I don't fully read the details yet, but looks quite fascinating program, including and mixed the concept of AEO, export bulk license (STS), and tax privilege.
One impressive point is that Singapore Customs assign Account Manager to the companies who participate in this program. The Account Manager is Singapore Customs officer and acts as contacting point or adviser, and help to answer various kinds of inquires regardless of its jurisdictions.
Also, the companies' privilege is divided into 5 categories, from Basic (for all traders) to the highest status is Premium. (Basic, Standard, Intermediate, Enhanced, then Premium)
The higher the status, the more the benefits.
Currently, 29 companies in Singapore are in Premium status, they looks like combination of mostly subsidiaries of US or European firm, and local companies.
I'm impressed Singapore Customs' smart and pro-business approach. They fully understand the importance of regional hub role, being competitive in trade facilitation, and drawing business by setting up attractive scheme.
(P.S.: As for export control perspective, I find the STS Handbook was update as of January 25, 2011. The Trade FIRST element was added into this handbook. For example as below.
What are the basic qualifying criteria to be eligible for a permit under the STS?
2.5.1 You have to meet the following basic criteria in order to qualify for a permit under the STS:
(a) You are a registered trader with Singapore Customs; and
(b) In the case of applications for Tier 2 and Tier 3 Permits, you must:
(i) maintain a good trade compliance record with Singapore Customs;
(ii) implement an effective Internal (Export Control) Compliance Programme; and
(iii) Achieve at least the “Enhanced” band under TradeFIRST. (added)
- Remove Indian entities from Entity List
- Remove India from country group D
I took a look Entity List today, and find it has been updated as of January 25, 2011. As for Indian entities, only remaining entities are the following Department of Atomic Energy entities:
Bhabha Atomic Research Center (BARC)
Indira Gandhi Atomic Research Center (IGCAR)
Indian Rare Earths
This means all other entities such as subsidiaries of India’s Defense Research and Development Organization (“DRDO”) and subsidiaries of the Indian Space Research Organization (“ISRO”) are no longer restricted in Entity List.
Other main change is removing from country group D. I took a look Part 740Spir - Supplement No. 1 to Part 740, Country Groups, and find India is in Group A:2 and Group B. This will change the applicable license exceptions.
However, please be noted it is only for export permit application of Category 0 (Nuclear items) which will be exported from April 1st, 2011 onward. Exporters have a period of 3 months preparation of export permit of this category and the application for the export permits must be submitted to the Atomic Energy Licensing Board (AELB) for category 0. Details on the application procedures are available on http://www.aelb.gov.my/ .
(I don't think Malaysia companies have many nuclear related items, though. In other word, it is good grace period in starting phase for improving the procedures in government authorities and industries by evaluating how implementation going on in real operational world.)
The export permit requirement for all other strategic items under the STA i.e., Military
Items and Dual Use Items (Category 1-9), will be enforced on 1st July 2011 and
companies are required to apply for the export permits from 1st April 2011.
Good news for exporters are the controlled items list is finally available on Malaysia MITI web site.
It can be downloaded in MS-Word file. As it was announced previously, the list is in link with EU list. I find their control list is, yes, same as EU list Annex I to Regulation 428/2009. The noteworthy point is that the list have conversion column with HS code, and relevant government authority is indicated in the right side column. I think HS code conversion is useful only for "first time" traders who have no idea of equivalent ECCN of their items. Please be noted export control code and HS code have totally different criteria in classification, HS code should be only for reference purpose to narrow down the possible export code.
Ministry of Finance (“MOF”) in Japan review the rule to what items are applicable to Generalized System of Preferences (“GSP”) tariff, and consequently 462 items of Chinese origin items will be not eligible to GSP tariff. GSP is a system to impose lower import duty to encourage import from developing countries and aim to help their economic development. The new policy by MOF is basically to terminate the GSP tariff to certain items which import amount occupy more than 50% from specific one country or region in consecutive three years. With applying this new policy, many Chinese origin items such as vegetables and variety of consumer items will be in target of the new rule, because import of such items are mostly occupied by China. The import duty rate for such items will increase 2.4% ~ 5.2% by applying MFN rate instead of GSP, and the increased trade cost will affect importers, or will be reflected into retail price in Japan.
MOF plan to amend the Temporary Tariff Measures Law and to implement the new tariff rule from April 2011. As Chinese commodities are gaining competitiveness internationally, it aims to terminate preferential measure to China to help other developing countries. The examples are vegetables from China such as Burdock (HS 0706.90), Matsutake mushroom (HS 0709.59), or consumer items such as Fireworks (HS 3604), Pearls (HS 7116), Fishing rods (HS 9507), or Thermos bottle (HS 9617) etc. All of them have been 0% import duty under GSP, but MFP rate ranges from 2.5% to 5.2%. Other examples are prepared fish such as Mackerel (HS 1604.11) and Eel (HS 1604.19), the GSP duty of them are 7.2%, while MFN rate is 9.6%.
In fiscal year 2009, the 86% of import amount under GSP was occupied by Chinese origin items. The background of this decision is that Chinese products are almost competitive internationally and treated well too much under GSP. system On the other hand, after 462 items are excluded from GSP treatment, still 3090 items are eligible to GSP and most of them are actually imported from China.
The list of HS code of Chinese origin items which will be excluded from GSP on April 2011 is already available in Customs web site. Traders who have business with China and made use of GSP should investigate whether your items are included in the list for assessing the trade cost impact to business in fiscal year 2011.
(Source and list of items: 平成23年度税制改正大綱 内閣府ホームページ)