Legal Analysis of Circular No. 15/2025-Customs: Procedural Reforms in Air Cargo and Transhipment Regime

The Central Board of Indirect Taxes and Customs (CBIC), by issuance of Circular No. 15/2025-Customs dated 25th April 2025, has introduced a set of comprehensive measures aimed at streamlining the procedures governing the movement and transhipment of air cargo, with particular focus on high-value and perishable consignments. These amendments are in continuation of the policy thrust as articulated by the Hon’ble Finance Minister during the Union Budget 2025–26 and represent a marked advancement in the simplification of customs operations and air cargo logistics.

I. Withdrawal of Transhipment Permit Fees

A key reform undertaken pertains to the abolition of the Transhipment Permit fee of Rs. 20 per movement, previously chargeable under the Goods Imported (Conditions of Transshipment) Regulations, 1995. This measure, effected through Notification No. 30/2025-Customs (N.T.) dated 24 April 2025, constitutes a compliance cost reduction initiative intended to accelerate cargo transhipment and reduce financial friction for stakeholders. The Board has thus effectively dismantled a long-standing procedural hurdle without compromising regulatory oversight.

II. Temporary Import of Unit Load Devices (ULDs): Harmonised Framework

In light of increasing reliance on Unit Load Devices (ULDs) for transportation of sensitive, perishable, and high-value commodities, the CBIC has introduced a harmonised procedure for their temporary import outside the customs area, modeled on the pre-existing framework applicable to marine containers (Circular No. 31/2005-Customs).

The procedural architecture is detailed as follows:

1. Execution of Continuity Bond: Air carriers and air console agents are permitted to temporarily import ULDs, with or without integrated tracking devices, upon execution of a Continuity Bond as security for re-export.
2. Tracking Devices – Identification and Compliance:
   • Devices affixed to ULDs must bear Unique Identity Numbers (UINs) at the time of import.
   • Devices typically comprise Bluetooth communication modules and power sources; compliance with standards prescribed by the Bureau of Civil Aviation Security (BCAS) is mandatory.
3. Accountability of Proof of Export: The obligation to furnish evidence of exportation of ULDs (including any attached devices) rests entirely on the importing air carrier or agent, within the prescribed timeline.
4. Exclusion Clause: The exemption afforded under Notification No. 104/94-Customs does not extend to standalone tracking devices/data loggers that are not physically affixed to ULDs at the time of import.
5. Applicability of Earlier Framework: Circular No. 51/2020-Customs continues to govern situations involving temporary import of containers by parties other than air carriers/console agents, including instances of laden or unladen containers being moved outside the customs zone.

III. Digitisation and All-India National Transhipment Bond

Furthering the digitisation mandate under the Ease of Doing Business agenda, the Board reiterates that:

• The All-India National Transhipment Bond introduced in 2022 remains the valid instrument for all import transhipments, thereby obviating the necessity for submission of multiple localised bonds at different air cargo customs stations.
• Additionally, transhipment requests may now be filed electronically via the ICEGATE portal, nullifying the need for in-person engagement with customs service centres at airports.

This digital enablement is expected to provide significant operational relief to airlines, air console agents, and all authorised air transhippers, and its adoption is strongly encouraged.

IV. Legal Efficacy and Implementation

The directions contained in the Circular take effect immediately and are legally binding upon all field formations. Any challenges or operational ambiguities arising from implementation are to be escalated to the Board for appropriate clarification.

Conclusion

The reforms encapsulated under Circular No. 15/2025-Customs reflect a strategic recalibration of the air cargo regulatory framework, one that marries regulatory certainty with procedural agility. By eliminating archaic fee structures, facilitating seamless temporary imports, and leveraging centralised digital tools, CBIC has made a significant contribution towards advancing India's competitiveness in the global trade logistics ecosystem—particularly for time-sensitive, high-value goods.