On 14 June 2017, Singapore Customs released a circular announcing the introduction of new end-user statement (EUS) formats for Strategic Trade Scheme (STS) bulk permits and individual permits, respectively. The new format is effective immediately for bulk permits, and from 1 July 2017 for individual permits.
For STS individual permits, the new EUS format:
- No longer requires an indication of the value of the goods to be exported to the end-user; and
- Clearly stipulates that the EUS is only to support STS individual permit applications.
For STS bulk permits, the new EUS format:
- No longer requires an indication of the quantity and value of goods to be exported to the end-user; and
- Includes additional text to specify the validity period for the EUS, i.e. either:
- Up to three years after it is signed; or
- Up to the validity period specified by Singapore Customs in the STS bulk permit approval.
The new EUS formats, which supersede the general EUS format that previously was used for both STS individual and bulk permits, are being implemented to accommodate the diverse business models adopted by companies.
Of particular note, the new EUS format for the STS bulk permit will supersede any EUS “facilitations” granted to bulk permit holders before 1 January 2015.
Effect of the changes
Exporters applying for STS individual permits up to 30 June 2017 may continue to use the existing EUS format to support their submissions.
However, as from 1 July 2017, submissions of STS individual permits must be supported by an EUS using the new format. If companies fail to comply with the new submission process, their applications will be rejected.
For STS bulk permit holders, the new EUS has been implemented with immediate effect.
Exporters under an STS bulk permit, therefore, must adopt the new EUS format for:
- New end-users;
- Existing end-users, when there are changes to the details of a current EUS;
- Existing EUS that were granted a facilitation; and
- New and existing end-users, when applying for a renewal of the STS bulk permit.
As mentioned above, the Singapore Customs circular on the changes to the EUS format stipulates that the new format will supersede any previous EUS facilitations granted before 1 January 2015. Our assessment is that there is still scope to explore, with Singapore Customs, extending previously granted EUS facilitations into current STS bulk permit approvals.
To avoid experiencing rejections or delays in their export permit applications, companies should:
- Ensure that the EUS used to support all STS individual permit applications from 1 July 2017 are using the new format;
- Review existing end-users under the STS bulk permit and assess whether revisions need to be made to the existing EUS details, prior to exports to those end-users;
- Adopt the new EUS formats when applying for or renewing their STS bulk permits; and
- Where the EUS is generated using an ERP system, assess whether a system update is required to generate EUS with the new format.
If you would like to find out more about the changes to the Singapore EUS formats for STS Individual and Bulk Permits and how it impacts your business, please get in contact with the following Deloitte team members:
- Pablo LeCour is a Partner in Deloitte's Global Export Controls and Sanctions team, London.
- Bob Fletcher is a Tax Director in the Tax and Legal team, Singapore.
- Stacey Toder Feldman is a Director in Deloitte's Global Export Controls and Sanctions team, London.
- Nur Diyanah Anuar is a Senior Manager in Deloitte’s Tax and Legal team, Singapore.