Import Monitoring System for Yellow Peas and Melon Seeds in India

1. Overview of the Products & Why Monitoring

• Yellow Peas (HS Code 07131010) are imported into India for food/feed use. India has recently liberalised their import policy but made imports subject to registration under an import monitoring system. (Business Standard)
• Melon Seeds (HS Code 12077090 “Other” under seed-sector) imports are controlled, due to seed-quality, domestic production, food-safety/regulatory concerns.
• Monitoring is intended to: safeguard domestic agriculture, ensure food safety/seed quality, track import volumes and origins, and avoid dumping or mis-use of imports.

2. Import Policy & Monitoring Requirements

2.1 Yellow Peas

• Imports of yellow peas are currently classified as “Free” (i.e., not subject to import restrictions) but subject to registration under the online Import Monitoring System (IMS). 
• For consignments with Bill of Lading (Shipped on Board) issued on or before certain cut-off dates, the “Free” status holds without Minimum Import Price (MIP) or special port restrictions. For example, consignments issued on or before March 31 2026 are covered under the extended “Free” status. 
• Key condition: Importer must register the consignment online under the IMS before import clearance. (The Economic Times)

2.2 Melon Seeds

• Imports of melon seeds under HS 12077090 are generally “Restricted” (i.e., import subject to policy condition (4) of Chapter) unless specifically allowed. 
• A notification (No. 05/2023-DGFT dated 5 April 2024 made the import policy “Free” for a limited period (1 May 2024 to 30 June 2024) on ‘Actual User’ basis to processors of melon seeds only, with valid manufacturer licence from Food Safety and Standards Authority of India (FSSAI) and subject to registration under Melon Seeds Import Monitoring System (MS-IMS). 
• A separate PUBLIC NOTICE NO. 02/ 2024 sets out the procedure for MS-IMS registration for melon seeds & yellow peas.

3. Procedure for Import Monitoring System Registration

Here is a step-by-step summary of how the registration works (particularly for melon seeds, similar for yellow peas):

1. Importer accesses the DGFT website ? Services ? Import Management System ? Import Monitoring System ? “Melon Seeds & Yellow Peas Import Monitoring System (MS-IMS/IMS)”.
2. The importer submits advance information about the consignment: e.g., exporter details, country of origin, port of loading, Bill of Lading details, etc. (PUBLIC NOTICE NO. 02/ 2024)
3. The importer pays an online fee (for example Rs 500 for melon seeds registration) and the system issues an Automatic Registration Number (ARN).
4. The ARN is valid for one specific country of origin and one port of import only (in case of melon seeds). (PUBLIC NOTICE NO. 02/ 2024)
5. The importer must complete registration within a given timeframe (e.g., within 10 days from Bill of Lading date in case of melon seeds).
6. On import clearance at the Indian customs port, importer needs to submit the ARN along with required licences/certificates (e.g., FSSAI manufacturing licence in case of melon seeds) to Customs authorities. (PUBLIC NOTICE NO. 02/ 2024)

4. Compliance Requirements & Related Conditions

• For yellow peas: registration under IMS is mandatory; though MIP and port restrictions may be relaxed, the tracking mechanism remains. (Business Standard)
• For melon seeds: Imports must be on ‘Actual User’ basis (processor/importer who will use the seeds), importer must hold a valid FSSAI manufacturer licence, and each consignment must be registered under MS-IMS. 
• The consignment’s Bill of Lading date matters: only consignments shipped on board before the cut-off date are eligible under certain “free” policy conditions. 

5. Practical Implications for Importers

• You must plan ahead: ensure registration is done early, the correct country of origin and port is captured, ARN is in hand before import clearance.
• For melon seeds: you must qualify as an actual user (processor) and hold FSSAI licence. Without this, import may not be cleared or might attract penalty.
• Bill of Lading (Shipped on Board) date is critical if you wish to avail “free” import status under the relaxed policies.
• Even under “Free” status (no MIP/port restriction), you are still under monitoring — so compliance remains high.
• Failure to register or incorrect registration may lead to customs hold, import rejection, or difficulties in clearance.

6. Why This Monitoring System Matters

• Helps the government track volumes, origins, and ports of high-sensitivity agricultural or seed-imports.
• Supports domestic industry protection (for processing, seed quality) and prevents misuse of imports (dumping, re-export etc).
• Enables policy flexibility: while giving “free” status temporarily, the tracking allows for future adjustments (like re-imposing restrictions if needed).
• Facilitates regulatory oversight by linking import registration to other licences (FSSAI, actual user status) to ensure alignment with domestic policy goals.

7. Key Considerations & Risks

• Importers must stay updated because policy status (free vs restricted) may change (e.g., melon seeds policy period was limited).
• Registers must ensure data accuracy (origin, port, user status) — errors may delay clearance.
• Since registration links to specific country/port (for melon seeds), choosing origin/port matters strategically.
• Clearance may still require additional licences or compliance checks (food safety, seed certification).
• Policy cut-off dates (B/L dates) must be honoured — consignments beyond the date may revert to restricted import policy.

Here’s a procedural checklist and a compliance-checklist for the import of Melon Seeds and Yellow Peas into India under the respective import-monitoring regimes. You can adapt it to your internal compliance manual or for onboarding new import-businesses.

? Procedural Checklist for Import of Melon Seeds & Yellow Peas

Compliance & Importer-Checklist (Good Trade Practices)

• Ensure IEC (Importer-Exporter Code) is valid, linked to PAN and active.
• Use correct HS code (Melon Seeds: 12077090; Yellow Peas: 07131010).
• Register under the correct IMS scheme-portal: MS-IMS for Melon Seeds and IMS for Yellow Peas.
• Upload all required BoL copies at registration; ensure country of origin and port details accurately declared. (PUBLIC NOTICE NO. 02/ 2024)
• Check “actual user” condition: The importer must actually process/consume the import (especially for Melon Seeds).
• Verify and maintain FSSAI manufacturer licence (when required) and ensure the unit is authorised for the specific product category.
• Confirm that shipment’s BoL date meets the “Free status” cut-off (to avoid falling into restricted regime).
• At time of customs clearance, present IMS registration ARN, FSSAI licence (if applicable), and ensure documents match registration.
• Monitor changes in import policy: policy windows are often time-bound (e.g., “Free” only till a specified date).
• Maintain transparency and accuracy in invoicing, origin, weight, product description — avoid mis-declaration because monitoring systems link to origin/port.
• Maintain audit trail: Keep copies of registration, licence, invoices, correspondence for five years or as required under Foreign Trade (Regulation) Rules.
• Use ERP/tracking system for key milestones: registration date, BoL date, customs clearance, policy change alerts.
• Engage with compliance/legal advisor when policy windows approach expiry or if imports from new country of origin/port are considered.