Global trade has become an everyday issue with immense effects on trade and the economy. Today’s global trade climate sees countries around the world engaged in trade negotiations aspiring to eliminate trade barriers. Customs tariffs and associated privileges are among the issues that most impact global trade flows and the import-export sector. Thailand has negotiated customs tariff privileges as part of its 14 free trade agreements (FTAs) with 18 countries, including six bilateral and eight regional agreements. These FTAs set forth criteria for member states to comply with and adopt into national law. To achieve customs privileges, one of the most important criteria is rules of origin, which indicate the originating country of imported or exported goods and the accompanying duty rates or privileges for reduction or exemption. Rules of Origin Under FTAs The rules of origin mapped out in FTAs allow for duty exemptions or rate reductions based on the determination of goods’ country of origin. This largely includes two main categories: Wholly obtained (WO) means the product was entirely produced in a single originating country and does not include any foreign (non-originating) content or manufacturing process. Product specific rules (PSR) are detailed criteria that define how each product’s origin is determined. PSR criteria that are often found in FTAs include “change in tariff classification” (determining origin based on sufficient transformation of materials), “regional value content” (requiring a minimum percentage of value to be added locally), and specific manufacturing or processing operations (mandating particular production steps occur in the originating country). These criteria also extend to cover other subordinated methods of verification, such as accumulation rules and de minimis rules, to provide more flexibility for the establishment of origins and tariff privileges under such FTAs. Compliance Challenges Despite attempts to promote international trade and eliminate trade barriers through the establishment of FTAs, importers and exporters

The Department of Trade under Myanmar’s Ministry of Commerce (MOC) issued a schedule of revised service fees for trade-related services, effective October 15, 2025. The revised fees are contained in Newsletter of Export/Import 6/2025, which supersedes the previous rates set out in 2018 and 2020. Service Fees The revised fees include the following: Annual fee for TradeNet 2.0, the MOC online platform for trade submissions: MMK 50,000 (approx. USD 23.81) Online service application fee: MMK 10,000 (approx. USD 4.76) Import or export license renewal (including for all imported goods exempt from the license fees): MMK 50,000 (approx. USD 23.81) for initial renewal (two months) MMK 30,000 (approx. USD 14.29) for second renewal (one month) Amendment of license information: MMK 10,000 (approx. USD 4.76) per amendment Return of export/import license: MMK 30,000 (approx. USD 14.29) Late fees for renewal/amendment of import or export license: MMK 5,000 (approx. USD 2.38) if within one month of expiry MMK 10,000 (approx. USD 4.76) if later than one month after expiry Submission Schedule License renewal applications submitted more than 14 days after the license expiration date will not be processed. Applications for license amendment must be submitted in advance of the relevant goods’ arrival at Myanmar ports or airports. For more information on this announcement, or on any aspect of import and export matters in Myanmar, please contact Tilleke & Gibbins at [email protected].

Myanmar’s National Committee for Setting the Minimum Wage has introduced another MMK 1,000 daily allowance for private-sector workers, bringing the total minimum daily wage to MMK 7,800 (approx. USD 3.72). Notification No. 1/2025 marks the third such increase in recent years as the government continues adjusting compensation across both public and private sectors. Although the notification was issued on October 14, 2025, it takes retroactive effect from October 1, 2025. Current Minimum Wage Structure In May 2018, the committee established a base minimum wage of MMK 4,800 (approximately USD 2.29) for an eight-hour workday (MMK 600 per hour), applying to all workers regardless of location or job type. The committee has subsequently announced additional daily allowances for private-sector workers: MMK 1,000 effective October 1, 2023, and another MMK 1,000 effective August 1, 2024. With the latest MMK 1,000 daily allowance from October 1, 2025, the total additional allowance reaches MMK 3,000, resulting in a new combined minimum daily wage of MMK 7,800. Alignment with Public Sector Increases The new allowance aligns with increases granted to government personnel. The Ministry of Finance and Revenue’s Notification No. 110/2025 previously granted monthly increases of MMK 30,000 to service and Tatmadaw personnel starting in October 2023 and August 2024. With the latest increase effective October 1, 2025, the total monthly allowance for these personnel now amounts to MMK 90,000. Daily wage employees in government departments received MMK 1,000 increases in the same periods, totaling MMK 3,000 in daily allowances—mirroring the private-sector adjustment. Key Implementation Details The latest announcement confirms several important aspects of the allowance structure: Employees are entitled to the base wage and additional allowances during their entitled leave and holidays, in accordance with the 1951 Leave and Holidays Act. The MMK 3,000 daily allowance is excluded from overtime calculations, which must be based solely on the base wage of MMK

