Trade and compliance guide
Free trade agreements, tariff codes, export controls and data rules that apply when robot components move between China, Malaysia and the rest of the world.
Last updated 8 October 2026 · Methodology
What changed
Key rules for companies in Malaysia
Trade rules for robots and their components have changed quickly since 2025.
- US
FCC Covered List: foreign-produced advanced robotic devices
In forceMarket access · 28 Jul 2026
New foreign-made humanoids, quadrupeds and autonomous mobile robots over 4.4 lb with sensors, connectivity and autonomy software need a conditional approval before FCC authorisation. Applies to all countries, including Malaysia. Fixed industrial and medical robots are excluded; 65% US content (70% by 2029) is exempt.
What it means: Malaysia is not a route to the US market for advanced mobile robots.
- US
US Section 301 tariffs on Malaysia and other economies
In forceTariff · 24 Jul 2026
10% for Malaysia, Indonesia and Cambodia, and 12.5% for other economies investigated, including Thailand, Vietnam, the Philippines, Singapore and China. Section 232 goods are excluded.
- ASEAN
ASEAN Digital Economy Framework Agreement
Signed, not in forceTrade agreement · May 2026Watch: 15 Nov 2026
Negotiations concluded in May 2026; signing targeted for the 49th ASEAN Summit in November 2026.
Signing targeted at the November 2026 ASEAN Summit.
- US
US reciprocal (IEEPA) tariffs struck down
EndedTariff · 20 Feb 2026
The US Supreme Court held that IEEPA does not authorise tariffs, voiding the 2025 reciprocal tariffs. Section 232 and China Section 301 tariffs remained.
- CN
Expanded rare-earth and battery controls (suspended)
SuspendedExport control · 7 Nov 2025Watch: 10 Nov 2026
A package announced on 9 October 2025 covering more rare earths, magnet-making equipment, lithium battery items and extraterritorial rules was suspended by Announcement No. 70 until 10 November 2026.
The suspension expires on 10 November 2026. The controls may return.
- ASEAN
ASEAN–China FTA 3.0 upgrade
Signed, not in forceTrade agreement · 28 Oct 2025Watch: 15 Nov 2026
Signed in Kuala Lumpur, adding the digital economy, green economy, supply-chain connectivity, standards and customs facilitation. Enters into force 60 days after all parties ratify. Existing ACFTA origin rule: 40% regional value content or change of tariff heading, with cumulation.
Entry into force targeted around the November 2026 ASEAN–China Summit.
- ASEAN
ATIGA upgrade (Second Protocol)
Signed, not in forceTrade agreement · 26 Oct 2025
Upgrade to ASEAN’s internal goods agreement adding seven chapters and liberalising rules of origin. Enters into force 18 months after all members sign.
- US
US–Malaysia Agreement on Reciprocal Trade
ContestedTrade agreement · 26 Oct 2025
Signed in October 2025 with a 19% tariff and 1,711 lines at zero, plus Malaysian commitments on export controls and critical minerals. Its status has been contested since the February 2026 Supreme Court ruling.
- US
US Section 232 investigation into robotics and industrial machinery
Under investigationTariff · 2 Sept 2025
National security investigation into imports of robotics and industrial machinery. No resulting tariff had been announced at the time of writing.
- CN
Battery technology export restrictions
In forceExport control · 15 Jul 2025
LFP and LMFP cathode technology and lithium extraction technology added to China’s restricted technology export catalogue.
- MY
Strategic Trade Permit for US-origin AI chips
In forceExport control · 14 Jul 2025
Exports, transshipment and transit of high-performance US-origin AI chips require a Strategic Trade Permit under the Strategic Trade Act 2010.
What it means: Robot makers shipping compute modules with US AI chips through Malaysia need permits.
- CN
Rare-earth export licences (MOFCOM Announcement No. 18)
In forceExport control · 4 Apr 2025
Export licences required for seven medium and heavy rare earths (Sm, Gd, Tb, Dy, Lu, Sc, Y) and magnets containing them, the inputs to robot joint motors. Dysprosium and terbium exports fell about 60% year on year in the first half of 2026.
What it means: Motor and actuator makers outside China face longer lead times for magnets. Tesla said Optimus actuators were affected.
- ASEAN
RCEP
In forceTrade agreement · 1 Jan 2022
Covers ASEAN, China, Japan, Korea, Australia and New Zealand. Usually 40% regional value content, a 10% de minimis for non-originating materials, and cumulation of originating materials.
