Last updated 27 September 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Statutory references are to the Consumer Protection (Trade Descriptions and Safety Requirements) Act 1975 (2020 Revised Edition) and the Consumer Protection (Safety Requirements) Regulations as in force on 27 September 2026. For a specific product or claim, take advice from a lawyer or the Competition and Consumer Commission of Singapore.
Most Singapore marketers know the Consumer Protection (Fair Trading) Act, the civil statute that lets a customer claw back money after an unfair practice. Far fewer know the older statute sitting beside it, which is criminal, which is aimed squarely at product claims, and which reaches the person who wrote the copy as well as the brand that sold the goods.
That statute is the Consumer Protection (Trade Descriptions and Safety Requirements) Act 1975. It turns almost every factual statement about a physical product into a “trade description”: the weight on the packet, the “100% cotton” in a Shopee title, the “made in Japan” on a product page, the “lab-tested” badge in a Meta ad, and the “as used in five-star hotels” line on a landing page. If that statement is false or likely to mislead in a material respect, applying it or selling goods under it is an offence carrying up to $10,000 or two years’ imprisonment.
The same Act powers the SAFETY Mark scheme, whose regulations make it an offence to advertise for the purpose of supply any of 33 categories of household electrical and gas goods that are not registered and marked. For an online seller, the listing is the offence. This guide covers both halves and who is liable.
What counts as a “trade description”
Section 2(1) defines a trade description as “any description, statement or indication which, directly or indirectly and by whatever means given” relates to any of eleven matters. “By whatever means given” is doing a lot of work: a photograph, an icon, a flag emoji next to a product name or a comparison chart can all be an indication. The eleven matters read like a product-page template.
| Limb of s 2(1) | What it covers | Where it shows up in marketing |
|---|---|---|
| (a) | Quantity, length, width, height, area, volume, capacity or weight | “2kg”, “55-inch”, “30L capacity”, pack counts in listing titles |
| (b) | Method of manufacture, production, processing or reconditioning | “Handmade”, “hand-stitched”, “cold-pressed”, “refurbished to factory standard” |
| (c) | Composition | “100% cotton”, “solid teak”, “genuine leather”, “stainless steel 304” |
| (d) | Fitness for purpose (including expiry date), strength, performance, behaviour or accuracy | “Waterproof to 50m”, “removes 99% of dust”, “10-hour battery”, “shatterproof” |
| (e) | Degree of fineness of gold and silver goods | “916 gold”, “999.9”, “sterling silver” |
| (f) | Other physical characteristics | Colour, finish, dimensions shown in a size chart |
| (g) | Testing by any person, and the results | “Lab-tested”, “dermatologically tested”, “passed drop test” |
| (h) | Approval by any person, or conformity with an approved type | “Certified”, “approved”, standards logos and certification badges |
| (i) | Place or date of manufacture, production, processing or reconditioning | “Made in Singapore”, “Japanese-made”, “2026 model”, “freshly roasted this week” |
| (j) | The person by whom goods are manufactured, produced, processed or reconditioned | “Made by the OEM for brand X”, “crafted by our in-house team” |
| (k) | Other history, including previous ownership or use | “Brand new”, “one owner”, “never used”, “ex-display” |
The Act applies to goods, which section 2 defines broadly to include vehicles, animals, plants and “all kinds of movable property”. It does not govern claims about services as such; misleading service claims fall under the Fair Trading Act instead, which our guide to the legal requirements for a Singapore website covers.
Two carve-outs that matter
First, under section 2(2) and the Schedule, where a trade description is governed by one of three specified laws — the Sale of Food Act 1973, the Health Products Act 2007 and the Electric Vehicles Charging Act 2022 (added from 8 December 2023) — this Act does not apply to a description applied in accordance with that law. Section 13 also takes goods regulated by those laws outside the safety Part entirely. So food claims are primarily a matter for our guide to food advertising claims, and supplements, medicines, cosmetics and medical devices for our guide to health product advertising.
Second, section 2(4) says a trade description published in a newspaper, book, periodical, film or broadcast is not treated as applied in the course of trade unless it is, or forms part of, an advertisement. Genuine editorial reviews are outside the Act; advertorials and paid influencer posts are advertisements.
The offence: false, or likely to mislead in a material respect
Section 4 makes it an offence for any person, in the course of a trade or business, to (a) apply a false trade description to any goods, or (b) supply any goods to which a false trade description is applied. “Supply” includes offering to supply, so an online listing that offers goods is within (b).
