Effective 1 May 2019, the list of strategic goods being transshipped in or in transit in Singapore needing a strategic goods permit will be expanded.

Currently, under the Strategic Goods (Control) Act (“SGCA“) strategic goods permits must be obtained when strategically controlled military and dual-use goods are being exported from, transshipped in or brought in transit in Singapore. For trade facilitation, the regime also provides strategic goods permit exemptions when certain items are transshipped or brought into transit in Singapore’s Free Trade Zones (“FTZs“) and meet the applicable transshipment / transit requirements.

The list of dual-use items ineligible for FTZ transshipment and transit strategic goods permit exemptions will be expanded from 1 May 2019. There will also be an expansion to military goods in transit ineligible for strategic goods permit exemptions. Items that are not eligible for permit exemption when transshipping or transiting in an FTZ are listed in the Fourth Schedule (Transshipment) and Fifth Schedule (Transit) to the Strategic Goods (Control) Regulations. On 25 February 2019, Singapore Customs released Circular Number 04/2019 detailing a further list of items across several code categories that will be added to the Fourth and Fifth Schedules (effective 1 May 2019). We include a link to the circular here.

Examples of items needing a permit for transshipment or transit from 1 May

For military goods ­– naval vessels and components along with military aircraft and components will no longer be eligible for transit permit exemptions. For dual-use goods – specific codes under the special materials and related equipment, materials processing, sensors and lasers, navigation and avionics, and aerospace and propulsion categories will no longer be eligible for transshipment and transit exemptions.  From 1 May 2019, transshipment or transit (as applicable) of the added items will require strategic goods permits under the SGCA, even if their shipment activity is confined to FTZs.

Action to take

Most new additions to the Fourth and Fifth Schedules are specific to the sub-category code level.  Supply chains with sensitive technology and utilizing Singapore FTZs will need to check if they currently rely on SGCA strategic goods permit exemptions and if this changes 1 May 2019.  If the goods fall under the newly added category codes in the Fourth and Fifth Schedules, from 1 May 2019, strategic goods permits will need to be obtained.


Ken Chia is a member of the Firm’s Asia Pacific IT & Communications and Global Privacy steering committees. He is regularly ranked as a leading ITC and competition lawyer by top legal directories, including Chambers, Asia Pacific Legal 500, PLC Which Lawyer? and Asialaw. Ken is a fellow of the Chartered Institute of Arbitrators and the Singapore Institute of Arbitrators. He is also an accredited mediator with the Alternative Dispute Resolution Group in the United Kingdom. Ken has more than 20 years of practicing in the areas of IT, telecommunications, intellectual property, trade and commerce, and competition law matters. He routinely assists clients, mostly governments and multinational corporations, in large-scale procurement, outsourcing and regional transactions, and provides sound advice on privacy and e-commerce matters.


Anne Petterd focuses on technology, telecommunications, customs and export controls, and consumer and commercial law issues. Much of her practice involves online, telecommunications and IT businesses as well as defence and government procurement. She previously worked with the Australian Government Solicitor. She also worked in Baker McKenzie's London office for 18 months and seconded to major telecommunications and information technology service providers. Anne handles projects involving digital economy, cloud computing and large-scale IT supplies in the Asia Pacific. Her work focuses on the retail, telecommunications, defence, government and financial services sectors, and often involves new business models and test regulatory issues on privacy and telecommunications. Anne also advises on customs assessment, compliance and export control requirements as well as related trade and product compliance issues. She regularly works with regulators on these matters.