DGFT’s certification waiver proposal for micro exports gets thumbs up, with riders
The Directorate General of Foreign Trade (DGFT) issued a trade notice proposing to exempt export consignments with a free-on-board (FOB) value of up to ₹10,000 from the requirement of obtaining a Registration-cum-Membership Certificate (RCMC), by amending Paragraph 2.57 of the Foreign Trade Policy (FTP) 2023.
The proposed "de minimis" exemption is targeted at exports moving through postal, courier and e-commerce channels, and is expected to primarily benefit micro, small and medium enterprises (MSMEs), artisans and first-time exporters.
The exemption would not apply to items classified as "Restricted" under the ITC (HS) export classification, meaning sensitive or controlled goods remain outside the relaxation regardless of consignment value.
Stakeholders, including exporters and industry associations, were given 10 days from the date of the trade notice to submit comments before the proposal is finalised, with industry reactions described as broadly positive but flagging that the low value cap may limit the practical impact.
DGFT and the Foreign Trade (Development and Regulation) Act, 1992
The Directorate General of Foreign Trade (DGFT) is an attached office of the Ministry of Commerce and Industry, responsible for implementing India's Foreign Trade Policy and issuing Importer-Exporter Codes (IEC), export authorisations and trade notices. Its statutory powers derive from the Foreign Trade (Development and Regulation) Act, 1992, which empowers the Central Government to regulate and promote foreign trade by facilitating imports and exports.
Key Details
- The Act replaced the earlier, more restrictive Imports and Exports (Control) Act, 1947, reflecting India's post-1991 liberalisation shift from a control-oriented to a facilitation-oriented trade regime.
- DGFT operates through Regional Authorities and formulates policy instruments such as the Foreign Trade Policy (issued periodically; the current version is FTP 2023, notified without a fixed end date to allow dynamic, need-based amendments).
- DGFT trade notices, such as the one proposing this RCMC waiver, are a standard instrument for public consultation before amending FTP provisions.
The proposed amendment to Paragraph 2.57 of FTP 2023 is a routine exercise of DGFT's statutory rule-making function under the 1992 Act, using the prescribed stakeholder-consultation route before altering an export procedural requirement.
Registration-cum-Membership Certificate (RCMC) — Function and Issuing Authority
An RCMC is a certificate that confirms an exporter's registration and membership with a relevant Export Promotion Council (EPC) or commodity board recognised by DGFT, and is ordinarily required to access benefits and authorisations under the Foreign Trade Policy, such as concessional duty schemes and export promotion scheme access.
Key Details
- RCMCs are issued by product/sector-specific EPCs or commodity boards, each authorised by the Central Government to register exporters within their designated category.
- An RCMC is typically valid for five financial years and must be renewed to continue accessing FTP-linked benefits and schemes.
- Mandatory RCMC compliance has been cited as a procedural barrier for micro and first-time exporters, particularly those transacting through postal, courier or e-commerce channels where consignment values are often too small to justify the compliance cost of registration.
The proposed waiver directly targets this compliance barrier by removing the RCMC requirement for the smallest-value shipments, aligning procedural burden with the (low) stakes of a de minimis consignment.
FTP 2023 De Minimis and Courier/E-Commerce Export Facilitation
The Foreign Trade Policy 2023, notified as a dynamic, non-expiring policy document, introduced several e-commerce and low-value export facilitation measures, including an earlier de minimis exemption from RCMC/Certificate of Registration requirements for FOB value up to ₹10,000, and separately raised (and later removed) the per-consignment value cap for exports routed through registered couriers and foreign post offices.
Key Details
- FTP 2023 removed the previous ₹10 lakh per-consignment value limit for courier and Foreign Post Office (FPO) exports effective April 1, 2026, to encourage e-commerce exporters to use courier channels for larger shipments.
- FTP 2023 also introduced "Dak Ghar Niryat Kendras" — a hub-and-spoke network integrating with Foreign Post Offices to help artisans, weavers and MSMEs in hinterland and landlocked regions access export markets.
- The current DGFT proposal effectively reiterates and operationalises the pre-existing ₹10,000 de minimis threshold specifically through an amendment to Paragraph 2.57, addressing implementation gaps flagged by exporters and industry bodies.
This proposal sits within a broader FTP 2023 policy thrust of lowering compliance costs for low-value, high-volume e-commerce and courier-based exports, treating "de minimis" trade facilitation as a distinct micro-export policy lever alongside traditional large-consignment trade regulation.
- Proposed RCMC exemption threshold: FOB value up to ₹10,000 per consignment
- FTP provision being amended: Paragraph 2.57 of Foreign Trade Policy (FTP) 2023
- Stakeholder comment window: 10 days from the trade notice
- Exclusion: goods classified "Restricted" under ITC (HS) remain outside the exemption
- Statutory basis for DGFT's authority: Foreign Trade (Development and Regulation) Act, 1992
- RCMC validity period (standard): 5 financial years
- Related FTP 2023 courier reform: removal of the ₹10 lakh per-consignment value cap for courier/Foreign Post Office exports, effective April 1, 2026
- Target beneficiary groups: MSMEs, artisans, first-time exporters, e-commerce sellers using postal/courier channels