Section 5 then defines a false trade description more widely than “untrue”. It is one which, “by reason of anything contained in or omitted from” it, is “false or likely to mislead in a material respect”. Three points follow.
- Literally true can still be false if the overall impression is likely to mislead.
- Omissions count. “Contained in or omitted from” means leaving out a qualifier — “refurbished”, “sold as a set of two”, “weight before packing” — can make an otherwise accurate description false.
- Standards claims are specially targeted. Section 5(b) deems it a false trade description to give a false indication that goods comply with a standard specified or recognised by any person, or approved by any person, where no such person or standard exists. An invented certification badge is caught even if the product is perfectly good.
Section 5(a)(ii) adds that altering a trade description — adding to it, effacing it or otherwise — so that it becomes misleading is itself a false trade description. Re-labelling imported stock is the obvious case.
How a description gets “applied”
Section 6 was written for labels but reaches digital marketing. A person applies a trade description if they mark it on the goods or their packaging, or if they “use the trade description in any manner likely to be taken as referring to the goods” (s 6(1)(c)). An oral statement can amount to use (s 6(2)), so a salesperson’s pitch or a livestream host’s patter counts. And if goods are supplied in response to a request that used a description, the supplier is deemed to have applied it (s 6(3)): a customer who orders “the waterproof version” and receives one that is not has been supplied goods under a false trade description.
Advertisements bind the whole class of goods
Section 7 is the provision that makes this Act a marketing statute. Where a trade description is used in an advertisement “in relation to any class of goods”, it is taken as referring to all goods of the class, whether or not in existence at the time the advertisement is published.
In practice, a brand-level claim attaches to every unit you later sell. If a campaign says “all our rattan furniture is handwoven in Indonesia”, and next season’s stock is machine-woven in another country, the old ad now describes the new stock falsely. Section 7(3) tells a court to decide what the “class” is by looking not only at the ad’s content but at “the time, place, manner and frequency of its publication” — an evergreen website banner or a pinned post is still describing your goods years after it was written.
Section 2 defines “advertisement” to include a catalogue, a circular and a price list. That is an inclusive definition, and a product feed that populates Google Shopping or a Meta catalogue is functionally a catalogue.
Who is liable — including the agency
The brand that sells the goods is the obvious defendant under section 4. The less obvious ones are in Part 5.
- Section 18, offences due to the fault of another person. Where an offence under the Act “is due to the act or default of some other person, that other person shall be guilty of the offence”, and can be charged and convicted “whether or not proceedings are taken against the firstmentioned person”. A copywriter who invents “handmade in Italy”, a supplier who sends a false spec sheet, or an agency that adds “clinically tested” to punch up a headline can each be the “other person”.
- Section 17, officers of companies. Where a company’s offence was committed with the consent or connivance of, or is attributable to neglect by, a director, manager or secretary, that person is also guilty.
- Section 20, the innocent publication defence. A person charged over publication of an advertisement has a defence if their business is to publish or arrange for the publication of advertisements, they received the advertisement in the ordinary course of business, and they did not know and had no reason to suspect that publishing it would be an offence. The defence is built for media owners and placement desks. It does not naturally fit the team that wrote the claim.
Section 19 gives every defendant a due-diligence defence: that the offence was due to a mistake, reliance on information supplied, the act or default of another person, an accident or a cause beyond their control, and that they took all reasonable precautions and exercised all due diligence. Blaming someone else requires written notice to the prosecutor at least seven clear days before the hearing (s 19(2)).
The practical consequence is that “the client told us” is only a defence if you can show the precautions. Keep the spec sheet, the certificate or the supplier’s written confirmation behind every factual claim, and keep it where you can find it for three years — section 16 gives prosecutors that long to begin proceedings.
“As used by” and “approved by”: section 14
Part 4 of the Act adds one more offence that is squarely about marketing copy. Under section 14(1), a person commits an offence if, in the course of trade, they give “any false indication, direct or indirect, that any goods supplied by the person or any methods adopted by the person are or are of a kind supplied to or approved by any person including any government or government department or agency or any international body or agency”, in Singapore or abroad.
That covers “as supplied to leading hotels” and “official supplier to” claims, “government-approved” or “HDB-approved” badges, “WHO-approved” style international claims, and client logo walls implying the named organisations buy the product. Each is lawful only if the supply or approval is real.
