Statute Details
- Title: Environmental Public Health (Part IV Fees) Regulations 2019
- Act/Instrument Code: EPHA1987-S275-2019
- Type: Subsidiary Legislation (SL)
- Authorising Act: Environmental Public Health Act (Chapter 95)
- Enacting Power: Section 42A of the Environmental Public Health Act
- Citation: No. S 275
- Commencement: 1 April 2019
- Status: Current version as at 27 Mar 2026 (per the provided extract)
- Key Provisions (from extract): Section 2 (licence fees); Section 3 (other fees); Section 4 (revocation)
- Schedule: Fees (split into Part 1: licence fees; Part 2: other fees)
What Is This Legislation About?
The Environmental Public Health (Part IV Fees) Regulations 2019 (“Fees Regulations”) is a Singapore subsidiary legislation instrument that sets out the fee framework for matters falling under Part IV of the Environmental Public Health Act (Chapter 95) (“EPHA”). In practical terms, it tells regulated persons what they must pay—either for licences or for other administrative/ regulatory matters—when dealing with the Singapore Food Agency (“SFA”) in relation to Part IV requirements.
Part IV of the EPHA generally concerns regulatory controls over environmental public health matters that fall within SFA’s remit. The Fees Regulations do not themselves create substantive regulatory duties (such as licensing conditions or prohibited conduct). Instead, they focus on the “price” of regulatory engagement: the fees payable to SFA for licences and related matters specified in the EPHA’s Part IV framework.
From a legal practitioner’s perspective, the Fees Regulations are important because they translate statutory regulation into enforceable administrative costs. They also affect compliance planning, budgeting, and the timing of applications and renewals. Where fees are payable, failure to pay can become a procedural barrier to obtaining or maintaining regulatory approvals.
What Are the Key Provisions?
Section 1 (Citation and commencement) provides the formal identity of the instrument and its effective date. The Regulations are cited as the Environmental Public Health (Part IV Fees) Regulations 2019 and come into operation on 1 April 2019. For practitioners, this matters when determining which fee schedule applies to applications made before and after commencement, and when assessing whether a fee demand is based on the correct version.
Section 2 (Licence fees) is the core provision for licensing-related charges. It states that the fees specified in the second column of Part 1 of the Schedule are payable to the Singapore Food Agency “in respect of licences under Part IV of the Act” for the matters listed in the first column of Part 1 of the Schedule. The structure is a classic fee-table approach: the Schedule identifies the licence category or matter; the second column provides the corresponding fee amount.
Although the extract provided does not reproduce the Schedule’s fee amounts, the legal mechanism is clear. Practitioners should treat the Schedule as integral to the Regulations. When advising clients, the correct fee depends on (i) the licence type or matter under Part IV, and (ii) the fee amount in the Schedule’s corresponding row. This is particularly relevant for multi-activity operators or those applying for licences that may be categorised differently depending on the nature of the regulated activity.
Section 3 (Other fees) addresses fees that are not “licences” per se but are still payable to SFA in connection with Part IV matters. It provides that the fees specified in the second column of Part 2 of the Schedule are payable to SFA “in respect of the matters in Part IV of the Act” specified opposite in the first column. In other words, Part 2 of the Schedule captures administrative charges that may arise during the regulatory lifecycle—such as processing, approvals, or other specified regulatory interactions—depending on how Part IV is operationalised.
For counsel, the distinction between Sections 2 and 3 is not merely semantic. Licence fees may be recurring (e.g., renewal) or tied to issuance, while “other fees” may be triggered by discrete events (e.g., amendments, submissions, or other specified procedural steps). In disputes or compliance reviews, it is often necessary to identify whether a charge is properly characterised as a licence fee or an “other fee,” because that can affect the applicable statutory basis, timing, and procedural expectations.
Section 4 (Revocation) provides that the Environmental Public Health (Licence Fees) Regulations (Rg 4) are revoked. This is a transitional and legal continuity provision. It indicates that the 2019 Fees Regulations replace an earlier fee instrument. Practitioners should therefore consider whether any applications, renewals, or fee disputes relate to periods before 1 April 2019, and whether the revoked Regulations govern those earlier periods. Revocation also helps avoid double charging or confusion about which fee schedule applies.
How Is This Legislation Structured?
The Fees Regulations are structured in a short, functional format typical of fee-making subsidiary legislation. The instrument contains:
(a) Enacting formula and short title establishing that the Minister makes the Regulations under the EPHA’s delegated power.
(b) Sections 1 to 4 covering: commencement (Section 1), licence fees (Section 2), other fees (Section 3), and revocation of the earlier fee regulations (Section 4).
(c) The Schedule which is the substantive fee table. The Schedule is divided into Part 1 (licence fees) and Part 2 (other fees). Each part uses a two-column format: the first column identifies the relevant licence category or matter; the second column sets the fee amount payable to SFA.
Because the Schedule is where the amounts and categories live, practitioners should always consult the Schedule directly rather than relying on the short sections. In fee-related compliance work, the Schedule is effectively the “operative” content.
Who Does This Legislation Apply To?
The Fees Regulations apply to persons who seek or hold licences under Part IV of the Environmental Public Health Act, and to persons who must pay fees for other specified matters under Part IV. While the extract does not list the regulated parties, the operative language makes the scope functional: it is tied to the licensing and regulatory processes under Part IV and the fee categories in the Schedule.
In practice, this typically includes regulated businesses and operators whose activities fall within Part IV’s environmental public health regulatory regime, and who interact with SFA for licensing or administrative approvals. The Regulations are also relevant to legal advisers, consultants, and compliance officers who manage applications, renewals, and submissions where fees are a condition of processing.
Why Is This Legislation Important?
Although the Fees Regulations are brief, they have real operational significance. First, they provide the legal basis for SFA to collect fees for Part IV licensing and related regulatory matters. Without a properly made fee regulation, fee collection would risk legal challenge as lacking statutory authority or being inconsistent with the delegated fee-making framework.
Second, the Regulations affect compliance planning and cost forecasting. Businesses that require licences under Part IV must budget for the relevant licence fees in Part 1 of the Schedule. They may also need to anticipate “other fees” in Part 2 for administrative steps that arise during the regulatory lifecycle. For practitioners advising clients on timelines, application strategy, or corporate restructuring (e.g., changes in ownership or scope of operations), understanding the fee triggers can be critical.
Third, the revocation in Section 4 signals that the fee regime changed as of 1 April 2019. This can matter in disputes about whether a particular fee was correctly assessed. For example, if a client applied for a licence or submitted a request around the commencement date, counsel may need to determine which fee schedule applied and whether SFA’s assessment aligns with the correct Schedule version.
Finally, the Regulations illustrate how Singapore’s regulatory system uses subsidiary legislation to implement detailed administrative requirements. Even where substantive regulatory obligations are contained in the EPHA itself, fee collection is often implemented through separate fee regulations. This separation supports administrative flexibility and allows fee schedules to be updated without amending the primary Act.
Related Legislation
- Environmental Public Health Act (Chapter 95) — in particular, Part IV and the delegated fee-making power in section 42A.
- Environmental Public Health (Licence Fees) Regulations (Rg 4) — revoked by Section 4 of the Fees Regulations.
Source Documents
This article provides an overview of the Environmental Public Health (Part IV Fees) Regulations 2019 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.