Research/Import and compliance brief进口与合规指南
Bringing a robot into Southeast Asia
机器人进入东南亚
Five countries, five regulators, one path from a factory in Shenzhen to a robot at work. The classification, duty, tax, licensing, radio approval, safety, battery and data rules for each, with the number behind each line and where it comes from.
五个国家、五个监管机构、一条从深圳工厂到机器人上岗的路径。每个国家的归类、关税、税收、进口资质、无线电核准、安全、电池和数据规则，每一条都给出背后的数字和来源。
中文版由我们自行翻译，表格、图表和来源保留英文。如有歧义，以英文版为准。
A service robot leaving a factory in Guangdong is, to the five customs services of Southeast Asia, three things at once: a machine, a radio transmitter and a lithium battery. Each of those has its own rulebook in each country, and the rulebooks were written for other products. The robot borrows its tariff line from industrial machinery, its radio approval from phones and routers, its shipping rules from laptops, and its safety standard from wheelchairs and forklifts. Nobody has written the robot version down, so we did.
This brief follows one robot along the path in Fig 1. For each stop it gives the rule in each of the five countries, the number that matters, and the source. We use it ourselves to quote landed cost and lead time, and we publish it so that a maker in Shenzhen and a buyer in Jakarta read the same page.
01Classification, duty and tax
Customs duty depends on the tariff line, and robots sit awkwardly between lines. The Harmonized System has one heading written for robots, 8479.50, "industrial robots, not elsewhere specified", meant for the arms on car lines. A cleaning robot or a delivery robot is usually entered as a machine with an individual function under 8479.89, or as handling equipment under 8428, and a humanoid has no settled line at all. Which line applies changes the duty, so the first document to settle with a customs broker is a classification ruling or at least a written opinion.
| Line | What customs means by it | SG | MY | ID | VN | TH | China origin with Form E |
|---|---|---|---|---|---|---|---|
| 8479.50 | Industrial robots, not elsewhere specified. Written for arms on production lines. | 0% | 0% | 5% | 0% | 0% | Indonesia 0% verified |
| 8479.89 | Other machines with an individual function. Where US Customs put AgiBot's humanoids and quadrupeds in ruling NY N356154, and where most service robots land.3 | 0% | 0% | 5% | 0% | 0% | Indonesia 0%, Thailand 0% verified |
| 8428.90 | Other lifting and handling machinery. Argued for warehouse AMRs that carry goods.4 | 0% | 0 to 5% | 5% | 0% | 0 to 5% | Indonesia 0%, Thailand 0%, Malaysia 0% verified |
| 8508.11 | Vacuum cleaners with a self-contained motor. Household robot vacuums, and the trap for a commercial cleaning robot described carelessly. | 0% | 20% | 10% | 25% | 10% | Vietnam 5%, others 0% verified |
MFN rates are the 2023 applied rates in the World Bank's WITS tariff database, the latest year it holds for these countries; the China-origin rates are the ASEAN-China FTA rates WITS records, 2021 or earlier, so confirm the current schedule before quoting a landed cost.1 All five countries use the ASEAN Harmonised Tariff Nomenclature on HS 2022, so the six-digit lines are common.2
Two naming traps. Describing a mobile robot as an "AGV" invites a vehicle heading with far higher duty, so the paperwork should say "autonomous mobile robot" or "machine with individual function".5 And "AMR" is marketing language with no definition in ISO 8373, which is why customs officers reach for the function of the machine instead.6
The ASEAN-China Free Trade Area removes duty on most machinery of Chinese origin when the shipment carries a Form E certificate of origin from a Chinese issuing body. The duty saving is the whole MFN rate, so a maker that cannot issue Form E is quoting a higher landed price whether it knows it or not. Value added tax or goods and services tax is charged at import in every country. In Singapore, Indonesia, Vietnam and Thailand a registered business claims it back, so it is a cash-flow cost. Malaysia's sales tax is a single-stage tax with no credit, so there it is a real cost on the robot's price.
| Country | Duty on a service robot (8479.89) | Tax at import | Other levies | Is the tax a final cost? |
|---|---|---|---|---|
| Singapore | 0%. Only liquor, tobacco, vehicles and petroleum are dutiable.7 verified | GST 9% on CIF value since 1 January 2024.8 | None. Import GST can be suspended under the Major Exporter and similar schemes.9 | No, for a GST-registered buyer. |
| Malaysia | 0% MFN. verified | Sales tax. Industrial machinery moved from 0% to 5% on 1 July 2025; unlisted goods pay 10%.10 The exact rate for each 8479 line after the 31 July 2026 amendment is unconfirmed. reported | Manufacturers importing machinery for their own production are exempt under Sales Tax Policy 4/2025.11 | Yes. Sales tax is single stage and is not credited back, so it is a real 5 to 10% on the robot's price. |
| Indonesia | 5% MFN, 0% with Form E. verified | VAT 12% on a deemed base of eleven twelfths, an effective 11%.12 | Income tax prepayment PPh 22: 2.5% of import value with an importer identification number, 7.5% without.13 | No. VAT is credited and PPh 22 is a prepayment of the importer's own income tax. |
| Vietnam | 0% under Decree 26/2023 for 8479.50 and most 8479.89 lines.14 reported | VAT 10% standard, cut to 8% for most goods from 1 July 2025 to 31 December 2026 by Resolution 204/2025.15 Whether robots sit in an excluded group is unconfirmed. | Special consumption tax not checked. | No, for a VAT-registered buyer. |
| Thailand | 0% MFN. verified | VAT 7%, extended to 30 September 2027 by Royal Decree 807; the statutory rate is 10%.16 reported | Excise not checked. | No, for a VAT-registered buyer. |
A worked landed cost
A cleaning robot quoted at US$12,000 FOB Shenzhen, with US$400 of sea freight and insurance, arrives at a customs value of US$12,400. Fig 2 shows what each government adds at the border, under the line 8479.89 and with Form E in hand. Singapore takes the most at the border and gives it all back to a GST-registered buyer. Malaysia takes the least and keeps it. Indonesia's stack looks large until you notice that two thirds of it comes back as a VAT credit and an income tax prepayment, and that without Form E and an importer number it would be US$704 higher. estimate
02Who can import
The importer of record has to be a company in the destination country in every case. The requirements range from a free online registration in Singapore to a licensing system in Indonesia that decides, by product, who may import at all.
