Can Products, Machinery, and Production Processes Be Changed After BOI Approval?
Emory
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2026-10-15 11:47:08
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When applying for BOI promotion, companies typically submit their planned products, production processes, machinery, and production capacity based on their investment plan at that time.
However, once the project moves into the implementation stage, circumstances often change.
Products may need to be updated, machinery models replaced, production processes optimized, or even certain manufacturing stages outsourced.
This raises an important question:
Can these changes still be made after BOI approval has already been granted?
The answer is yes—in certain cases.
However, if the proposed changes affect the essential elements of the BOI-approved project, the company may first need to apply for a Project Amendment and obtain BOI approval before implementing the new plan.
The key principle is:
Do not change first and explain later. Assess first, then amend if necessary.
Before making any changes to a BOI-promoted project, companies should review the following five key areas.
Does the Revised Plan Still Match the Original BOI Approval?
The first step is to compare the proposed changes with the company's existing Promotion Certificate and the originally approved project details.
For example:
Changing from Product A to Product B
Adopting a different manufacturing process
Making significant changes to the originally approved machinery plan
The first question should always be:
Does the revised plan still fall within the scope of the original BOI approval?
If the changes go beyond the approved project scope, they should not simply be treated as normal business adjustments. Instead, the company should determine whether a BOI Project Amendment is required.
Will the Changes Affect the Activity, Product, Capacity, or Project Conditions?
The second consideration is whether the proposed changes affect the project's key elements.
These include:
Activity – BOI-promoted business activity
Product – Product type
Capacity – Production capacity
Value Added – Value-added requirements
Project Conditions – Conditions specified in the BOI approval
For example, routine equipment replacement is very different from equipment changes that alter production capacity, manufacturing methods, or the products themselves.
Therefore, determining whether a BOI amendment is required depends not only on what has changed, but also on how those changes affect the approved project.
Has the Production Process Changed?
Another critical factor is the Process Flow.
Companies should determine whether the changes involve:
Adding production steps
Removing production steps
Rearranging manufacturing processes
Changing core production methods
Outsourcing manufacturing processes that were previously performed in-house
Particular attention should be paid when production shifts from in-house manufacturing to outsourced production.
This is more than simply changing a procurement method.
If outsourced activities involve core manufacturing processes approved under the BOI project, the changes may affect the project's approved production process and overall eligibility.
Whenever the production process changes, companies should compare the original Process Flow with the revised Process Flow before deciding whether a Project Amendment is necessary.
The fourth area to review is the project's Main Machinery and Project Location.
Examples include:
Replacing major machinery with different models
Adding or removing key production equipment
Significant changes in machinery specifications or production capacity
Replacing core manufacturing equipment
Relocating the project site
These changes should not be evaluated simply as purchasing new equipment.
Major machinery is directly linked to:
Therefore, companies should determine whether the changes only affect the Machine List or whether they have broader implications for the entire BOI project.
Besides the Project Itself, What Other BOI Records Need to Be Updated?
One issue that companies often overlook is that completing a project amendment does not necessarily mean updating only one document.
Depending on the nature of the changes, companies may also need to update:
BOI Project Amendment records
eMT Machine List
BOI online system information
Other documents related to the project's approval conditions
In other words, a single operational change may require updates across multiple BOI management systems.
If only part of the information is updated while other records remain unchanged, discrepancies may arise between the company's actual operations and the BOI records.
Prepare a Before / After Comparison Before Making Changes
Before implementing any changes to a BOI-promoted project, companies should avoid proceeding immediately with the revised plan.
Instead, prepare a complete Before / After Comparison, including:
Original Product → New Product
Original Process Flow → New Process Flow
Original Machine List → New Machine List
Original Capacity → New Capacity
Original Project Conditions → Revised Project Conditions
This comparison helps determine:
What exactly has changed?
Do the changes affect the core elements of the BOI project?
Is it necessary to amend the BOI Project, update the eMT Machine List, or modify other BOI records?
Which approvals should be obtained before implementing the changes?
For BOI-promoted companies, project adjustments are not unusual. The real risk is allowing actual operations to change while the BOI approval records remain unchanged.
TMA GROUP can assist companies in preparing a comprehensive Before / After Comparison, reviewing the proposed changes against the original BOI approval, identifying the required amendments, and supporting the preparation of BOI Project Amendments, Machine List updates, and related procedures.
If your company is planning to change products, replace machinery, modify production processes, adjust production capacity, or outsource part of the manufacturing process, it is advisable to first determine what BOI procedures are required before implementing the changes.
