Why Mobility Scooters should be Regulated as Medical Devices

To:
The Honourable Ong Ye Kung, Minister for Health
The Honourable Jeffrey Siow, Acting Minister for Transport
The Honourable Lawrence Wong, Prime Minister and Minister for Finance

Dear Ministers,

Re: An open letter regarding the regulation of mobility scooters in Singapore

I am writing this open letter to the public and to you on an issue that requires a coordinated, cross-ministerial effort: the regulation of mobility scooters. The proposed solution falls under the purview of the Ministry of Health, the Ministry of Transport, and Singapore Customs, and I hope this letter will encourage the necessary collaboration.

In many developed countries, such as the USA and across Europe, mobility scooters are regulated as medical devices. Yet, for some reason, they are not currently classified as such in Singapore. This allows these devices to be brought into the country without the importer holding an active Importer’s Licence from the Health Sciences Authority (HSA).

This regulatory gap is a significant contributing factor to personal mobility aid (PMA) abuse. It has led to a proliferation of illegal mobility scooters that do not comply with the new regulations laid out by the Land Transport Authority (LTA). Many of these devices are supplied by micro-businesses in Singapore as well as online sellers located overseas.

The Government has crafted new regulations pertaining to the usage of PMAs, set to commence in 2026. While these proposals are excellent, enforcement will be difficult and resource-intensive if the number of PMA suppliers is not controlled, especially where many are foreign sellers.

A simple adjustment would make the policing of mobility scooter sellers much easier. I am of the firm opinion that mobility scooters should be classified as medical devices. This will achieve two things:

1. Raise the barrier to entry for local suppliers.
   An Importer’s Licence from HSA costs more than S$1,000 a year to maintain. This would reduce the number of suppliers the Government needs to police, as only serious and legitimate businesses would be able to afford and maintain the licence.
   
   
2. Give greater enforcement power to Singapore Customs.
   If mobility scooters are designated medical devices, they become controlled goods. Singapore Customs can refuse clearance and detain shipments that lack the required HSA importer’s licence and approvals, and HSA may take enforcement action, including seizure, under the Health Products Act. This makes overseas sellers think twice about trying to sell mobility scooters into Singapore, a major source of illegal and unsafe devices that are currently beyond effective control.

I see no reason why mobility scooters should be exempt from being classified as medical devices. Based on HSA’s definition*, if a product is intended for the alleviation of, or compensation for, an injury, it is a medical device. Wheelchairs are specifically provided as an example.

Perhaps it was not clear in previous years whether mobility scooters were meant for people with walking disabilities. But with the Government’s intention now clear, that only people with certified medical needs or walking disabilities will be allowed to use PMAs, this is no longer a grey area.

Since mobility scooters will only be allowed for such users, by definition under HSA’s guidance, mobility scooters should be considered Class A medical devices, alongside electric wheelchairs and manual wheelchairs.

Major wheelchair importers already voluntarily notify HSA that their mobility scooters are Class A medical devices along with their motorised wheelchairs. Why not make this mandatory across the board?

As this involves multiple agencies, namely LTA, HSA and Singapore Customs, I hope a multi-agency task force will be formed to study this proposal.

Thank you for your attention to this matter.

Yours sincerely,

Warren Chew
Founder, ELFIGO Mobility

* Source: HSA — Is it a medical device?