| Country | Importer of record | What the import needs | Robot-specific catch |
|---|---|---|---|
| Singapore | Any company with a UEN that activates a Customs Account, free, online.17 verified | A customs permit through TradeNet for every shipment, filed by the importer or a declaring agent.18 | Radio equipment needs an IMDA dealer's licence on the importer's side, which TradeNet checks. |
| Malaysia | A Malaysian company. | Communications equipment is a restricted import under the Customs (Prohibition of Imports) Order 2023: the SIRIM QAS certificate of approval is applied for through ePermit before the goods clear.19 reported | Electrical equipment on the Energy Commission's list also needs a certificate of approval or an exemption letter.20 |
| Indonesia | An Indonesian company with a business identification number (NIB) and the right importer type: API-U to import for resale, API-P to import inputs for its own production.21 reported | Goods must be new; used capital goods need separate approval under Permendag 24/2025.22 Electronics listed in Permendag 21/2025 need an import approval and a surveyor report.23 | Whether the robot tariff lines are on the 21/2025 list is the open question; the annex could not be read. |
| Vietnam | A Vietnamese company, including a foreign-invested one whose registration includes import rights.24 reported | No general machinery licence. Used machinery only if under ten years old, under Decision 18/2019.25 | Radio approval through a local applicant, see section 03. |
| Thailand | A company registered with Thai Customs for e-Customs, with a digital certificate.26 reported | No general machinery licence. | Importers of certified radio equipment reportedly also hold an NBTC seller licence.27 |
No country lists robots, humanoids or quadrupeds as a restricted import as such. The controls reach the robot through its radio module, its charger, its battery and, in Indonesia, possibly through the electronics list. unverified as an absence.
03Radio type approval
Every service robot carries at least one radio: Wi-Fi, Bluetooth, usually an LTE or 5G modem, often a 2.4 GHz remote. Each transmitter needs approval from the telecoms regulator of each country before the robot is sold, imported or in some countries even switched on. The approval attaches to a model, so a maker that changes its Wi-Fi module between production batches has created a new product in five regulators' eyes. This is the step that most often delays a first shipment, because it is the one that makers who sell in China do not meet at home.
| Country | Regulator and route | Who may apply | Wi-Fi and Bluetooth | LTE and 5G modem | Validity, fee, time |
|---|---|---|---|---|---|
| Singapore | IMDA equipment registration.28 verified | Only a holder of an IMDA telecommunication dealer's licence (individual licence S$250 for five years).29 A foreign maker cannot register directly. | ESER, a free online self-declaration for short-range devices. | SER, a self-declaration for mobile terminals, S$100 plus S$50 per family. | Five years. GER, for high-interference kit, S$350 to S$500. Label "Complies with IMDA Standards" plus the dealer licence number.30 |
| Malaysia | MCMC, certified through SIRIM QAS.31 verified | A Malaysian-registered company; a foreign maker only through a local representative.32 | Compliance approval for sale, or a Special Approval for trials, demonstrations and exhibitions that may not be sold locally.33 | Five years on a certificate we read for a Wi-Fi and Bluetooth board.34 Fees and times not published. | |
| Indonesia | Komdigi (formerly Kominfo, SDPPI) under Permenkominfo 3/2024.35 verified | An Indonesian business with an NIB; a foreign brand appoints an Indonesian representative and files the appointment letter.36 | Test reports from a designated domestic lab or a recognised foreign lab; Komdigi announced in June 2025 that most testing moves into Indonesia by end 2026.37 | Three years.38 reported Fees set as state revenue; current amounts not found. | |
| Vietnam | Ministry of Science and Technology, which absorbed the information ministry on 1 March 2025; product list in Circular 29/2025.39 reported | A Vietnamese-registered importer, distributor, subsidiary or compliance agent.40 | Certification plus a declaration of conformity for radio transmitters; the CR conformity mark replaced the ICT mark on 31 December 2024. | Three years with a valid ISO 9001; about seven to eight weeks from a complete file.40 | |
| Thailand | NBTC.41 reported, all from test labs | A Thai person or company, or a Thai representative with power of attorney.27 | Class B or a self-declaration for low-power short-range devices. | Class A for cellular. | No expiry; about eight weeks; foreign ISO 17025 reports to RED or FCC rules accepted, sometimes with Thai frequency tests. |
The practical sequence is to get the module-level approvals first, because a robot that uses an already-certified Wi-Fi or cellular module can often reuse the module's test reports, then apply for the robot as a host product. We ask every maker for the module part numbers and their existing certificates before we quote a lead time.
04Product safety and batteries
Electrical safety rules in the region are written for consumer appliances. A robot is rarely on the list of controlled products, which means it is rarely required to carry a national safety mark, and also that the buyer, not the regulator, has to ask for the test report. We ask for IEC 62368-1 or IEC 60335-1 test reports on the charger and dock, and for the battery pack's IEC 62133-2 report.