The Indonesian Food and Drug Administration (BPOM) has introduced more stringent oversight of health supplements containing probiotics with new guidelines that require clinical trials for certain products and expanded documentation standards. BPOM Regulation No. 17 of 2025 replaces the previous 2021 regulation and establishes a comprehensive framework for evaluating probiotic strains used in health supplements. Assessment Requirements The new regulation expands the scope of assessment to include not only categorization and documentation but also technical procedures, strain classification, and clinical trial requirements. Unlike the previous regulation, which provided general guidance, the updated framework creates a comprehensive system for evaluating both registered probiotic strains and new or combined strains. Manufacturers must now submit supporting documentation covering strain identification and functional characterization, safety, efficacy, and product quality. The previous regulation required documentation only on safety, efficacy, and quality. Clinical Trials One of the most significant changes is the requirement for clinical trials conducted in Indonesia for applications that include benefit claims other than maintaining digestive health, or where there are modifications to benefit claims. The regulation specifies that phase 1 trials must demonstrate safety, while phase 2 trials must validate efficacy using statistically valid methods such as double-blind, randomized, placebo-controlled studies). In addition, phase 3 and phase 4 trials may be required, and postmarket surveillance data must be submitted. Technical Assessment Framework Annex 4, a newly introduced section, establishes technical procedures for assessing health supplements containing probiotics in Indonesia. This comprehensive framework outlines criteria for evaluating new probiotic strains, including strain identification, functional characterization, safety, efficacy, and product quality. The annex introduces a clear classification of claims for health supplement products containing probiotics: General claims(e.g., maintaining digestive health). Functional claims(e.g., normal biological function or activity in the body). Risk reduction claims(e.g., lowering disease risk). The regulation restricts use of the term “probiotic” to products containing live microorganisms with proven health benefits, using specific

On September 24, 2025, Thailand’s House of Representatives voted to approve two draft amendments to the Labor Protection Act in their first reading, aiming to enhance workers’ rights and quality of life through improved working conditions, expanded leave entitlements, and stronger antidiscrimination protections. Key provisions of the draft amendments are outlined below. Draft Bill on Workers’ Rights This draft bill focuses on improving working conditions, working hours, and annual leave entitlements. The key provisions include: Limiting normal working hours to no more than 40 hours per week, reduced from the current 48 hours per week. For hazardous work, as defined by ministerial regulations, the maximum working hours are set at 35 hours per week, reduced from the current 42 hours per week. Mandating at least 2 days off per week, with no more than 5 consecutive working days between rest days. This is an increase from the current requirement of at least 1 day off per week, with the interval between days off not exceeding 6 days. Providing annual leave entitlement of at least 10 working days after the completion of 120 consecutive working days, compared to the current entitlement of 6 days after 1 year of employment. Draft Bill on Workers’ Quality of Life This draft bill is designed to enhance workers’ quality of life and promote equality and nondiscrimination in the workplace. The new additions to the Labor Protection Act include: Menstrual leave for female employees: Up to 3 days per month, which shall not be counted as sick leave or deducted from other statutory leave entitlements. Family caregiving leave: Employees are entitled to up to 15 working days per year to care for close family members or loved ones. For absences of 5 or more days, employers may request supporting documents such as a medical certificate or death certificate. Workplace breastfeeding rights: Employers are required to provide