Section 14(2) preserves every other law restricting the use of names, emblems, seals, flags and titles, so a false government-approval claim can also engage the rules in our guide to brand impersonation and, for a flag or crest, the national symbols rules.
The SAFETY Mark: advertising unregistered goods is an offence
Part 3 of the Act lets the Minister impose safety requirements on classes of goods and prohibit supply of goods that do not meet them (s 11). The Consumer Protection (Safety Requirements) Regulations use that power, and regulation 4(1) is the rule every e-commerce marketer needs to know.
It provides that no person shall, in the course of trade, “supply or advertise for the purpose of supply” any controlled goods unless they are registered controlled goods conforming to the safety requirements, and have the Safety Mark affixed. A contravention is an offence under section 11(2), so the Act’s general penalty of up to $10,000 or two years applies, and the Safety Authority can require a recall; failing to carry out a required recall is a separate offence of up to $2,000 or 12 months.
Read the verb again: advertise. A marketplace listing, a social post with a “buy now” link or a paid ad for an unregistered controlled product is the offence, even if nothing has shipped.
Which goods are controlled
The First Schedule lists 33 categories, all effective from 15 January 2018. They are household electrical, electronic and gas products, including:
- Audio and video products, home computer systems and AC adaptors
- Fans, air coolers, air-conditioners, refrigerators, washing machines, vacuum cleaners and irons
- Kettles, water heaters, coffee makers, toasters, fryers, microwaves, rice cookers, blenders and ovens
- Hair dryers, curlers, straighteners and stylers
- Plugs, fuses, socket-outlets, cable reels, multi-way adaptors, switches, lamps and decorative lighting
- Portable gas cookers, their gas canisters, and LPG hoses, regulators and valves
Each category has a precise description with limits, most commonly household use at a rated voltage of not more than 250 Vac, so check the Schedule wording rather than the headline.
What “registered and marked” means
Regulation 5 requires the importer or manufacturer in Singapore that intends to supply or advertise controlled goods to register as a Registered Supplier and register each product. Registration needs a certificate of conformity or, for low-risk goods, a supplier’s declaration backed by a test report (reg 7). The fee is $180 per registration and $50 per renewal, and registration lasts up to three years or the validity of the certificate, whichever is shorter (reg 8).
The Safety Mark itself is defined in the Second Schedule: a safety logo in a square, the words “SAFETY MARK” in a rectangle, and a unique 8-digit certification number traceable to the registrant. Only a Registered Supplier may affix it, and only to goods it has registered (reg 13); affixing it otherwise is an offence of up to $2,000 or 12 months.
Who enforces it now
Since 1 July 2025, the Safety Authority under the Act is the Competition and Consumer Commission of Singapore: the Competition (Amendment) Act 2025 moved the Consumer Product Safety Office from Enterprise Singapore to CCCS, and existing registrations remain valid. One agency now handles fair-trading complaints and product safety, so a complaint about a misleading listing can more easily become a safety inquiry.
“Made in Singapore” and other origin claims
Place of manufacture, production or processing is limb (i) of the definition, and the person who made the goods is limb (j). So an origin claim is a trade description, and it is judged by the section 5 test: is it false or likely to mislead in a material respect?
The Act does not set a percentage or a “last substantial transformation” rule for when goods may be called made in a particular country. That is a real grey zone, and it is why the safe drafting is specific rather than impressionistic. Compare:
- Risky: “Made in Singapore” on a phone case designed here and manufactured in Shenzhen. A reasonable buyer would take it to mean manufactured here.
- Safer: “Designed in Singapore, made in China” or “Singapore brand, manufactured by our partner in Shenzhen”. Both are true and neither omits the material fact.
- Risky by omission: “Italian leather sofa” where only the hide is Italian and the frame and upholstery are done elsewhere. The phrase is literally true, but section 5 asks what it is likely to convey.
- Risky by imagery: a Japanese flag, a “Japan quality” roundel and Japanese-script packaging on a product made in Vietnam. “By whatever means given” includes visual indications.
A product-claims checklist for e-commerce teams
- Build a claims register. For every factual claim in titles, bullets, images, feeds and ads, record the limb of s 2(1) it touches and the evidence behind it: spec sheet, test report, certificate or supplier confirmation. That register is your section 19 due diligence.
- Audit the feed, not just the page. Shopping and catalogue feeds are rewritten by tools, templates and marketplace optimisers. A template that appends “100% cotton” to a whole category is a section 7 class advertisement.
