Two decades on, the US-Singapore Free Trade Agreement (USSFTA) has proven to be more than a bilateral deal. It was Washington’s first FTA with an Asia-Pacific partner and remains its only one with an ASEAN member. At the time, leaders of both countries pitched it as an anchor for US presence in Asia and a foundation for future rulemaking.

ACI’s latest study shows that these ambitions were not misplaced. The USSFTA introduced provisions, specifically those related to competition policy, government procurement, and e-commerce facilitation, that have since diffused into subsequent agreements.

Intercontinental agreements like the USSFTA facilitate a cross-pollination effect where provisions are more likely to diffuse successfully across regions. Provisions introduced in an agreement involving countries from different regions reflect consensus among diverse country partners. This sends a strong signal about the relevance and acceptability of the provisions.

Over time, USSFTA clauses showed up in both bilateral trade deals and also mega-regional agreements including the Comprehensive and Progressive Agreement for the Trans-Pacific Partnership (CPTPP) and the Regional Comprehensive Economic Partnership (RCEP), often nearly word-for-word.

Competition policy offers the clearest example. The USSFTA not only required both sides to legislate competition laws, establish enforcement authorities, and guarantee due process; it also required government enterprises and designated monopolies to operate on commercial terms. For Singapore, this meant enacting reforms that ensured government‑linked companies operated on a non-discriminatory basis. These provisions were echoed in later US bilateral trade agreements and mega-regional agreements, in particular, the RCEP.

Government procurement shows a somewhat different trajectory, with only modest uptake of related provisions in subsequent agreements. Here the USSFTA went well beyond the WTO baseline enshrined in the Government Procurement Agreement, halving contract thresholds and expanding coverage to digital goods and build-operate-transfer projects. American and Singaporean firms gained wider access to each other’s government procurement markets, while the clauses themselves have been replicated in US agreements that followed.

As for the mega-regionals, while the CPTPP has incorporated a range of government procurement provisions, the uptake in the RCEP is much more modest with only the inclusion of obligations for public notices and further cooperation. This is reflective of the existing state of play with regards to the uptake of disciplines on government procurements in international trade agreements, where developing countries have been reluctant to accede to the WTO GPA. Currently, only 49 WTO members participate in the WTO GPA.

The digital economy is where the USSFTA’s impact has been most enduring. By offering some of the first definitions for key terms in digital trade, and extending duty-free status and non-discriminatory obligations to digital products, the USSFTA introduced a set of provisions that today form the foundation of e-commerce commitments. Newer FTAs have expanded e-commerce provisions into areas such as data privacy, cybersecurity, and cross-border data flows.

In conclusion, the spread of provisions from the USSFTA highlights the cross-pollination effect of intercontinental agreements in the diffusion of global trade rules. This represents an important dynamic through which provisions are adopted and integrated into other trade agreements, even without the participation of the innovating country or the “rule-maker”. This suggests that embedding specific innovations in smaller or bilateral trade agreements serves as a strategy to shape global trade rules or achieve regulatory harmonisation. The findings of this study sheds light on a key mechanism through which global trade rules evolve.

Researchers: LEE, Jesslene, TAN, Kway Guan