| Country | Mandatory product safety scheme | Does it catch a service robot? |
|---|---|---|
| Singapore | Consumer Protection (Safety Requirements) Registration Scheme: 33 categories of household electrical, electronic and gas appliances must be tested, registered and carry the SAFETY Mark.42 verified | The scheme is for goods supplied to consumers. A commercial robot sold to a business sits outside it; its adapter or charger may not, and a product with a controlled and a non-controlled function is treated as controlled as a whole.43 We did not check the 33-item list line by line. unverified |
| Malaysia | Energy Commission certificate of approval and the ST-SIRIM label for regulated electrical equipment under the Electricity Regulations 1994; the list includes household appliances, adapters, chargers and vacuum cleaners.44 reported | The charger, and a cleaning robot that customs calls a vacuum cleaner. |
| Indonesia | Mandatory SNI standards; vacuum cleaners must meet SNI IEC 60335-2-2.45 reported | No mandatory SNI for robots, humanoids or mobile robots found. unverified |
| Vietnam | The amended Law on Product and Goods Quality in force from 1 January 2026 with three risk tiers; high-risk goods need certification against a national technical regulation.46 reported | No robot-specific technical regulation found. |
| Thailand | TISI mandatory standards, about 136 categories in 2025, including lithium batteries and charging equipment.47 reported | The battery and the charger, possibly, which is reason to ask the maker for TISI status before shipping. |
Shipping the battery
A robot's battery decides how it travels. Lithium-ion cells need a UN 38.3 test summary, which the maker must produce, before any carrier accepts them. A battery installed in the robot ships as UN 3481 ("lithium ion batteries contained in equipment") under dangerous goods class 9; loose spare packs ship as UN 3480. By air, the IATA packing instructions cap what passengers and cargo may carry, and packs above 100 Wh cannot go in passenger baggage at all without airline approval, which matters when an engineer wants to carry a demonstration unit. The numbers from the IATA 2026 guidance: up to 100 Wh per battery for the lighter Section II rules, full class 9 above that; a battery packed with equipment, and from 1 January 2026 a robot shipped as a battery-powered vehicle, travels at no more than 30% state of charge; passengers may carry up to 100 Wh freely, 100 to 160 Wh with airline approval and at most two spares, and nothing above 160 Wh.48 verified A humanoid's pack is several hundred watt-hours, so it never flies as baggage. By sea the same packs travel under the IMDG Code with a dangerous goods declaration. A maker that cannot hand over a UN 38.3 summary and a safety data sheet has not shipped internationally before.
05Robots in use: safety standards and public space
No country in the region licenses a service robot the way it licenses a lift or a vehicle. The rules that apply are the general workplace safety law, the building code, and, for robots on public paths, the road or active mobility law. Buyers fill the gap with international standards: ISO 13482 for personal care robots, ISO 3691-4 for driverless industrial trucks and the mobile robots that behave like them, ISO 10218 for industrial arms, and ISO/TS 15066 for collaborative robots. Singapore adopts these as Singapore Standards and adds its own.
| Where | Rule or standard | What it does for a robot |
|---|---|---|
| International | ISO 10218-1 and -2, revised 2025, with the collaborative robot content of ISO/TS 15066 folded in.49 reported | Industrial arms and cells. The reference for a humanoid working beside people in a factory until a humanoid standard exists. |
| International | ISO 13482, personal care robots, being replaced by a wider service robot safety standard at FDIS stage; publication by October 2026 unconfirmed.50 unverified | The standard most service robot makers cite. Ask which edition the test report is against. |
| International | ISO 3691-4:2023, driverless industrial trucks, which names autonomous mobile robots in scope.51 reported | Warehouse and factory mobile robots. |
| Singapore | SS 713:2025 robot-to-lift and robot-to-door data exchange, promoted from TR 93:2021; TR 104:2022 safe use of mobile robots in warehouses; TR 130:2025 fleet interoperability; SS ISO 18646-2:2025 navigation performance.52 verified | SS 713 is the one to ask a maker about: it is how the robot rides a lift without a human pressing buttons. |
| Singapore | Active Mobility Act: autonomous mobile robots count as motor vehicles and may not use public paths without an exemption order from the Minister for Transport through LTA; footpath limit 10 km/h; trials request by form to LTA.53 verified | Any delivery robot on a public footpath. Private premises are outside the Act. Punggol Digital District runs under a precinct-wide exemption, and an AV Act is planned for Parliament in 2027.54 |
| Singapore | Workplace Safety and Health Act, with the WSH guidelines on safe use of machinery as the basis for a risk assessment.55 reported | The site's duty, which the robot's safety file has to support. |
| Malaysia | Occupational Safety and Health (Amendment) Act 2022 in force 1 June 2024; the Factories and Machinery Act repealed; certificates of fitness remain for boilers, pressure vessels and lifting machinery.56 reported | No robot-specific DOSH guideline found. |
| Indonesia, Vietnam, Thailand | No robot-specific deployment or public-path rule found. unverified | General workplace law and the building owner's rules apply. |
06Data: cameras, microphones and where the video goes
Every service robot records. Cameras for navigation, microphones for voice, logs that place a robot and the people around it at a time. All five countries now have a general data protection law that treats images of identifiable people as personal data, and three of them restrict sending that data abroad. A robot that streams camera frames to a maker's servers in China for "remote support" is, in each country, a cross-border transfer that the operator has to be able to justify.
| Country | Law | Sending robot video abroad | Breach notice and ceiling fine |
|---|---|---|---|
| Singapore | PDPA. A video image of an individual is personal data; CCTV and recordings are covered in the Selected Topics guidelines revised May 2024.57 verified | Allowed when the overseas recipient is bound, usually by contract, to a comparable standard.58 | Mandatory notification regime; fines up to 10% of Singapore turnover in the Act (not re-checked this pass). |
| Malaysia | PDPA as amended in 2024, phased in through 1 June 2025: data protection officer, breach notification, portability.59 reported | Whitelist removed; allowed where the destination has a substantially similar law or under listed exceptions, with cross-border guidelines issued in 2025.60 | 72 hours; up to RM1,000,000 and three years' jail.61 |
| Indonesia | PDP Law 27/2022, with implementing regulation GR 33/2026 enacted 16 July 2026 and a compliance deadline of 16 January 2027.62 reported | Adequacy, then binding safeguards, then consent for limited transfers; the supervisory agency that would approve the first two does not exist yet, so consent is the working route. | 72 hours; up to 2% of annual gross revenue. |
| Vietnam | Law 91/2025/QH15 in force 1 January 2026 with Decree 356/2025.63 reported | Storing Vietnam-collected data abroad, or using a platform outside Vietnam to process it, is a cross-border transfer; a transfer impact assessment goes to the authority within 60 days of the first transfer. | Up to 5% of prior-year revenue for cross-border violations.64 |
| Thailand | PDPA 2019, with cross-border notifications under sections 28 and 29 in force 24 March 2024.65 reported | Adequate countries, otherwise binding corporate rules, standard clauses or certification; no adequacy list published. | Administrative fines up to THB 3 million, THB 5 million for sensitive data sent abroad.66 |
None of the five has a blanket rule that robot video must stay in the country. Vietnam comes closest, with a filing duty and the largest fine, and Indonesia's missing agency means a Chinese maker's standard remote-support clause rests on consent there.
