Daily Customs & DGFT Update | 2 November 2026

1. DGFT amends Chapter 10 of the Handbook of Procedures, 2023

DGFT Public Notice | SCOMET Export Authorisation

Public Notice No. 36/2026-27

Date: 2 November 2026

The Directorate General of Foreign Trade (DGFT), Department of Commerce, Ministry of Commerce and Industry, has issued Public Notice No. 36/2026-27 dated 2 November 2026, amending specified provisions of Chapter 10 of the Handbook of Procedures, 2023.

Chapter 10 of HBP 2023 contains the procedural framework for export of SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) items. The amendment provides facilitation to eligible 4-Star and 5-Star Status Holders by recognising their valid Status Holder Certificate as an alternative to specified AEO certification requirements in identified procedures.

The change is particularly relevant where the existing procedure refers to AEO certification, including the AEO T2 requirement. Under the amended provisions, the specified Status Holder category may rely on its valid 4-Star or 5-Star certificate in place of the relevant AEO certificate, subject to the conditions of the particular paragraph.

What is the significance of the Status Holder Certificate alternative?

The Foreign Trade Policy recognises exporters with established export performance through the Status Holder system. The DGFT amendment uses this existing recognition framework to provide facilitation in certain SCOMET authorisation procedures.

For an eligible exporter, this can reduce the need to separately rely on the specified AEO certification route for the amended procedure. However, the benefit must be read narrowly: the certificate must be valid, the exporter must fall within the specified 4-Star or 5-Star category, and the applicable procedural conditions must continue to be met.

Paragraph-wise amendments

The following provisions have been identified as amended by the Public Notice. The table summarises the operational subject of each change and should be read with the exact substituted text in the official instrument.

Who can use this facilitation?

The alternative is relevant to exporters holding a valid 4-Star or 5-Star Status Holder Certificate. An exporter should verify the validity of its certificate on the date it seeks to rely on the amended procedure and confirm that the precise authorisation category is covered.

Businesses holding a 1-Star, 2-Star or 3-Star certificate should not assume that the same relaxation applies to them. Similarly, a valid Status Holder Certificate should not be treated as a substitute for unrelated licensing, end-use, record-keeping, ICP or other SCOMET controls.

Practical significance for exporters

• Review authorisation route: Identify whether the proposed export or authorisation falls under one of the paragraphs amended by PN 36/2026-27.
• Check certificate category: Confirm that the organisation holds a valid 4-Star or 5-Star Status Holder Certificate.
• Retain supporting evidence: Keep the Status Holder Certificate and relevant ICP documentation readily available for internal review and regulatory verification.
• Do not over-extend the benefit: Apply the alternative only to the specific AEO reference modified by the Public Notice.

Primary reference: DGFT Public Notice No. 36/2026-27 dated 2 November 2026. DGFT official portal. Locate the notice by its number and date and consult the original PDF before relying on the amended wording.

2. GAER validity extended from one year to three years

GAER | General Authorisation for Export after Repair in India

One of the most operationally significant changes in Public Notice No. 36/2026-27 concerns the validity period of the General Authorisation for Export after Repair in India (GAER). The validity period is revised from one year to three years from the date of issuance.

GAER is relevant to the export-after-repair process involving imported SCOMET items. The authorisation framework enables eligible Indian entities to undertake repair in India and thereafter export the relevant items in accordance with the prescribed conditions. The longer validity period can reduce the frequency with which an eligible entity needs to seek renewal or a fresh authorisation, subject to the terms governing the authorisation.

Earlier position and revised position

What does the three-year validity mean?

Under the revised framework, the GAER authorisation validity runs for three years from its date of issuance. This is a material change for entities that undertake repeated repair-and-export transactions and need to plan their authorisation lifecycle over a longer period.

However, the revised validity should not be interpreted as an unconditional extension of every GAER already issued. Holders of existing authorisations should examine the operative language of the Public Notice, including any commencement or transitional provision, before treating an existing authorisation as extended. The date of issuance and the specific conditions printed in the authorisation remain important.

Quarterly post-shipment reporting: What has changed?

The reporting cycle has also been rationalised. Instead of submitting a post-shipment report within 30 days of each export, the relevant reports are to be submitted quarterly, within 30 days from the end of the respective quarter.

This changes the compliance rhythm for GAER holders. Rather than tracking a separate 30-day reporting deadline after every export, the entity can organise the prescribed reporting by quarter. It does not, however, remove the obligation to maintain transaction-level records. Exporters should continue to capture each export, repair reference, authorisation reference and supporting document so that the quarterly report can be prepared accurately.