Trade agreements
Free trade agreements and rules of origin
Preferential rates depend on meeting rules of origin. Keep supplier declarations and cost records for every shipment.
| Agreement | Status | Typical origin rule | Why it matters |
|---|---|---|---|
| ASEAN–China FTA (ACFTA) | In force. Version 3.0 signed October 2025, pending entry into force. | 40% regional value content, or a change of tariff heading for listed chapters. ASEAN–China cumulation. | Main channel for Chinese components into Malaysia, and for ASEAN-made goods into China. |
| RCEP | In force since 1 January 2022. | Usually 40% regional value content. 10% de minimis for non-originating materials. Cumulation of originating materials. | Covers China, Japan, Korea, Australia, New Zealand and ASEAN, so parts from all of them can count toward origin. |
| ATIGA | In force. Second upgrade protocol signed October 2025. | 40% regional value content or change of tariff heading. | Moving parts and robots between ASEAN countries, for example Thai actuators into Malaysian assembly. |
Tariff codes
HS codes for robots and key components
Humanoid and mobile robots have no dedicated HS code. Request an advance ruling from the Royal Malaysian Customs Department (JKDM) for new products.
| HS code | Description | Robot use | Indicative Malaysian MFN duty |
|---|---|---|---|
| 8479.50 | Industrial robots, not elsewhere specified | Complete industrial robots | 0% |
| 8483.40 | Gears and gearing; ball or roller screws; gear boxes and other speed changers | Harmonic and planetary reducers, roller screws | 5% |
| 8501 | Electric motors and generators | Joint motors | 0% for most small DC motors; up to 15% for some AC motors |
| 8505 | Electromagnets; permanent magnets | Rare-earth magnets in motors | 0% |
| 8507 | Electric storage batteries (8507.60 lithium-ion) | Robot battery packs | Varies by line, up to 20% |
| 8542 | Electronic integrated circuits | Processors, AI chips, controllers | Check ezHS |
| 9031 | Measuring or checking instruments, not elsewhere specified | Some force and torque sensors | Check ezHS |
Data protection
Robots with cameras collect personal data
- 2025
PDPA amendments: data protection officers and breach notification
In forceData protection · 1 Jun 2025
Data protection officers became mandatory, along with data breach notification and data portability rights.
- 2025
PDPA amendments: biometric data and cross-border transfers
In forceData protection · 1 Apr 2025
Biometric data became sensitive personal data, data processors gained direct security duties, maximum penalties rose to RM1 million and three years, and the cross-border transfer whitelist was replaced.
What it means: Robots with cameras that recognise people, or send data to overseas clouds, must meet these rules.
Checklist
Before you import or export
Classify
Confirm HS codes for each product and component, with an advance ruling for new items.
Qualify
Check which FTA gives the best rate and whether your bill of materials meets its origin rule.
Screen
Check export-control status in China, Malaysia and the destination country, especially for magnets, chips and batteries.
Comply
Plan for destination rules such as US FCC authorisation and Malaysian data protection duties.
Not legal or trade advice
This guide is a general overview based on public sources as of the date shown. Confirm current requirements with JKDM, MITI, the Strategic Trade Secretariat and qualified advisers.
Sources
- Skadden, FCC Covered List update. skadden.com
- K&L Gates, five things to know. klgates.com
- USTR, Section 301 forced labor actions. ustr.gov
- Rahmat Lim & Partners, DEFA concluded. rahmatlim.com
- DLA Piper, Supreme Court IEEPA ruling. dlapiper.com
- CIRS, China suspends export controls. cirs-group.com
- Pillsbury, China suspends export controls. pillsburylaw.com
- Vietnam MOIT, ACFTA 3.0 signed. moit.gov.vn
- Enterprise Singapore, ACFTA rules of origin. enterprisesg.gov.sg
- The Nation, ACFTA 3.0 ratification. nationthailand.com
- JETRO, ATIGA upgrade. jetro.go.jp
- US Mission to ASEAN, joint statement. asean.usmission.gov
- Fulcrum, calm before another storm. fulcrum.sg
- Federal Register, Section 232 robotics investigation. federalregister.gov
- Shanghai Municipal Government, export catalogue update. english.shanghai.gov.cn
- MITI, Malaysia regulates trade of US AI chips. miti.gov.my
- DFDL, implementation of the PDPA amendments. dfdl.com
- MOFCOM Announcement No. 18. english.mofcom.gov.cn
- SMM, rare earth export review H1 2026. news.metal.com
- TrendForce, Tesla and rare-earth curbs. trendforce.com
- Mayer Brown, key amendments to Malaysia’s PDPA. mayerbrown.com
- New Zealand Tariff Finder, RCEP. tariff-finder.govt.nz