Our contract requirement is simple: video and audio stay in the deployment country unless the site agrees in writing, the maker's remote access is logged, and the operator can switch it off. A maker that cannot agree to that cannot sell into a hospital, a school or a government building here.
07Money on the table
Governments in the region subsidise automation, and the grants are large enough to change a buyer's decision. The grant goes to the local buyer, so a maker's local partner is the one who can use it in a sale.
| Country | Scheme | What it gives |
|---|---|---|
| Singapore | EDGE grant, open since 30 September 2026, replacing PSG, EDG and MRA.67 verified | Up to 70% of cost for SMEs and 50% for others, capped at S$100,000 per company per year, within which S$30,000 for single-function digital solutions and selected automation; the buyer must be Singapore-registered with at least 30% local ownership.68 Separately, a 400% tax deduction on up to S$50,000 of AI spending a year for YA2027 and YA2028.69 |
| Malaysia | Automation capital allowance.70 reported | 200% allowance on the first RM10 million of qualifying automation spend, YA2023 to YA2027, for companies operating at least 36 months; Budget 2026 adds accelerated allowances on plant, machinery and ICT bought from 11 October 2025 to 31 December 2026.71 |
| Indonesia | Investment incentives.72 reported | Import duty and VAT exemption on machinery for promoted investments, a tax holiday for pioneer industries that reportedly name robotics, and an R&D super deduction up to 300%. Robot eligibility not confirmed on a regulator site. |
| Vietnam | Law 71/2025 on the digital technology industry, incentives from 1 July 2025.73 reported | Import duty exemption on goods that form fixed assets and preferential corporate tax for digital technology producers; whether a robot buyer qualifies is unconfirmed. |
| Thailand | BOI Notification 4/2569, gazetted 31 March 2026, applications 2026 to 2027.74 reported | Import duty exemption on machinery and a three-year corporate tax exemption worth 50% of automation and robotics investment, rising to 100% when at least 30% of machinery value comes from Thai automation makers. |
08The paperwork, in order
What we collect from a maker before the first unit ships. A maker that can produce all of this in a week is ready to export; one that cannot is not, whatever the price.
- Commercial invoice and packing list with the HS code the maker proposes, the robot's model number as it appears on its label, and the battery's watt-hours.
- Form E certificate of origin from a Chinese issuing body, so the ASEAN-China preferential rate applies.
- UN 38.3 test summary and a safety data sheet for the battery, and the dangerous goods declaration for the carrier.
- Radio module list: every transmitter in the robot with its part number, bands, output power and any existing certificates in any market.
- Radio approval application in the destination country through a local holder, started before the ship leaves.
- Electrical safety reports on the charger, dock and battery pack to IEC standards, from an accredited lab.
- Robot safety file: the standard the robot was designed to, the risk assessment, and the maker's safety manual.
- Data map: what the robot records, where it sends it, who at the maker can reach it, and how to turn remote access off.
- Warranty and spares terms in writing: warranty period by subsystem, what voids it, whether an authorised third party may repair, the spare parts price list, and the location of in-country stock.
- Service manual, fault code table and diagnostic access for the operator, so the robot can be kept running without a ticket to Shenzhen.
No ASEAN customs ruling on a humanoid or quadruped has been published; the 8479.89 reading rests on US rulings. Malaysia's sales tax at the eight-digit level after July 2026, Indonesia's electronics import annex, radio fees and official processing times in Indonesia, Malaysia and Vietnam, every Thai radio fact from the regulator's own pages, the publication status of the new ISO 13482, excise on robots in Thailand and Vietnam, and the 2026 ACFTA line rates are all open. We will update this page as each closes.
Sources
- WITS TRAINS tariff data, MFN applied rates 2023 and ACFTA rates, World Bankread 2 Oct 2026
- Harmonized Tariff Schedule, heading 8479.50 and 8479.89, USITC
- Customs ruling NY N356154, tariff classification of AgiBot robotic platforms from Chinarequest dated 17 Nov 2025
- HS codes for robots, Robot Sourcing Index22 Jun 2026
- Customs duty on AMR and AGV, DF Automation27 May 2020
- Definition of service robots, IFR World Robotics 2026
- Import procedures overview, Singapore Customs
- GST rate change, IRAS
- Import operations overview and GST schemes, Singapore Customs
- FAQ on the transition of sales tax rate changes 2025, Royal Malaysian Customs9 Jun 2025
- Sales Tax Policy No. 4/2025, Royal Malaysian Customs10 Oct 2025
- PMK 11/2025 on the VAT base, Directorate General of Taxes, Indonesia2025
- PPh Pasal 22, Directorate General of Taxes, Indonesia
- Preferential import tariff, heading 84, from 15 Jul 2023 (Decree 26/2023), Thư Viện Pháp Luật
- Resolution 204/2025/QH15 on the reduction in value added tax17 Jun 2025
