manufactured or processed in more than one country, the country/region of origin shall be the country/region where the last substantial manufacturing or processing was carried out based on the applicable rules of origin in the relevant country of manufacture.
For the avoidance of doubt, Singapore Customs also clarified that the “country/region of origin” field in export declarations must not be marked as “N/A”, even if the goods do not qualify as originating in Singapore.
Our Commentary
The clarity provided by the Circular is a welcome development, especially in light of the growing emphasis on accurate country of origin declaration. By applying the rules of origin of the foreign country of manufacture for determining the country of origin for foreign-made goods, the guidelines offer practical relief for companies that operate in Singapore primarily as a warehousing and transshipment hub, as no Singapore-specific origin analysis would be required.
