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Streamlining and Expediting Assessment in FAG-REG: Ensuring Faster Customs Clearance through Better Compliance

YAGAY andSUN
Importers must self-assess and upload complete, legible IRN-tagged documents to electronic repository to enable faceless assessment The circular reiterates that under the Customs Act importers bear self-assessment responsibility and must furnish complete, legible, and correctly linked supporting documents via the electronic repository to enable efficient faceless assessment. A query analysis identified frequent delays caused by missing invoices, purchase orders, remittance proofs, licences, technical literature, and compliance certificates; the directive therefore mandates uploading and IRN-tagging of relevant documents, clear product descriptions and technical parameters, proof for exemption claims or preferential treatment, and prompt, specific responses to queries. Proper documentation and statutory registrations are emphasized to reduce correspondence, expedite clearance, and ensure accurate classification and valuation. (AI Summary)

JNCH Public Notice 82/2025 dtd. 29-10-2025

Introduction

The Indian Customs administration continues to advance toward a transparent, technology-driven, and paperless clearance system. In line with this vision, the Faceless Assessment Groups (FAGs) were established to promote uniformity, reduce delays, and simplify customs clearance under the Faceless Assessment regime.

To further improve efficiency and address recurring delays, the Commissioner of Customs, NS–V, Mumbai Customs Zone–II, has issued important directions under the title “Streamlining and Expediting Assessment in FAG–REG.” The circular emphasizes the responsibilities of importers and customs brokers in ensuring complete and accurate documentation while filing Bills of Entry (BEs) to facilitate quicker assessment.


Legal and Policy Background

Under Section 17 of the Customs Act, 1962, every importer is legally responsible for self-assessment—that is, correctly determining and declaring the duty liability on imported goods. This self-assessment system relies heavily on the accuracy and completeness of information furnished by the importer.

In October 2020, the Central Board of Indirect Taxes and Customs (CBIC) issued Circular No. 45/2020-Customs, introducing guidelines for faceless assessment. The circular urged the trade community to submit complete and correct information upfront, noting that missing or unclear details lead to queries from assessing officers, which ultimately delay clearance.


Findings from Query Analysis

The National Assessment Centre (NAC) for Electrical Machinery conducted a comprehensive query analysis exercise to identify why queries were being raised during assessment. The goal was to reduce unnecessary correspondence and speed up the process.

The study found that many Bills of Entry were filed with only the Airway Bill or Bill of Lading, while essential supporting documents were missing. Documents often omitted included Purchase Orders, Freight Invoices, Remittance Proofs, SVB Orders, BIS/ETA/MTCTE/WPC Licenses, and EPR Authorizations for plastic, battery, and e-waste imports.

In the absence of these documents, Assessing Officers had no choice but to raise queries for verification, causing avoidable delays in assessment and clearance.


General Instructions for Faster Assessment

To address these challenges, the circular provides detailed instructions for importers, customs brokers, and all stakeholders. The key recommendations are as follows:

  1. Upload all documents in e-Sanchit:
    Ensure legible copies of all supporting documents are uploaded before filing the BE.

  2. Properly link documents to the Bill of Entry:
    After uploading, tag each document’s IRN (Image Reference Number) with the correct BE to ensure traceability.

  3. Provide catalogues and technical literature:
    Upload product catalogues, technical write-ups, data sheets, or user manuals with images to assist in product identification and classification.

  4. Support declared values:
    Upload purchase orders, previous Bills of Entry, contracts, or remittance copies to substantiate declared transaction values.

  5. Declare technical parameters clearly:
    For electrical machinery (like transformers, motors, ferrite cores, or PCBs), specify wattage, voltage, frequency, and function to help accurate classification.

  6. Specify manufacturer details:
    For goods subject to anti-dumping duty, where rates depend on the manufacturer, documents identifying the manufacturer must be uploaded.

  7. Provide clear and complete descriptions:
    Avoid vague, cryptic, or overly technical descriptions. The “generic description” field should explain the product’s nature and intended use.

  8. Ensure compliance when claiming exemptions:
    Study conditions of exemption notifications carefully, and upload supporting evidence that proves eligibility.

  9. Fulfill statutory registration requirements:
    Obtain and upload registration certificates under relevant Acts or rules (e.g., BIS, LMPC, MTCTE) before filing the BE.

  10. Comply with BIS standards:
    For goods under mandatory BIS certification, ensure valid registration and upload proof to prevent import of substandard products.

  11. Submit data for monitored goods:
    For imports of steel, chips, and non-ferrous metals, provide required data on designated government portals and upload proof in e-Sanchit.

  12. Use correct document codes:
    While uploading, select appropriate document codes in e-Sanchit to help assessing officers verify faster.

  13. Reply to queries clearly and completely:
    When queries are raised, respond specifically with complete answers and mention IRNs of the related documents. Vague or incomplete replies cause repeated queries.

  14. Mention reasons for provisional assessment:
    If opting for provisional assessment under Section 18, clearly state the reasons (such as pending SVB investigation).


Indicative List of Supporting Documents

The circular also provides an illustrative list of documents generally required for Group 5ACM (Electrical Machinery) Bills of Entry, apart from the mandatory invoice, packing list, and Bill of Lading:

  • Purchase Order or Contract Copy
  • Freight Invoice
  • Product Catalogue / Technical Literature
  • End-Use Statement
  • Country of Origin Certificate
  • Preferential Trade Agreement documents (Form-I, Sections I–III, if applicable)
  • SVB Order (for related party imports)
  • Shipping Bill and export benefit reversal details (in case of re-imports)
  • BIS Registration Certificate
  • MTCTE Certificate (for telecom equipment)
  • WPC/ETA Certificate (for wireless products)
  • LMPC Certificate (for packaged goods)
  • High Sea Sale Agreement and Invoice (if applicable)
  • EPR Authorization for Plastic, E-waste, and Batteries
  • DGFT or other Special Import Licenses for restricted goods

It is also emphasized that this list is not exhaustive, and officers may seek additional documents depending on the product type and assessment requirements.


Conclusion: A Step Toward Greater Efficiency and Transparency

The circular by Commissioner Anil Ramteke, dated 29 October 2025, reinforces the collaborative nature of India’s Faceless Assessment framework. While Customs has invested heavily in digital infrastructure and process automation, the responsibility for accurate and timely clearance lies equally with the trade community.

By submitting complete, legible, and correctly tagged documentation through e-Sanchit, importers can minimize queries, reduce dwell time, and ensure faster cargo release. The instructions also help foster consistency, reduce disputes, and support India’s vision of a trade-friendly, transparent, and efficient Customs ecosystem.


In essence, the message is clear:
Good documentation is the foundation of quick clearance.
Faceless Assessment works best when both Customs and trade fulfill their roles responsibly.


*** 

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