- Thailand's Royal Decree 807 extends the 7% VAT rateAug 2026
- Activate a Customs Account, Singapore Customs
- Obtain a customs import permit, Singapore Customs
- SIRIM import permit for communications equipment, DHL Malaysia
- Malaysia Suruhanjaya Tenaga approval, TÜV Rheinland
- Import licences in Indonesia, SIP Law Firm2025
- Indonesia Permendag 24/2025 on the import of non-new goods, TÜV Rheinland
- Permendag 21/2025 on the import of electronic and telematics goods, Ministry of Trade, Indonesia30 Jun 2025
- New regulations on foreign investment in goods trading (Decree 09/2018), Tilleke & Gibbins
- Decision 18/2019/QD-TTg on the import of used machinery
- Guide to Thailand's import and export procedures, ASEAN Briefing
- Thailand NBTC type approval guide, Nanotech
- Equipment registration, IMDAread 2 Oct 2026
- Telecommunication dealer's (individual) licence, GoBusiness
- Singapore IMDA labelling requirements, C-PRAVSep 2024
- Equipment compliance approval, MCMC
- Who is eligible to apply for certification, MCMC
- Special approval requirements, SIRIM QAS
- Certificate of conformity, Raspberry Pi Zero 2, SIRIM QAS15 Nov 2021
- Permenkominfo 3/2024 on certification of telecommunication equipment, Komdigi23 Feb 2024
- Telecommunication equipment certification service, Komdigi
- Komdigi to conduct local testing of most telecom equipment in 2026, CAICT17 Jun 2025
- SDPPI certification for Indonesia, TÜV SÜD2 Sep 2026
- Circular 29/2025/TT-BKHCN, lists of products requiring certification, LuatVietnam13 Nov 2025
- Vietnam type approval guide for 2026, MiCOM Labs
- Thailand type approval guide, MiCOM Labs
- Overview of the Consumer Protection (Safety Requirements) Registration Scheme, Consumer Product Safety Office
- CPSR information booklet, Consumer Product Safety OfficePDF offline when checked on 2 Oct 2026 and not archived; the scheme page in the previous source carries the same rules
- SIRIM certification in Malaysia, Emerhub
- SNI scope list, TÜV Rheinland Indonesia
- Amended Law on Product and Goods Quality, Vietnam Briefing
- Thailand TISI mandatory certification 2025, Blue Asia Labs
- Lithium battery guidance document 2026, IATA1 Jan 2026
- ISO 10218-1:2025 robot safety, ANSI blog2025
- ISO/FDIS 13482, Robotics, safety requirements for service robots, ISO
- ISO 3691-4:2023 driverless industrial trucks, ANSI blog
- SS 713:2025, Singapore Standards eShopwith TR 93:2021, TR 104:2022, SS ISO 18646-2:2025
- Exemption request for active mobility devices, LTA
- Consultation paper on the regulatory and legal framework for AVs, LTA and MOTApr 2026
- Robots at the workplace, NUS TRAIL
- Malaysia OSH (Amendment) Act 2022 in effect, Enviliance2024
- Advisory guidelines on the PDPA for selected topics, PDPCMay 2024
- Guide to cross-border data transfers, PDPC
- Implementation of the PDP (Amendment) Act 2024, DFDL2025
- Key amendments to Malaysia's PDPA and the cross-border transfer guidelines, Mayer BrownJul 2025
- Malaysia tightens data protection from June 2025, ASEAN Briefing
- Indonesia's PDP implementing regulation GR 33/2026, Nusantara DFDL24 Sep 2026
- Law on Personal Data Protection No. 91/2025/QH15, LuatVietnam26 Jun 2025
- Decree 356/2025/ND-CP implementing the personal data law, LuatVietnam31 Dec 2025
- Thailand's regulations for cross-border personal data transfer come into force, Tilleke & Gibbins2024
- New Thai law targets cross-border data flows, ASEAN Briefing
- EDGE grant, Enterprise SingaporeSep 2026
- EDGE grant FAQ, Enterprise Singapore
- Budget 2026 summary for businesses, GoBusiness13 Apr 2026
- Guideline for the automation capital allowance, services sector, MIDAJul 2024
- Malaysia's 2026 budget, ASEAN BriefingOct 2025
- Indonesia tax credits and incentives, PwC Tax Summaries2026
- Vietnam passes its first law on the digital technology industry, Vietnam Briefing2025
- Thailand's BOI in 2026, Mahanakorn Partners2026
一台离开广东工厂的服务机器人，在东南亚五国海关眼里同时是三样东西：一台机器、一台无线电发射设备和一块锂电池。这三样在每个国家各有一套规则，而这些规则都是为别的产品写的。机器人借用工业机械的税则号、手机和路由器的无线电核准、笔记本电脑的运输规则，以及轮椅和叉车的安全标准。没有人把"机器人版"写下来，所以我们写了。
本文沿着图 1 的路径跟踪一台机器人。每一站给出五个国家各自的规定、要紧的数字和来源。我们自己用它来报到岸成本和交期，公开它是为了让深圳的厂商和雅加达的买家读的是同一页。
01归类、关税与税
关税取决于税则号，而机器人在税则号之间的位置很尴尬。协调制度里只有一个为机器人而写的税目：8479.50"未列名的工业机器人"，本意是汽车生产线上的机械臂。清洁机器人或配送机器人通常按 8479.89"具有独立功能的其他机器"申报，或按 8428 搬运设备申报，而人形机器人根本没有定论。适用哪个税则号会改变关税，所以与报关行要敲定的第一份文件是归类裁定，至少是一份书面意见。
| Line | What customs means by it | SG | MY | ID | VN | TH | China origin with Form E |
|---|---|---|---|---|---|---|---|
| 8479.50 | Industrial robots, not elsewhere specified. Written for arms on production lines. | 0% | 0% | 5% | 0% | 0% | Indonesia 0% verified |
| 8479.89 | Other machines with an individual function. Where US Customs put AgiBot's humanoids and quadrupeds in ruling NY N356154, and where most service robots land.3 | 0% | 0% | 5% | 0% | 0% | Indonesia 0%, Thailand 0% verified |
| 8428.90 | Other lifting and handling machinery. Argued for warehouse AMRs that carry goods.4 | 0% | 0 to 5% | 5% | 0% | 0 to 5% | Indonesia 0%, Thailand 0%, Malaysia 0% verified |
| 8508.11 | Vacuum cleaners with a self-contained motor. Household robot vacuums, and the trap for a commercial cleaning robot described carelessly. | 0% | 20% | 10% | 25% | 10% | Vietnam 5%, others 0% verified |
