Export compliance checklist

1. DGFT & Registration Compliance (Before You Ship)

The Directorate General of Foreign Trade (DGFT) governs all export-import policies and licenses through the Foreign Trade Policy (FTP). Getting the groundwork right is paramount.

• IEC (Importer Exporter Code) Status: Ensure your 10-digit IEC is active and regularly updated on the DGFT portal. Without an IEC, you cannot legally export.

• RCMC (Registration-cum-Membership Certificate): Obtain and keep valid the RCMC from your respective Export Promotion Council (EPC) (e.g., APEDA, EEPC, FIEO). This is mandatory for claiming benefits under the FTP.

• Product Classification: Accurately classify your product using the 8-digit ITC-HS Code. This code determines export policy (restricted/free), Customs Duty rates, and eligibility for all incentive schemes (RoDTEP, AA, etc.). Misclassification is the number one cause of disputes.

• Licensing Check (if applicable): Verify if your product falls under the Restricted list or requires a license under SCOMET (Special Chemicals, Organisms, Materials, Equipment, and Technologies). Obtain the necessary authorization from DGFT before production/shipping.

• Incentive Pre-Compliance:

  • Advance Authorisation (AA): If using AA, ensure you have the authorization copy and have followed the SION (Standard Input-Output Norms) for raw material usage.

  • EPCG Scheme: Ensure you track the initial import details and have a clear plan for fulfilling the 6x duty saved Export Obligation (EO) over the 6-year period.

2. Customs & Shipment Compliance (During Shipment)

The Central Board of Indirect Taxes and Customs (CBIC) is responsible for clearance at the port. Correct documentation is the key to swift clearance.

• Customs Registration: Register your AD Code (Authorised Dealer Code) with the Customs House where your goods will be cleared (via ICEGATE). This links your export transaction to your bank for foreign currency realization.

• Shipping Bill Filing: Ensure the Shipping Bill (the primary customs document) is filed electronically via the ICEGATE portal accurately and on time, using your Customs House Agent (CHA).

  • Mandatory fields to cross-check: Accurate HS Code, declared FOB Value, correct Incoterm, and the declaration code for the export incentive being claimed (e.g., ‘RoDTEPY’ if claiming RoDTEP).

• Required Documentation: Prepare a complete and consistent set of commercial and transport documents:

  • Commercial Invoice & Packing List (must match the Shipping Bill data).

  • Bill of Lading (B/L) or Air Waybill (AWB).

  • Certificate of Origin (COO) (required by the buyer or for FTA/PTA benefits).

  • Inspection/Phytosanitary Certificates (if required for the product/destination).

• Let Export Order (LEO): Obtain the LEO from the Customs Officer. This is the final approval for the goods to be loaded onto the vessel/aircraft.

• EGM/IGM Filing: Ensure your shipping line or airline files the Export General Manifest (EGM) correctly and on time, as this forms the electronic proof of shipment necessary for incentive claims.

3.FEMA & Payment Compliance (After Shipment)

The Foreign Exchange Management Act (FEMA), monitored by the Reserve Bank of India (RBI) through your Authorised Dealer (AD) Bank, governs the inflow of foreign exchange.

• Payment Realization Timeline: Ensure the full export value of the goods or services is realized and repatriated to India within 15 months from the date of export (as per recent RBI circulars, consult your bank for the currently applicable period).

• Manner of Receipt: Ensure payment is received through proper banking channels (your AD Bank) and typically in a freely convertible foreign currency (unless INR invoicing is specifically permitted by RBI).

• Submission of Documents: Submit the required export documents (Invoice, Packing List, Exchange Control Copy of the Shipping Bill, etc.) to your AD Bank within 21 days from the date of export.

• e-BRC (Electronic Bank Realization Certificate): Upon receipt of the export proceeds, ensure your AD Bank issues and uploads the e-BRC to the DGFT portal. This certificate is the final proof of foreign exchange realization and is mandatory for closing incentive obligations (AA/EPCG) and claiming refunds (RoDTEP/GST).

• Advance Payment: If you received an advance payment, ensure the goods are shipped within three years from the date of receipt, and the advance is duly reported to your AD Bank (as per recent RBI guidelines).