- Retire evergreen class claims when sourcing changes. “All our furniture is solid wood” on a homepage describes next season’s stock too.
- Treat badges as claims. Every “certified”, “tested” or standards logo must correspond to a real certificate for that model. Invented badges are deemed false by section 5(b).
- Check “as used by” claims and logo walls against real supply relationships (s 14).
- Screen electrical and gas products against the First Schedule before listing, and show the Safety Mark and number in the images.
This checklist belongs in the product-data workflow, not just copy review. Our guides to e-commerce conversion optimisation and Black Friday for Singapore e-commerce show where product claims do their commercial work; this Act limits how far they go. Mega-sale price claims have their own rulebook, covered in our 9.9, 11.11 and 12.12 campaign guide, and appliances also need the energy label rules in our guide to energy label advertising.
Worked examples
1. The refurbished laptop. A reseller lists ex-corporate laptops as “new, unboxed”. Previous ownership and use are limb (k). Calling them “refurbished, grade A, 30-day warranty” is the compliant version; the original is false by omission even if every unit works perfectly.
2. The marketplace hair straightener. A small importer lists a straightener on a marketplace before registering it, planning to register “once it sells”. Hair straighteners are item 9 of the First Schedule. Advertising for the purpose of supply without registration and a Safety Mark is the offence in regulation 4(1), from the moment the listing is live.
3. The agency headline. An agency writes “lab-tested to kill 99.9% of bacteria” for a kitchen cloth after the client said it was “very hygienic”. No test exists. Testing and results are limb (g), performance is limb (d), and section 18 lets the agency be charged for an offence due to its act, whether or not the brand is.
Quantity claims have their own statute. The Weights and Measures Act makes it an offence to use non-metric units on a package, price list or advertisement unless a metric figure comes first and no smaller, and to sell packs short of their stated weight; see our guide to the weights and measures rules for Singapore listings and labels.
Product descriptions are only half of what CCS reads on a store. The other half is the interface around them: countdown timers, “people are viewing this” counters, pre-ticked add-ons and reviews. Our guide to dark patterns in Singapore covers the cases and an audit checklist.
Frequently asked questions
What is a false trade description in Singapore?
Under section 5 of the Consumer Protection (Trade Descriptions and Safety Requirements) Act 1975, it is a trade description that, because of what it contains or omits, is false or likely to mislead in a material respect about the goods. Applying one, or supplying goods to which one is applied, in the course of trade is an offence under section 4, with a maximum of $10,000 or two years’ imprisonment.
Does the Trade Descriptions Act apply to online listings and ads?
Yes. A trade description can be given “by whatever means”, a person applies one by using it in any manner likely to be taken as referring to the goods, and supply includes offering to supply. Section 7 also says a description in an advertisement refers to all goods of the class advertised.
Can a marketing agency be prosecuted for a client’s false product claim?
It can. Section 18 provides that where an offence is due to the act or default of another person, that person is guilty of the offence and can be convicted whether or not the business that sold the goods is prosecuted. The innocent publication defence in section 20 is designed for businesses that publish or arrange publication of advertisements they receive in the ordinary course without reason to suspect a problem.
Can I sell electrical products online in Singapore without a Safety Mark?
Not if they are controlled goods. Regulation 4(1) of the Consumer Protection (Safety Requirements) Regulations prohibits supplying or advertising for the purpose of supply any of the 33 categories of controlled goods unless they are registered and carry the Safety Mark. Advertising an unregistered product is itself the offence.
Can I say “Made in Singapore” if my product is designed here but manufactured overseas?
That is risky. Place of manufacture is a trade description, and the test is whether the claim is likely to mislead in a material respect. The Act sets no percentage rule, so the safe approach is to state both facts plainly, for example “Designed in Singapore, made in Vietnam”.
The takeaway
The Trade Descriptions Act reads like a fifty-year-old statute about labels, which is why marketers overlook it. But it covers every product title, feed attribute, badge and ad line, it is criminal, and it reaches the copywriter as well as the seller. Two habits cover most of the risk: keep evidence behind every factual claim for three years, and screen electrical and gas products against the Safety Mark schedule before listing, because there the advertisement is the offence.
If your product pages, feeds and store build need that discipline designed in, it is part of what our web design and e-commerce team does; see our client case studies. Start with our guide to web design in Singapore, and read this alongside the legal requirements for a Singapore website.