中国东盟自由贸易区对原产于中国的大多数机械免除关税，前提是货物附有中国签发机构出具的 Form E 原产地证。省下的是整个最惠国税率，所以开不出 Form E 的厂商，无论自己知不知道，报的都是更高的到岸价。增值税或商品及服务税在每个国家都在进口时征收。在新加坡、印度尼西亚、越南和泰国，注册企业可以抵扣，因此只是现金流成本；马来西亚的销售税是单一环节税，不能抵扣，在那里是机器人价格上实实在在的成本。
| Country | Duty on a service robot (8479.89) | Tax at import | Other levies | Is the tax a final cost? |
|---|---|---|---|---|
| Singapore | 0%. Only liquor, tobacco, vehicles and petroleum are dutiable.7 verified | GST 9% on CIF value since 1 January 2024.8 | None. Import GST can be suspended under the Major Exporter and similar schemes.9 | No, for a GST-registered buyer. |
| Malaysia | 0% MFN. verified | Sales tax. Industrial machinery moved from 0% to 5% on 1 July 2025; unlisted goods pay 10%.10 The exact rate for each 8479 line after the 31 July 2026 amendment is unconfirmed. reported | Manufacturers importing machinery for their own production are exempt under Sales Tax Policy 4/2025.11 | Yes. Sales tax is single stage and is not credited back, so it is a real 5 to 10% on the robot's price. |
| Indonesia | 5% MFN, 0% with Form E. verified | VAT 12% on a deemed base of eleven twelfths, an effective 11%.12 | Income tax prepayment PPh 22: 2.5% of import value with an importer identification number, 7.5% without.13 | No. VAT is credited and PPh 22 is a prepayment of the importer's own income tax. |
| Vietnam | 0% under Decree 26/2023 for 8479.50 and most 8479.89 lines.14 reported | VAT 10% standard, cut to 8% for most goods from 1 July 2025 to 31 December 2026 by Resolution 204/2025.15 Whether robots sit in an excluded group is unconfirmed. | Special consumption tax not checked. | No, for a VAT-registered buyer. |
| Thailand | 0% MFN. verified | VAT 7%, extended to 30 September 2027 by Royal Decree 807; the statutory rate is 10%.16 reported | Excise not checked. | No, for a VAT-registered buyer. |
到岸成本算例
一台深圳离岸价 12,000 美元的清洁机器人，加 400 美元海运和保险，到港完税价格 12,400 美元。图 2 显示了按 8479.89 归类并持有 Form E 时各国政府在口岸加收的金额。新加坡在口岸收得最多，但对增值税注册的买家全部退还。马来西亚收得最少，但不退。印度尼西亚的税负看起来最高，直到你注意到其中三分之二会以增值税抵扣和所得税预缴的形式回来，而没有 Form E 和进口商识别号的话会再高出 704 美元。estimate
02谁可以进口
无论哪个国家，进口商都必须是目的国的公司。要求从新加坡的免费在线登记，到印度尼西亚按产品决定谁可以进口的许可制度，不一而足。
| Country | Importer of record | What the import needs | Robot-specific catch |
|---|---|---|---|
| Singapore | Any company with a UEN that activates a Customs Account, free, online.17 verified | A customs permit through TradeNet for every shipment, filed by the importer or a declaring agent.18 | Radio equipment needs an IMDA dealer's licence on the importer's side, which TradeNet checks. |
| Malaysia | A Malaysian company. | Communications equipment is a restricted import under the Customs (Prohibition of Imports) Order 2023: the SIRIM QAS certificate of approval is applied for through ePermit before the goods clear.19 reported | Electrical equipment on the Energy Commission's list also needs a certificate of approval or an exemption letter.20 |
| Indonesia | An Indonesian company with a business identification number (NIB) and the right importer type: API-U to import for resale, API-P to import inputs for its own production.21 reported | Goods must be new; used capital goods need separate approval under Permendag 24/2025.22 Electronics listed in Permendag 21/2025 need an import approval and a surveyor report.23 | Whether the robot tariff lines are on the 21/2025 list is the open question; the annex could not be read. |
| Vietnam | A Vietnamese company, including a foreign-invested one whose registration includes import rights.24 reported | No general machinery licence. Used machinery only if under ten years old, under Decision 18/2019.25 | Radio approval through a local applicant, see section 03. |
| Thailand | A company registered with Thai Customs for e-Customs, with a digital certificate.26 reported | No general machinery licence. | Importers of certified radio equipment reportedly also hold an NBTC seller licence.27 |
没有一个国家把机器人、人形机器人或四足机器人本身列为限制进口商品。管制通过无线电模块、充电器、电池，以及（在印度尼西亚）可能通过电子产品清单触及机器人。作为"未发现"的结论，标注unverified。
03无线电型号核准
每台服务机器人至少带一个无线电模块：Wi-Fi、蓝牙，通常还有 LTE 或 5G 模块，常常还有 2.4 GHz 遥控器。每一个发射器都需要在每个国家取得电信监管机构的核准，然后机器人才能销售、进口，在某些国家甚至才能开机。核准绑定型号，所以厂商在两个生产批次之间换了 Wi-Fi 模块，在五个监管机构眼里就是造了一个新产品。这是最常拖延首批发货的一步，因为在中国本土销售的厂商在国内不需要过这一关。
| Country | Regulator and route | Who may apply | Wi-Fi and Bluetooth | LTE and 5G modem | Validity, fee, time |
|---|---|---|---|---|---|
| Singapore | IMDA equipment registration.28 verified | Only a holder of an IMDA telecommunication dealer's licence (individual licence S$250 for five years).29 A foreign maker cannot register directly. | ESER, a free online self-declaration for short-range devices. | SER, a self-declaration for mobile terminals, S$100 plus S$50 per family. | Five years. GER, for high-interference kit, S$350 to S$500. Label "Complies with IMDA Standards" plus the dealer licence number.30 |
| Malaysia | MCMC, certified through SIRIM QAS.31 verified | A Malaysian-registered company; a foreign maker only through a local representative.32 | Compliance approval for sale, or a Special Approval for trials, demonstrations and exhibitions that may not be sold locally.33 | Five years on a certificate we read for a Wi-Fi and Bluetooth board.34 Fees and times not published. | |
