On 6 July 2026, Myanmar’s Ministry of Finance and Revenue issued a new notification on Export and Import Compliance Procedures (the “Procedures”), replacing a series of notifications that had been in place since 2017. The Procedures introduce the compliance regime and introduce more detailed, commodity-specific penalties, clearer fine bands, and stricter timing consequences for import and export violations. Business moves goods in or out of Myanmar should review current and in-transit shipments now, as several changes create direct financial and confiscation risk.
At a Glance
- A unified, detailed penalty schedule: Four earlier notifications (2017, 2023, 2025, and March 2026) are repealed and replaced by a single consolidated framework with specific fine rates for specific violations.
- Commodity-specific penalties for unlicensed imports: Importing without a licence, permit or declaration now carries consequences based on the type of goods, ranging from fines of 1×, 2× or 3× assessable value to outright confiscation for certain categories.
- Graduated timing penalties: Goods arriving before licence issuance or after licence expiry now fall within express day-by-day penalty bands, with materially higher exposure once the relevant thresholds are exceeded.
- Immediate action required: Importers and exporters should review licences, shipment timing, commodity classification, product specifications, and supporting documents before customs clearance.
Key Watch Points for Exporters
Annex Schedule (1) introduces a tiered fine structure for export discrepancies. Fines range depending on the nature and impact of the discrepancy, from minor document errors at the lower end to type or category mismatches and excess-quantity exports at the higher end. Three points deserve particular attention:
- Country of Origin mismatches: CMP goods mislabelled as anything other than “Made in Myanmar” attract a lower fine than general goods with an origin mismatch (which also require mandatory rectification before re-export). Exporters of CMP goods should ensure their labelling is correct to benefit from the lower tier.
- Excess-quantity exports: Exporting in excess of the licensed quantity carries a fine, after which a revised licence must be obtained before the goods may be exported.
- Exporting without documentation: Exporting without any documentation at all results in confiscation of the entire shipment. This is the severest outcome under the export schedule and leaves no room for a redemption payment.
Key Watch Points for Importers
The import side carries the most significant changes. Four areas stand out:
- Missing brand name or Country of Origin: Where goods arrive with no brand name or Country of Origin information at all, vehicles and machinery face confiscation and general goods face a monetary fine. Both penalties are waived if the information is verifiable from supporting documents.
- Vehicle/machinery manufacturing year violations: Fines are graduated by the nature of the mismatch. A model year newer than Ministry of Commerce guidelines or a production year higher than the declared invoice age each attracts a fine. A model year older than guidelines attracts a lower fine. A year that falls significantly below the permitted cut-off results in confiscation.
- Brand and trademark mismatches: A main brand or trademark mismatch (for example, declaring Toyota but importing Nissan) carries a fine for vehicles and for general goods. A sub-brand mismatch (for example, a Toyota Corolla declared but a Toyota Belta imported) carries a fine for vehicles. EV battery capacity or motor power mismatches are treated separately and carry a monetary fine, with a tolerance exemption for variations within +/- 3%.
- Condition misrepresentation: Declaring used or reconditioned goods as brand new results in confiscation for vehicles and machinery, and a monetary fine for general goods. The reverse (declaring new goods as used) carries no fine, but duties are reassessed upward to reflect actual market value.
Timing Violations: New Explicit Penalty Bands
This is where many businesses will feel the sharpest practical change. Timing violations previously lacked a clear, graduated scale. The Procedures now set out an explicit day-by-day penalty band for two common scenarios:
| Scenario | Penalty-Free Window | Risk if You Exceed It |
|---|---|---|
| Goods arrive before the Import Licence/Permit is issued | Up to 15 days | Graduated fines, rising to full confiscation at 61+ days |
| Goods arrive after the Import Licence/Permit has expired | Up to 7 days | Graduated fines; rising to full confiscation at 31+ days |
Exceptions: CMP goods are exempt for up to 50 days (with VPA clearance). Aircraft spare parts with VPA are fully exempt. Post-arrival licence amendments are only permitted for clerical errors with no duty impact.
Unlicensed Imports: Commodity-Specific Consequences
Where goods arrive without any licence, permit, or declaration, the penalty depends on the type of goods. Essential goods (such as pharmaceuticals, seeds, and agricultural machinery) attract a monetary fine. Higher-risk commodities including fuels, construction materials, and telecoms hardware attract a higher fine, and premium consumer electronics attract the highest fine tier. Commercial vehicles, trailers, and certain other categories face outright confiscation, as do sensitive goods such as cigarettes, vapes, beer, and playing cards.
Dispute Resolution
Where goods face confiscation, an application to pay a redemption fine may be made to the Customs Department except for prohibited goods. Formal appeals lie under the Sea Customs Act or the Tax Appellate Tribunal Law within the prescribed time limits.
Action for Businesses
- Audit in-transit shipments against the new timing bands identify which penalty tier applies and act before customs clearance.
- Confirm your commodity category for unlicensed import exposure confiscation-category goods have no financial fix after arrival.
- Verify vehicle and EV specs including manufacturing year, VIN, battery capacity, and condition must align precisely with your import licence.
- Check your supporting documents including brand name and Country of Origin penalties are waived if verifiable from invoices and certificates of origin.
- Do not amend licences post-arrival unless it is a clerical error with no duty impact.
We are happy to assist with licence compliance reviews, penalty assessments, or customs appeals. Please reach out to your usual contact at our firm.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
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