On September 26, 2025, the Contract Committee under Thailand’s Consumer Protection Board issued a regulation that aims to standardize contracts and enhance consumer protection within the beauty and wellness industry. The Notification on Prescribing the Beauty Service Business as a Contract-Controlled Business B.E. 2568 (2025), which takes effect on January 24, 2026, requires business operators to use a prescribed standard contract in Thai and adhere to strict mandatory provisions and prohibitions. These regulations apply to operators across all in-person and online service channels, including via digital platforms. “Beauty services business” is defined as the provision of services under an agreement allowing consumers to receive a series of treatments, either over a set number of sessions or within a set period. This includes massage, spa, other methods for cleanliness, beauty, or care of facial or body skin, and weight control and body shaping—including services offered electronically. The law excludes surgery, liposuction, and medical treatments performed by licensed practitioners. The notification establishes the following key requirements: Mandatory contract and formatting. All contracts with consumers must use the standard contract form, in Thai, with clear, readable text (minimum font size of 2 millimeters, no more than 11 characters per inch), and include all essential terms from the annexed form. Contract execution. Contracts must be made in duplicate, with one copy given to the consumer at signing. For agreements concluded through electronic channels, the process must comply with the Electronic Transactions Act and use the same required terms. Digital platforms. Business operators who provide services facilitated through a digital platform as an intermediary are ultimately responsible for ensuring the consumer receives a compliant contract. Prohibited clauses. The law prohibits clauses that limit or exclude liability for damages to life, body, health, mind, or property resulting from breach of contract or a wrongful act; bind consumers to business operators’ rules

In Thailand, the rise in online intellectual property infringement has prompted authorities to strengthen enforcement efforts, including the use of website-blocking orders under Section 20(3) of the Computer Crime Act B.E. 2560 (2017) (CCA). This provision authorizes the Ministry of Digital Economy and Society (MDES), with court approval, to block or remove computer data that constitutes a criminal offence under IP law. Since its implementation, the procedure has undergone several developments, which is an encouraging sign of progress. Website-blocking procedure In practice, website-blocking orders under Section 20(3) of the CCA are primarily used for copyright and trademark infringement. While such orders are legally applicable to patent infringement, their use remains challenging due to the difficulty of proving infringement through administrative procedures. The website-blocking procedure begins when an IP owner identifies online infringing content. For copyright infringement, which is considered a compoundable offence, the IP owner is required to first file a police report with the specialized police unit known as the Economic Crime Suppression Division (ECD) prior to filing the website-blocking application with the Department of Intellectual Property (DIP). For trademark infringement cases, the application can be filed directly with the DIP without a prior police report. The DIP reviews the evidence and, if infringement is confirmed, forwards it to the MDES for further consideration. If the case is deemed valid, the MDES requests a court order to block the infringing website. Once granted, the MDES notifies the internet service providers (ISPs) to block access to the specified website. Website blocking procedure in Thailand Recent advancements in website-blocking actions Seamless collaboration through digital integration. Thailand has made significant progress in digitizing its website-blocking procedures to improve efficiency and transparency. At present, all website-blocking applications and supporting evidence must be submitted in electronic format. These systems have significantly reduced processing times while enhancing transparency and traceability, resulting

In September 2025, Thailand’s Securities and Exchange Commission (SEC) accused a company listed on the Stock Exchange of Thailand (SET), including its current and former directors, of concealing material information in connection with its filing registration and draft prospectus. This recent enforcement action demonstrates the serious consequences of making false statements or appearing to conceal material information in IPO filings and ongoing disclosures. In addition to being subject to criminal penalties, such actions can impact the eligibility of directors and executives to serve and may cause lasting reputational damage. Key Legal Risks The Securities and Exchange Act B.E. 2535 (1992) (as amended) imposes strict liability for making false statements or concealing material information in IPO registration statements and draft prospectuses. In such cases, investors can claim for damages, and there are also criminal penalties, including imprisonment for up to five years and substantial fines, may apply to the company, its directors, and responsible officers. However, misstatements or omissions in IPO filings do not, by themselves, disqualify directors or executives from holding office, whether arising from an SEC accusation or even a final court judgment. In contrast, for ongoing disclosures after listing, such as financial statements, annual reports, and meeting notices, false or misleading statements or concealment of material information can result in not only criminal liability but also immediate disqualification of directors and executives. If the SEC accuses a listed company or its directors or executives of such misstatements or omissions, those directors or executives are immediately disqualified from their positions, even before a final court judgment. Director and Executive Qualifications Directors and executives must meet the SEC’s specified standards of trustworthiness, as set out in the relevant rules. The SEC clearly defines characteristics that are considered to demonstrate a lack of trustworthiness. For ongoing disclosures, being involved in making false statements or concealing