| Indonesia | Komdigi (formerly Kominfo, SDPPI) under Permenkominfo 3/2024.35 verified | An Indonesian business with an NIB; a foreign brand appoints an Indonesian representative and files the appointment letter.36 | Test reports from a designated domestic lab or a recognised foreign lab; Komdigi announced in June 2025 that most testing moves into Indonesia by end 2026.37 | Three years.38 reported Fees set as state revenue; current amounts not found. | |
| Vietnam | Ministry of Science and Technology, which absorbed the information ministry on 1 March 2025; product list in Circular 29/2025.39 reported | A Vietnamese-registered importer, distributor, subsidiary or compliance agent.40 | Certification plus a declaration of conformity for radio transmitters; the CR conformity mark replaced the ICT mark on 31 December 2024. | Three years with a valid ISO 9001; about seven to eight weeks from a complete file.40 | |
| Thailand | NBTC.41 reported, all from test labs | A Thai person or company, or a Thai representative with power of attorney.27 | Class B or a self-declaration for low-power short-range devices. | Class A for cellular. | No expiry; about eight weeks; foreign ISO 17025 reports to RED or FCC rules accepted, sometimes with Thai frequency tests. |
实际的顺序是先取得模块级核准：使用已认证 Wi-Fi 或蜂窝模块的机器人通常可以复用模块的测试报告，然后再为机器人整机作为宿主产品申请。我们在报交期之前，会向每家厂商索要模块型号及其在任何市场已有的证书。
04产品安全与电池
本地区的电气安全规则是为消费类电器写的。机器人很少出现在受管制产品清单上，这意味着它很少被要求贴国家安全标志，也意味着要测试报告的是买家而不是监管机构。我们要求充电器和充电桩提供 IEC 62368-1 或 IEC 60335-1 测试报告，电池包提供 IEC 62133-2 报告。
| Country | Mandatory product safety scheme | Does it catch a service robot? |
|---|---|---|
| Singapore | Consumer Protection (Safety Requirements) Registration Scheme: 33 categories of household electrical, electronic and gas appliances must be tested, registered and carry the SAFETY Mark.42 verified | The scheme is for goods supplied to consumers. A commercial robot sold to a business sits outside it; its adapter or charger may not, and a product with a controlled and a non-controlled function is treated as controlled as a whole.43 We did not check the 33-item list line by line. unverified |
| Malaysia | Energy Commission certificate of approval and the ST-SIRIM label for regulated electrical equipment under the Electricity Regulations 1994; the list includes household appliances, adapters, chargers and vacuum cleaners.44 reported | The charger, and a cleaning robot that customs calls a vacuum cleaner. |
| Indonesia | Mandatory SNI standards; vacuum cleaners must meet SNI IEC 60335-2-2.45 reported | No mandatory SNI for robots, humanoids or mobile robots found. unverified |
| Vietnam | The amended Law on Product and Goods Quality in force from 1 January 2026 with three risk tiers; high-risk goods need certification against a national technical regulation.46 reported | No robot-specific technical regulation found. |
| Thailand | TISI mandatory standards, about 136 categories in 2025, including lithium batteries and charging equipment.47 reported | The battery and the charger, possibly, which is reason to ask the maker for TISI status before shipping. |
电池的运输
机器人的电池决定它怎么走。锂离子电芯在任何承运人接收之前都需要 UN 38.3 测试摘要，由厂商出具。装在机器人里的电池按 UN 3481"设备内的锂离子电池"以第 9 类危险品运输，散装备用电池按 UN 3480。空运时 IATA 包装指南限制旅客和货物可携带的数量，超过 100 Wh 的电池未经航空公司批准不能进入旅客行李，这对想随身带一台演示机的工程师很要紧。IATA 2026 年指南中的数字：每块电池 100 Wh 以内适用较宽松的第二节规则，超过则是完整的第 9 类；与设备一同包装的电池，以及自 2026 年 1 月 1 日起作为电池驱动车辆运输的机器人，荷电状态不超过 30%；旅客可自由携带 100 Wh 以内的电池，100 到 160 Wh 需航空公司批准且备用电池最多两块，160 Wh 以上不得携带。48 verified 人形机器人的电池包有几百瓦时，永远不能作为行李上飞机。海运时同样的电池按《国际海运危险货物规则》运输，附危险品申报。拿不出 UN 38.3 摘要和安全数据表的厂商，以前没有做过国际发货。
05使用中的机器人：安全标准与公共空间
本地区没有哪个国家像给电梯或车辆发牌那样给服务机器人发牌。适用的是一般性的职业安全法、建筑规范，以及对公共道路上的机器人适用的道路或主动出行法。买家用国际标准填补空白：ISO 13482 个人护理机器人，ISO 3691-4 无人驾驶工业车辆及行为类似的移动机器人，ISO 10218 工业机械臂，ISO/TS 15066 协作机器人。新加坡把这些采纳为新加坡标准，并增加了自己的标准。
| Where | Rule or standard | What it does for a robot |
|---|---|---|
| International | ISO 10218-1 and -2, revised 2025, with the collaborative robot content of ISO/TS 15066 folded in.49 reported | Industrial arms and cells. The reference for a humanoid working beside people in a factory until a humanoid standard exists. |
| International | ISO 13482, personal care robots, being replaced by a wider service robot safety standard at FDIS stage; publication by October 2026 unconfirmed.50 unverified | The standard most service robot makers cite. Ask which edition the test report is against. |
| International | ISO 3691-4:2023, driverless industrial trucks, which names autonomous mobile robots in scope.51 reported | Warehouse and factory mobile robots. |
| Singapore | SS 713:2025 robot-to-lift and robot-to-door data exchange, promoted from TR 93:2021; TR 104:2022 safe use of mobile robots in warehouses; TR 130:2025 fleet interoperability; SS ISO 18646-2:2025 navigation performance.52 verified | SS 713 is the one to ask a maker about: it is how the robot rides a lift without a human pressing buttons. |
| Singapore | Active Mobility Act: autonomous mobile robots count as motor vehicles and may not use public paths without an exemption order from the Minister for Transport through LTA; footpath limit 10 km/h; trials request by form to LTA.53 verified | Any delivery robot on a public footpath. Private premises are outside the Act. Punggol Digital District runs under a precinct-wide exemption, and an AV Act is planned for Parliament in 2027.54 |
