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Registration Certificate For Import

  • Writer: Commercial Consultancy Counsel
    Commercial Consultancy Counsel
  • Oct 28, 2024
  • 2 min read

Updated: Jan 15

  1. What is a Registration Certificate under the FTP?


Registration Certificate (“RC”) for import is a crucial regulatory requirement for importers in cases of transitional arrangements (“Arrangements”) provided under para 1.05(b) of the Foreign Trade Policy (“FTP”). RC may also be required for specific cases other than such Arrangements as notified by the DGFT in the FTP from time to time.


  1. When is RC required?

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RC is required when there is a change in the import/export policy of an item (e.g., from "free" to "restricted" or "prohibited"). RC ensures that the importer complies with the new policy and that the import of the item is lawful.


  1. What does the FTP provide for the requirement of RC in case of change in policy as mentioned in question 2 above?


If an importer/exporter has already committed to a transaction under an Irrevocable Commercial Letter of Credit (“ICLC”) before the policy change, they can still complete the import under the original policy condition, provided that the remaining quantity, value, and period are within the terms of the ICLC.

The ICLC serves as proof that an importer had a pre-existing commercial commitment before the government changed the import/export policy for the item (e.g., from "free" to "restricted").

By attaching the ICLC while applying for the RC on the DGFT portal, the importer can demonstrate that the transaction is covered under the Arrangement of the FTP, allowing the importer to import the item with respect to the original policy terms despite the policy change.

RC allows the importer to continue importing the inputs under the original conditions, even after the policy has shifted.


  1. When is RC not required?


If an importer has already imported the item before the policy change, then he is not affected by the new restrictions and doesn’t not require to register for the the RC.


  1. What is the validity period of the RC?


The RC shall be valid till the ‘Original Shipment’ period as mentioned in the ICLC or as stipulated by the DGFT.


  1. What is the timeline for filling for RC?


The RC must be filed on the DGFT Portal within 15 days of imposition of any such restriction/regulation/policy change.

 
 
 

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