Harun Raaj & AssociatesHarun Raaj & Associates

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Customs Duty & Trade Policy

EPCG Scheme — Zero Duty Capital Goods

EPCG Scheme

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Regulatory Framework

The Export Promotion Capital Goods (EPCG) Scheme, set out in Chapter 5 of the Foreign Trade Policy 2023 (read with HBP 2023 Chapter 5), permits import of capital goods for pre-production, production, and post-production — including CKD/SKD components and computer software systems used for such capital goods — at zero Basic Customs Duty. The corresponding obligation is 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 EPCG authorisation.

Capital goods imported under EPCG remain subject to Actual User condition until the export obligation is discharged. Standard Input-Output Norms (SION) do not apply to EPCG, since it is a capital-goods scheme rather than an input scheme — it should not be conflated with Advance Authorisation, which serves a materially different purpose (duty-free inputs, not capital equipment).

On fulfilment of the EO, the authorisation holder applies to DGFT for redemption and an Export Obligation Discharge Certificate (EODC); any shortfall attracts proportionate customs duty recovery with interest, and repeated or wilful default can additionally attract penal action under the Foreign Trade (Development & Regulation) Act, 1992. The scheme is available to manufacturer-exporters, merchant-exporters (with a supporting manufacturer), and specified categories of service providers.

Overview

The EPCG scheme — Export Promotion Capital Goods — lets an exporter import capital goods at a concessional or zero customs duty, subject to an export obligation: the exporter must export goods of a value equal to a prescribed multiple of the duty saved, within a prescribed period (VERIFY: the current export obligation multiple and period under the Foreign Trade Policy). The scheme is the government's way of making Indian manufacturing's machinery competitive — the duty saving is effectively repaid through future exports, and the obligation is monitored by DGFT and Customs.

The scheme suits manufacturers whose capital costs — machinery, plant, equipment — are the competitive constraint. Importing the machine duty-free lowers the capital base; the export obligation converts the saving into a performance target. The obligation runs for years, and its fulfilment is tracked through shipping bills and export realisations, with the Export Obligation Discharge Certificate (EODC) closing the file.

The risk is the reversal: if the export obligation is not fulfilled in time, the duty saved becomes payable under the Customs Act with interest, and the exporter's DGFT record carries the default. The obligation can be extended in part under the FTP's provisions, but extensions are not automatic — they require application and conditions.

This service is for exporters importing capital goods under the EPCG scheme. We compute the duty saving and the obligation, prepare and file the application under the FTP, manage the import and the bonding, track the export obligation through shipping bills and e-BRCs, apply for extensions where needed, and file the EODC to close the authorisation cleanly.

How It Works

  1. 1

    Capital Goods & Duty Analysis

    We assess the capital goods import and compute the duty saving and the export obligation.

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

    EPCG Application

    We prepare the application under the Foreign Trade Policy with the capital goods and export plan.

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

    DGFT Issuance & Import

    We file the application and coordinate the import at the concessional duty.

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

    Obligation Tracking

    We track the export obligation through shipping bills and e-BRCs across the period.

    Harun Raaj & Associates does thisOngoing
  5. 5

    EODC & Extension

    We apply for extensions where needed and file the EODC to close the scheme.

    Harun Raaj & Associates does this1-2 weeks

Frequently Asked Questions

What is the export obligation under the EPCG scheme and how is it calculated?
Under Para 5.01 of the Foreign Trade Policy 2023, an EPCG authorisation holder must fulfil an export obligation equal to 6 times the CIF value of capital goods imported, within 6 years from the date of authorisation. Para 5.04 provides a reduced obligation of 75% for specified sectors. Fulfilment is evidenced by an Export Obligation Discharge Certificate (EODC) issued by the Regional Authority of DGFT.
Which capital goods qualify for 0% duty import under an EPCG authorisation?
Para 5.01 of FTP 2023 read with Customs Notification No. 16/2015-Cus permits import of new capital goods including spares, jigs, fixtures, dies, and moulds at 0% Basic Customs Duty. Second-hand capital goods with a residual life of at least 10 years are allowed under Para 5.06. The goods must be pre-production, production, or post-production equipment directly linked to the exported product or service.
What are the consequences of failing to meet the export obligation within the prescribed period?
If the export obligation is not fulfilled within 6 years, the duty saved becomes recoverable with interest at 15% per annum under Customs Act 1962 Section 28 read with Para 5.23 of FTP 2023. A Show Cause Notice may be issued under Section 11 of the Foreign Trade (Development and Regulation) Act 1992. A composition fee option is available under DGFT Policy Circulars to regularise defaults without full penalty.
Can an EPCG authorisation holder claim Input Tax Credit on IGST paid at import?
Yes, where IGST is paid on imported capital goods (i.e., not exempted by a separate Customs Notification), the importer can avail ITC under CGST Act 2017 Section 16 read with Rule 36 of CGST Rules 2017, provided the goods are used for making taxable supplies. Where both BCD and IGST are exempted under a Customs Notification, no ITC is available on the exempted IGST component.
Is annual reporting to DGFT mandatory and what is the deadline?
Yes. Para 5.22 of FTP 2023 requires EPCG authorisation holders to submit an Annual Return by 30 April each year to the Regional Authority in the prescribed format, detailing exports made against each authorisation. Non-submission can result in debarment from future DGFT licences. The EODC application must be filed within 6 months of completing the export obligation or expiry of the obligation period, whichever is earlier.

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