| Singapore | Workplace Safety and Health Act, with the WSH guidelines on safe use of machinery as the basis for a risk assessment.55 reported | The site's duty, which the robot's safety file has to support. |
| Malaysia | Occupational Safety and Health (Amendment) Act 2022 in force 1 June 2024; the Factories and Machinery Act repealed; certificates of fitness remain for boilers, pressure vessels and lifting machinery.56 reported | No robot-specific DOSH guideline found. |
| Indonesia, Vietnam, Thailand | No robot-specific deployment or public-path rule found. unverified | General workplace law and the building owner's rules apply. |
06数据：摄像头、麦克风和视频去了哪里
每台服务机器人都在记录。用于导航的摄像头、用于语音的麦克风，以及把机器人和周围的人定位在某个时刻的日志。五个国家现在都有通用的个人数据保护法，把可识别个人的影像视为个人数据，其中三个国家限制把这类数据传到境外。一台为了"远程支持"把摄像头画面传到厂商在中国的服务器的机器人，在每个国家都构成跨境传输，运营方必须能够说明理由。
| Country | Law | Sending robot video abroad | Breach notice and ceiling fine |
|---|---|---|---|
| Singapore | PDPA. A video image of an individual is personal data; CCTV and recordings are covered in the Selected Topics guidelines revised May 2024.57 verified | Allowed when the overseas recipient is bound, usually by contract, to a comparable standard.58 | Mandatory notification regime; fines up to 10% of Singapore turnover in the Act (not re-checked this pass). |
| Malaysia | PDPA as amended in 2024, phased in through 1 June 2025: data protection officer, breach notification, portability.59 reported | Whitelist removed; allowed where the destination has a substantially similar law or under listed exceptions, with cross-border guidelines issued in 2025.60 | 72 hours; up to RM1,000,000 and three years' jail.61 |
| Indonesia | PDP Law 27/2022, with implementing regulation GR 33/2026 enacted 16 July 2026 and a compliance deadline of 16 January 2027.62 reported | Adequacy, then binding safeguards, then consent for limited transfers; the supervisory agency that would approve the first two does not exist yet, so consent is the working route. | 72 hours; up to 2% of annual gross revenue. |
| Vietnam | Law 91/2025/QH15 in force 1 January 2026 with Decree 356/2025.63 reported | Storing Vietnam-collected data abroad, or using a platform outside Vietnam to process it, is a cross-border transfer; a transfer impact assessment goes to the authority within 60 days of the first transfer. | Up to 5% of prior-year revenue for cross-border violations.64 |
| Thailand | PDPA 2019, with cross-border notifications under sections 28 and 29 in force 24 March 2024.65 reported | Adequate countries, otherwise binding corporate rules, standard clauses or certification; no adequacy list published. | Administrative fines up to THB 3 million, THB 5 million for sensitive data sent abroad.66 |
五个国家都没有一刀切地规定机器人视频必须留在境内。越南最接近，有备案义务和最高的罚款；印度尼西亚缺少监管机构，意味着中国厂商的标准远程支持条款在那里只能依靠同意。我们的合同要求很简单：视频和音频留在部署国境内，除非场地书面同意；厂商的远程访问有日志记录，运营方可以关闭。做不到这一点的厂商，卖不进这里的医院、学校或政府大楼。
07桌上的钱
本地区各国政府补贴自动化，补贴额度大到足以改变买家的决定。补贴给的是本地买家，所以能在销售中用上它的，是厂商的本地合作伙伴。
| Country | Scheme | What it gives |
|---|---|---|
| Singapore | EDGE grant, open since 30 September 2026, replacing PSG, EDG and MRA.67 verified | Up to 70% of cost for SMEs and 50% for others, capped at S$100,000 per company per year, within which S$30,000 for single-function digital solutions and selected automation; the buyer must be Singapore-registered with at least 30% local ownership.68 Separately, a 400% tax deduction on up to S$50,000 of AI spending a year for YA2027 and YA2028.69 |
| Malaysia | Automation capital allowance.70 reported | 200% allowance on the first RM10 million of qualifying automation spend, YA2023 to YA2027, for companies operating at least 36 months; Budget 2026 adds accelerated allowances on plant, machinery and ICT bought from 11 October 2025 to 31 December 2026.71 |
| Indonesia | Investment incentives.72 reported | Import duty and VAT exemption on machinery for promoted investments, a tax holiday for pioneer industries that reportedly name robotics, and an R&D super deduction up to 300%. Robot eligibility not confirmed on a regulator site. |
| Vietnam | Law 71/2025 on the digital technology industry, incentives from 1 July 2025.73 reported | Import duty exemption on goods that form fixed assets and preferential corporate tax for digital technology producers; whether a robot buyer qualifies is unconfirmed. |
| Thailand | BOI Notification 4/2569, gazetted 31 March 2026, applications 2026 to 2027.74 reported | Import duty exemption on machinery and a three-year corporate tax exemption worth 50% of automation and robotics investment, rising to 100% when at least 30% of machinery value comes from Thai automation makers. |
08文件清单，按顺序
首台设备发货前我们向厂商收取的材料。一周内能备齐全部材料的厂商已经准备好出口；备不齐的，无论价格如何，都还没有准备好。
- 商业发票和装箱单，写明厂商建议的税则号、与机器人铭牌一致的型号，以及电池的瓦时数。
- 中国签发机构出具的 Form E 原产地证，以适用中国东盟优惠税率。
- UN 38.3 测试摘要和电池的安全数据表，以及给承运人的危险品申报。
- 无线电模块清单：机器人内每一个发射器的型号、频段、输出功率，以及在任何市场已有的证书。
- 目的国无线电核准申请，通过本地持证人提交，在船离港前启动。
- 电气安全报告：充电器、充电桩和电池包按 IEC 标准由认可实验室出具。
- 机器人安全文件：机器人设计所依据的标准、风险评估和厂商的安全手册。
- 数据地图：机器人记录什么、发到哪里、厂商哪些人能访问、如何关闭远程访问。
- 书面的保修和备件条款：按子系统划分的保修期、什么情况下失效、授权第三方能否维修、备件价格表，以及境内库存地点。
- 维修手册、故障码表和诊断访问权限，让运营方不用给深圳开工单也能让机器人保持运行。
东盟没有公布过对人形或四足机器人的海关裁定，8479.89 的判断依据的是美国裁定。马来西亚 2026 年 7 月之后八位税号级别的销售税税率、印度尼西亚电子产品进口附件、印度尼西亚、马来西亚和越南的无线电核准费用和官方处理时限、泰国监管机构自己页面上的每一条无线电规定、新版 ISO 13482 的发布状态、泰国和越南对机器人的消费税，以及 2026 年的中国东盟协定税率，都还是开放问题。每解决一项我们就更新本页。