Three packaging rules under Singapore’s Resource Sustainability Act 2019 now affect producers and retailers. Companies with annual turnover above S$10 million that import or use packaging for goods supplied in Singapore must report packaging data and 3R plans to NEA each year, with the next window running from 1 January to 31 March 2027. Supermarket operators with turnover above S$100 million must charge at least 5 cents per disposable carrier bag. And since 1 October 2026, covered plastic and metal drink containers supplied in Singapore must carry the deposit mark, barcode and a 10-cent deposit.
Which of the three rules applies to my company?
Each rule has its own trigger. A brand owner importing bottled drinks may be caught by all three. A boutique retailer with S$3 million turnover may be caught only by the deposit rules when it sells drinks.
| Rule | Who is caught | Main obligation | Key date |
|---|---|---|---|
| Mandatory packaging reporting | Producers of regulated goods with annual turnover above S$10 million that import or use packaging | Annual packaging data report and 3R plan to NEA | 1 January to 31 March each year (2027 window covers 2026 data) |
| Disposable carrier bag charge | Supermarket operators with company-level annual turnover above S$100 million, at SFA-licensed supermarkets | Charge at least 5 cents per bag and publish data annually | In force since 3 July 2023 |
| Beverage container return scheme | Importers and manufacturers of covered drinks; retailers selling them; large supermarkets as return points | Register with the scheme operator, label containers, charge and refund the 10-cent deposit | Started 1 April 2026; full labelling from 1 October 2026 |
Mandatory packaging reporting: are we a producer?
NEA says a company must report if it meets all three criteria:
- It carries on a business of supplying regulated goods in Singapore.
- Its annual turnover exceeds S$10 million.
- It imports or uses specified packaging.
Producers include brand owners, manufacturers, importers and retailers such as supermarkets. Retailers report service packaging they hand out, such as carrier bags. Where you buy goods already packed from a local supplier, NEA says the reporting obligation generally sits with that supplier, unless you engaged them to manufacture or import the products for you.
Turnover is measured on a calendar year basis, not your financial year, and it is your total gross revenue, not just sales of packaged goods. NEA counts sales whether local or overseas. The test looks back two years: a company whose turnover exceeded S$10 million in 2025 must report its 2026 packaging data and 3R plans between 1 January and 31 March 2027. Because the obligation attaches to each company that meets the criteria, review each entity in a group separately. If your company’s financial year does not follow the calendar year, ask your accountant to produce calendar-year revenue figures from the ledger.
What goes into the report and the 3R plan?
- Packaging data. The annual weight of packaging imported or used, broken down by material (plastic, paper, metal, glass and so on) and by form (carrier bags, bottles and so on), rounded to whole numbers. Packaging is reported even if it is later recycled or reused.
- 3R plan. Key initiatives, indicators and targets to reduce, reuse or recycle packaging over three years, with progress reported in later years.
- Supporting documents submitted with NEA’s reporting template.
Registration and submission are through NEA’s Waste and Resource Management System. Keep the records behind each report and plan for five years.
The numbers usually come from purchasing and import records rather than the general ledger, so build the data collection into procurement. Companies already preparing sustainability reports can reuse the packaging data, but the NEA report is a separate statutory filing.
What if we miss the packaging report?
NEA’s published guidance on the Act sets out the same penalty structure for failing to submit a packaging report (section 20(4)), failing to submit a 3R plan (section 21(3)) and failing to keep records (section 23(3)):
| Conviction | Maximum penalty |
|---|---|
| First conviction | Fine of up to S$5,000 |
| Second or subsequent conviction | Fine of up to S$10,000, imprisonment of up to 3 months, or both |
| Continuing offence after a second conviction | Further fine of up to S$1,000 for each day or part of a day |
If you discover the company should have reported in an earlier cycle, contact NEA at its packaging reporting address, gather the historical purchasing data and file as soon as possible rather than waiting for the next window.
How does the carrier bag charge work?
Since 3 July 2023, supermarket operators with company-level annual turnover above S$100 million must charge at least 5 cents for each disposable carrier bag at their SFA-licensed supermarkets. NEA says this covers about 400 outlets. The rules were added to the Act as a new Part 4A by the 2023 amendments.
- The charge is per bag, not per transaction, and applies to bags of every material, including paper and biodegradable bags.
- It applies to in-store purchases, scan-and-go purchases and bags used to deliver in-store purchases to customers’ homes.
- It does not apply to online orders, including click-and-collect.
- Operators must publish each year the number of bags supplied, the proceeds collected and how the proceeds were used, and registered retailers report data to NEA.
Smaller supermarkets and other retailers are encouraged, but not required, to charge. If you charge voluntarily, record bag income in your sales records and, if the company is registered for GST, check its GST treatment with your accountant.
