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In a major step towards export process reform, the Central Board of Indirect Taxes and Customs (CBIC) has issued Circular No. 11/2025-Customs, dated 3rd April 2025, implementing the Export Entry (Post Export Conversion in relation to Instrument-based Scheme) Regulations, 2025. This new regulatory framework supersedes the earlier Shipping Bill (Post Export Conversion) Regulations, 2022, and is aimed at automating and streamlining the amendment process for export documentation, thus reducing compliance costs and enhancing ease of doing business for exporters.
Context and Objective
India’s export landscape has undergone several transformations in recent years. The government's focus has been on simplification, digitalization, and transparency. Measures like seamless credit of drawback, single registration for Authorized Dealer (AD) Codes, and expanded RODTEP coverage reflect this broader reform trajectory.
In keeping with the 2025-26 Budget’s mandate for automation of remaining customs processes, the CBIC has now introduced a formal mechanism for post-export changes in shipping bills, under Section 149 of the Customs Act, 1962.
Key Features of the New Amendment Mechanism
The latest circular outlines the following salient features for post-export changes:
- Electronic Processing of amendments under Section 149, eliminating manual interventions.
- Handling of provisional assessment in export scenarios via digital means.
- Re-transmission of updated shipping bill details to relevant government agencies and systems.
This automation is set to bring transparency, traceability, and faster resolution of amendment requests.
Approval Requirements for Sensitive Fields
Certain critical fields in the shipping bill, if amended post-export, require higher-level approval due to the potential implications on revenue, international tracking, and benefit eligibility. These are:
Category | Fields Requiring Additional/Joint Commissioner’s Approval |
Shipping Bill Level | Port of Loading, Country of Final Destination, Port of Discharge |
Invoice Level | AD Code, Invoice Value |
Item Level | HS Code, Description of Goods, Quantity |
Note: Where shipping bill conversion is involved, the competent authority continues to be the Commissioner or Principal Commissioner of Customs.
Highlights of the Export Entry Regulations, 2025
The Export Entry (Post Export Conversion in relation to Instrument-based Scheme) Regulations, 2025, as introduced via Notification No. 21/2025-Customs (NT), include several important updates:
Clause | Provision |
Definition | Introduces the term ‘Export Entry’ encompassing all exports under Section 2(16) of the Customs Act. |
Time Limit | Post-export conversion must be filed within 1 year from the date of clearance order. For entries prior to 22.02.2022, the one-year window starts from the effective date of the new regulation. |
Section 84 Entries | Entries under Section 84 now covered, provided that conditions on reversal of benefits are fulfilled. |
Drawback to Instrument-based Schemes | Allows conversion from drawback to schemes like MEIS, RODTEP, EPCG, subject to reversal of earlier benefits. |
Reversal Condition | Conversion requests require full reversal of benefits claimed under the original scheme. |
Coverage | Applies to all export entries, including Advance Authorization, EPCG, Drawback, and other schemes, but not free shipping bills. |
Implementation and Advisory
The Directorate General of Systems and Data Management (DG Systems) will soon issue an implementation advisory, including operational instructions for the Post Export General Manifest (EGM) module.
Exporters and field officers alike are encouraged to adapt to the new digital interface to handle post-export amendments effectively. Furthermore, the circular mandates the issuance of Trade/Public Notices to ensure wider awareness among the exporting community.
Conclusion
Circular No. 11/2025-Customs marks another significant milestone in India’s export reform journey. By digitizing and streamlining post-export amendments, the CBIC has not only addressed long-standing industry concerns but also reaffirmed its commitment to building a more agile and responsive customs framework. Exporters should take advantage of these changes by aligning their compliance protocols accordingly and keeping abreast of the upcoming DG Systems advisory for smooth implementation.
For any unresolved issues or difficulties in execution, stakeholders are advised to escalate them to the CBIC for timely resolution.