Harun Raaj & AssociatesHarun Raaj & Associates
FEMA & Cross-Border Transactions

EPCG Scheme & Advance Authorisation

EPCG / Advance Auth

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Regulatory Framework

Foreign Trade Policy 2023 provides two principal duty-exemption schemes for export-oriented capital investment and production:

EPCG (Chapter 5, FTP 2023, read with HBP 2023 Chapter 5): permits import of capital goods for pre-production, production, and post-production at zero Basic Customs Duty, subject to an Export Obligation (EO) equal to 6 times the aggregate duties, taxes, and cess saved on the imported capital goods, to be fulfilled within 6 years from the date of issuance of the authorisation. Capital goods remain subject to Actual User condition until the EO is discharged.

Advance Authorisation (Chapter 4, FTP 2023, read with HBP 2023 Chapter 4): permits duty-free import of inputs physically incorporated in the export product (plus specified fuel, catalysts, and packing materials), subject to a minimum value-addition threshold and export obligation fulfilment within 18 months from the date of authorisation, evidenced by import/export/consumption records and closed via an Export Obligation Discharge Certificate (EODC). Input-output norms for the authorisation may be fixed under Standard Input Output Norms (SION), self-declaration, ad hoc Norms Committee ratification, or the Self Ratification Scheme.

Both schemes are administered by DGFT; shortfall in export obligation under either scheme attracts proportionate customs duty recovery with interest, and repeated or wilful default is actionable under the Foreign Trade (Development & Regulation) Act, 1992. The two schemes are frequently confused but are structurally distinct — EPCG addresses capital goods, Advance Authorisation addresses production inputs.

Overview

The EPCG scheme and Advance Authorisation are the two flagship export incentives of the Foreign Trade Policy. Under the EPCG scheme, an exporter can import capital goods — machinery and equipment — at a concessional or zero customs duty, in exchange for an export obligation: the export of goods worth a prescribed multiple of the duty saved within the prescribed period (VERIFY: the current export obligation multiple and period under the FTP). Under Advance Authorisation, the exporter imports inputs duty-free against the export of the goods made from them, under Chapter 4 of the Foreign Trade Policy.

The two schemes serve different parts of the manufacturing chain. EPCG covers the machines; Advance Authorisation covers the materials. They are frequently used together by the same exporter — the EPCG for the plant, the Advance Authorisation for the production inputs — which is where the compliance becomes a shared discipline: both obligations are tracked against export performance, and both carry the reversal risk if the exports do not materialise.

The cost of missing an export obligation is the recovery of the benefit with interest: the duty saved becomes payable under the Customs Act with interest, and the exporter's record with DGFT carries the default. Because the obligation periods run for years, the tracking is the product — an exporter who loses the obligation file loses the benefit.

This service is for exporters using or planning the EPCG and Advance Authorisation schemes. We assess the duty saving and the obligation, prepare and file the applications under the FTP, track the export obligation against the shipping bills and e-BRCs, manage extensions and the EODC closure, and keep the schemes a source of margin rather than a source of risk.

How It Works

  1. 1

    Scheme & Savings Analysis

    We assess the EPCG and Advance Authorisation benefit for your import and export mix.

    Harun Raaj & Associates does this3-5 days
  2. 2

    Application Preparation

    We prepare the scheme applications with the input-output or capital goods data for DGFT.

    Harun Raaj & Associates does this1-2 weeks
  3. 3

    DGFT Filing & Issuance

    We file the applications and follow them to issuance of the authorisations.

    Harun Raaj & Associates does this2-6 weeks
  4. 4

    Export Obligation Tracking

    We track the obligations against shipping bills and e-BRCs through the period.

    Harun Raaj & Associates does thisOngoing
  5. 5

    EODC & Closure

    We file the Export Obligation Discharge Certificate and close the authorisations cleanly.

    Harun Raaj & Associates does this1-2 weeks

Frequently Asked Questions

What is the export obligation period under EPCG and what happens if it is missed?
Under Para 5.01 of the Foreign Trade Policy 2023, the export obligation under EPCG must be fulfilled within 6 years from the date of issue of the authorisation. If the obligation is not met, customs duty saved along with 15% interest per annum is recoverable under Section 28AA of the Customs Act 1962. Partial fulfilment triggers proportionate redemption under DGFT Public Notice guidelines.
What are the duty savings available under an Advance Authorisation and how is the value cap determined?
Advance Authorisation under Chapter 4 of FTP 2023 grants exemption from Basic Customs Duty, IGST, and Compensation Cess on inputs imported for physical export. The CIF value of permitted imports is based on SION (Standard Input-Output Norms) notified by DGFT. Where no SION exists, a self-declaration route under Para 4.07 applies, subject to independent CA certification of actual input consumption.
Is GST refund available on inputs procured domestically under Advance Authorisation?
Yes. Domestic supplies to an Advance Authorisation holder are treated as deemed exports under Section 147 of the CGST Act 2017, read with Rule 89(1)(g) of the CGST Rules 2017. The supplier can claim a refund of IGST paid, or the AA holder can claim refund of tax paid on deemed export supplies, whichever route is chosen under Notification No. 48/2017-CT.
What obligation tracking and redemption documents does DGFT require for EPCG closure?
Redemption requires submission of shipping bills with LEO (Let Export Order) date, Bank Realisation Certificates (BRCs) or eBRC from EDPMS, and installation certificate from a Chartered Engineer for capital goods. The application is filed on the DGFT portal using ANF-5B along with the EODC (Export Obligation Discharge Certificate) request. The CA certifies exports against the authorisation ledger.
Can EPCG authorisations be transferred or the export obligation be fulfilled through third-party exports?
EPCG authorisations are not transferable. However, export obligation can be fulfilled through third-party exports under Para 5.13 of FTP 2023, provided the main authorisation holder is named on the shipping bill as the exporter of record. The supporting manufacturer must have a valid IEC under Section 7 of the Foreign Trade (Development and Regulation) Act 1992.

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