What does the beverage container return scheme require?
The scheme began on 1 April 2026 and is run by Beverage Container Return Scheme Ltd (BCRS Ltd), a not-for-profit company licensed by NEA. The transition period ran from 1 April to 30 September 2026. NEA’s circular of 16 September 2026 confirms that from 1 October 2026, containers for all covered beverage products must carry a deposit mark and barcode, and a 10-cent deposit, when supplied in Singapore.
What is covered: pre-packaged drinks in plastic and metal containers from 150ml to 3 litres, including water, soft drinks, juices, dairy drinks, cordials and alcohol. Cartons, pouches, glass, freshly prepared drinks made and sold on the premises, and foods for special medical purposes are outside the scheme.
Producers that import or manufacture covered drinks must register with BCRS Ltd as members, pay the scheme fees, register each product’s container and barcode details, and make sure the containers carry the deposit mark. If you import drinks yourself, even for your own retail shops, you may be the producer. Our article on duties for importers covers the customs side of the same shipments.
Retailers charge the 10-cent deposit on each marked container sold. NEA has said supermarkets with floor area above 200 square metres must also host return points. Major supermarkets show shelf prices without the deposit and add it at checkout.
F&B outlets can join the Return Right F&B Scheme, under which dine-in outlets collect containers back without charging the deposit; NEA offers one-time support of S$500 per food shop on application. Outlets that do not join sell drinks with the deposit included.
When is the deposit mark not needed?
Under regulation 8 of the Resource Sustainability (Beverage Container Return Scheme) Regulations 2026, read with section 23P(2)(b) of the Act, drinks do not need the mark and barcode if they are exported, supplied for consumption on board a conveyance entering or leaving Singapore, or sold at licensed airport or port duty-free shops (or certain duty-free online platforms) to departing travellers in tamper-evident bags. Each supplier in the chain must keep records proving the exclusion, such as export permits, shipping documents, delivery orders and written confirmation of the end use. NEA requires these to be kept for five years from the date of the document or from 1 April 2026, whichever is later.
Example: a drinks importer with a retail arm
Example: A hypothetical Singapore company imports canned and bottled juices, sells them to supermarkets and runs two of its own shops. Its 2025 turnover was S$14 million. It must register on NEA’s system and report its 2026 packaging (cans, plastic bottles, shrink wrap and cartons used for shipping) with a 3R plan between 1 January and 31 March 2027. As importer of covered drinks, it is also a producer under the beverage container scheme, so it registered its products with BCRS Ltd and has labelled every can and bottle since 1 October 2026. A batch shipped to a Malaysian customer goes out without the mark, and the company files the export permit and invoice to support that. The company is not a supermarket operator above S$100 million, so the carrier bag charge does not bind it, though it may choose to charge.
This is an illustration only. Apply the published criteria to your own facts.
Records checklist
- Calendar-year gross revenue for each company, two years back
- Purchase and import records showing packaging weights by material and form
- The current 3R plan and evidence of progress against its targets
- NEA registration and submission acknowledgements
- BCRS Ltd membership, product registrations and fee invoices
- Export permits, shipping documents and end-use confirmations for unmarked containers
- For large supermarket operators, bag counts, proceeds and published reports
If your company is planning projects to cut packaging waste, NEA’s 3R Fund may co-fund qualifying costs.
Frequently asked questions
Our turnover is S$9 million. Do we need to report packaging?
Not under the current threshold, which is turnover above S$10 million. NEA has said the criteria may be reviewed, so check each year, especially if revenue is growing.
Is turnover based on our financial year?
No. NEA uses calendar-year turnover, measured two years before the report is due.
Do small producers have to join the beverage container return scheme?
NEA says it is onboarding producers of all sizes, and the scheme operator’s board includes both large and small producers. If you import or manufacture covered drinks for supply in Singapore, assume you need to register and confirm your position with BCRS Ltd or NEA.
Does the 5-cent bag charge apply to our online store?
No. The mandatory charge applies only to obligated supermarket operators, and NEA excludes online orders, including click-and-collect.
Can old stock without the deposit mark still be sold?
The transition period for clearing unlabelled stock ended on 30 September 2026. From 1 October 2026, covered containers supplied in Singapore must carry the mark and barcode unless an exclusion applies.
Need help with packaging and sustainability compliance?
If your company needs calendar-year turnover figures, records for an NEA packaging report or a review of how deposits and bag charges are recorded in your books, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133. We handle bookkeeping, GST, annual filings and the company records behind these obligations, and can coordinate with your sustainability consultants. If NEA takes enforcement action, we can refer you to a firm on our panel of Singapore law firms.
The Raffles Corporate Services Editorial Team, Raffles Corporate Services