Illustrative quarterly reporting calendar

The following is an illustrative calendar applying the stated rule of submission within 30 days from the end of each quarter. The exact reporting periods and any special instructions should be checked against the prescribed form and official procedure.

The table illustrates quarter-end reporting periods. It does not replace the official reporting calendar, prescribed form or any instructions specifying the relevant quarter definition or submission mechanism.

What should GAER holders do now?

1. Review the authorisation: Record the GAER number, date of issue, current expiry date and conditions.
2. Check transitional treatment: Determine from the Public Notice whether and how the revised three-year validity applies to authorisations already in force.
3. Update the reporting calendar: Replace individual post-export deadline tracking with a quarterly control, where the amended procedure applies.
4. Maintain transaction-level data: Keep export dates, item descriptions, quantities, repair records, re-export details and supporting documents reconciled.
5. Assign responsibility: Nominate an owner for quarter-end preparation, review and submission of the post-shipment report.
6. Retain evidence of filing: Preserve acknowledgements and the final report submitted for each reporting period.

3. Impact across key SCOMET authorisation procedures

The Public Notice makes changes across more than one procedural route in Chapter 10. The provisions identified in the amendment include Stock and Sale, GAER, GAET and GAEIS. These routes serve different transaction structures, and the Status Holder facilitation should be applied with reference to the exact paragraph relevant to the proposed activity.

Stock and Sale

Paragraph 10.10(c)(vii) is identified as the Stock and Sale provision affected by the amendment. For the specified condition, a valid 4-Star or 5-Star Status Holder Certificate is accepted as an alternative to the AEO certificate. Exporters using the Stock and Sale route should check the remaining eligibility and authorisation conditions independently.

GAER

Paragraphs 10.12(D)(A)(m) and 10.12(D)(B)(5) are identified in connection with the Status Holder Certificate alternative. The relevant provision also refers to Internal Compliance Programme (ICP) compliance. The certificate alternative should therefore not be read as dispensing with the ICP-related requirement.

Separately, Paragraph 10.12(D)(A)(e) and Serial No. 4 of the table under Paragraph 10.17 are identified in connection with the revised GAER validity and quarterly reporting treatment.

GAET and GAEIS

Paragraph 10.15(I)(1)(b)(vi), relating to GAET, and Paragraph 10.15(II)(1)(b)(vi), relating to GAEIS, are identified as the corresponding provisions where the Status Holder Certificate alternative is recognised for eligible 4-Star and 5-Star Status Holders to meet the specified AEO T2 requirement.

Entities using these authorisation routes should verify the precise wording and any associated conditions in the amended HBP text. The existence of a similar alternative in one route does not mean that every procedural condition in another route is identical.

4. Practical compliance checklist for exporters

The amendment requires affected businesses to review both their authorisation eligibility and their ongoing compliance processes. The following checklist can be used by export compliance, legal, logistics and finance teams.

5. Important dates and timelines

The Public Notice date is not necessarily the same as the commencement date for every amendment. The operative clause and any transitional provision in the original instrument govern. In particular, do not presume that an existing GAER authorisation has automatically acquired a three-year validity period without checking the notice.

6. Other portal updates reviewed for 2 November 2026

In addition to the principal DGFT development, the portal scan for this edition covered the principal Customs and trade-related sources. The findings below distinguish a dated policy instrument from a portal scan result. A clear scan means that no separately dated item was identified in the material reviewed; it should not be read as a legal certification that no communication was issued through any channel.

DGFT: Two Public Notices issued on the same date

The distinction between Public Notice No. 36/2026-27 and Public Notice No. 37/2026-27 is important for accurate citation. The SCOMET / GAER amendments discussed in this article are attributed to Public Notice No. 36/2026-27 dated 2 November 2026. Public Notice No. 37/2026-27 is a separate instrument and should not be cited as the legal basis for the amendments described above.

For a regulatory article, the notice number, subject and operative paragraphs must travel together. A correct date with an incorrect notice number can lead readers to a different instrument and undermine the reliability of the compliance summary.

7. Official research portals

The following portals are relevant for readers who wish to verify the original instruments and monitor subsequent developments:

• DGFT – Official portal and Public Notices
• CBIC – Central Board of Indirect Taxes and Customs
• CBIC Tax Information Portal
• e-Gazette of India
• ICEGATE – Indian Customs Electronic Gateway
• Department of Commerce