Export Compliance India 2026 | DGFT, Customs & SCOMET Guide

Export compliance is non-negotiable. Violations of India's export control laws can result in IEC cancellation, heavy penalties, cargo seizure, and criminal prosecution. This pillar guide covers every compliance requirement for Indian exporters in 2026.

India's Export Regulatory Framework

India's export trade is governed by multiple authorities:

• DGFT (Directorate General of Foreign Trade): Issues IEC, licences, and administers the Foreign Trade Policy
• Indian Customs (CBIC): Controls physical movement of goods at ports and airports
• RBI (Reserve Bank of India): Governs foreign exchange and export proceeds realisation under FEMA
• Ministry of Commerce & Industry: Policy oversight for export promotion and restrictions
• Sector-specific regulators: CDSCO (pharma), APEDA (agri), AERB (nuclear), DRDO (defence)

Foreign Trade Policy (FTP) 2023 — Key Compliance Points

• All exports must be covered by a valid IEC
• Restricted goods require a licence from DGFT before export
• Prohibited goods cannot be exported under any circumstances
• Export obligations under EPCG and Advance Authorisation must be fulfilled on time
• Annual IEC update on DGFT portal is mandatory (April–June each year)

Export Categories Under ITC(HS)

Every export product is classified under the Indian Trade Classification (Harmonised System) — ITC(HS). Each product falls into one of three categories:

• Free: Can be exported without any licence or restriction
• Restricted: Requires a licence or permission from DGFT or the relevant authority
• Prohibited: Cannot be exported under any circumstances (e.g., wild animals, certain antiques, beef)
• Canalized: Can only be exported through designated government agencies (e.g., certain petroleum products)

SCOMET Controls — Dual-Use Export Controls

SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) is India's export control list for dual-use items and munitions. Exporting SCOMET items without a licence is a serious criminal offence.

SCOMET Categories

• Category 0: Nuclear materials and equipment
• Category 1: Toxic chemical agents and precursors
• Category 2: Micro-organisms and toxins
• Category 3: Materials, materials processing equipment
• Category 4: Electronics
• Category 5: Computers
• Category 6: Telecommunications and information security
• Category 7: Sensors and lasers
• Category 8: Navigation and avionics
• Category 9: Aerospace and propulsion
• Category 7A: Munitions list

How to Apply for a SCOMET Licence

1. Identify if your product falls under any SCOMET category
2. Apply on the DGFT portal with end-user certificate from the buyer
3. DGFT consults with MEA, DRDO, and other agencies
4. Licence issued within 30–60 days (subject to inter-ministerial clearance)

Customs Compliance at Export

• Shipping Bill: Must be filed accurately on ICEGATE before goods reach the port
• Let Export Order (LEO): Customs officer grants LEO after examination; goods can only be loaded after LEO
• Risk-Based Examination: Customs uses RMS (Risk Management System) to select shipments for physical examination
• Misdeclaration: Incorrect description, quantity, or value is a customs offence under the Customs Act 1962

FEMA Compliance for Exporters

• Export proceeds must be realised within 9 months (15 months for project/deemed exports)
• eBRC must be filed with the bank within 21 days of realisation
• Overdue bills must be reported via XOS statement to RBI
• Write-off of unrealised export proceeds requires RBI approval beyond prescribed limits

Penalties for Non-Compliance

• IEC suspension or cancellation by DGFT
• Penalty up to 5x the value of goods under FEMA
• Cargo seizure and confiscation under Customs Act
• Criminal prosecution for SCOMET violations
• Denial of export incentives (RoDTEP, Duty Drawback)

Export Compliance Checklist

• ☐ IEC active and annually updated
• ☐ Product classified correctly under ITC(HS)
• ☐ SCOMET check completed for dual-use items
• ☐ Restricted goods licence obtained (if applicable)
• ☐ Shipping Bill filed accurately on ICEGATE
• ☐ LEO obtained before loading
• ☐ Export proceeds realised within 9 months
• ☐ eBRC filed within 21 days of realisation
• ☐ RCMC current with relevant EPC

Related Pillar Guides

• How to Start Exporting from India
• IEC Registration India
• Export Documentation India
• Export Incentives India — RoDTEP & Duty Drawback