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EPCG Scheme - DO’s & DON’Ts (Staff/Employees Training Guide)

YAGAY andSUN
EPCG Scheme internal compliance checklist for capital goods, export obligation monitoring, installation timelines and document control Article outlines internal compliance guidelines for staff handling capital goods under the EPCG Scheme. It emphasizes maintaining valid EPCG authorization, nexus certificate, installation certificate, and accurate HS codes, with complete and properly filed import and export documents. Capital goods must be installed within prescribed timelines, supported by a Chartered Engineer certificate and evidentiary records. Continuous monitoring of export obligation, timely communication with DGFT and Customs, and adherence to company SOPs and audit controls are required. Staff are prohibited from unauthorized sale, transfer, relocation, or delayed installation of EPCG machinery, from data mismatches or misdeclarations, and from ignoring notices, as non-compliance may trigger duty recovery, interest, and penalties. (AI Summary)

Below is a clean, one-page, staff-friendly EPCG Do’s & Don’ts sheet suitable for internal training, induction, and compliance awareness. You can copy/paste this into a PDF or poster format for your team

DO’s (What You MUST Do?)

1. Documentation & Approvals

Always verify that EPCG Authorization, Nexus Certificate, and IC are available and valid.

Ensure HS codes, model numbers, and specifications match across all documents.

Keep Bills of Entry, shipping bills, e-BRCs, and CA certificates properly filed.

2. Installation Compliance

Install imported capital goods within 6 months (or as approved).

Obtain a Chartered Engineer Installation Certificate with correct serial numbers.

Maintain photos, videos, and commissioning reports as evidence.

3. Export Obligation (EO) Monitoring

Track EO monthly and block-wise.

Ensure export invoices, shipping bills & e-BRCs are correct and consistent.

Alert the EPCG compliance officer immediately if EO shortfall is expected.

4. Communication & Updates

Coordinate between Import, Plant, Finance & DGFT teams.

Immediately inform ECO before shifting machinery or changing addresses.

Respond promptly to DGFT or Customs queries or deficiency letters.

5. Internal Controls

Maintain EPCG records for minimum 10 years.

Follow the company’s EPCG SOP and audit checklists.

Seek management approval for all EPCG-related decisions.

DON’Ts (What You MUST NOT Do?)

1. Machinery Handling

Do NOT sell, lease, relocate or transfer EPCG machinery without DGFT approval.

Do NOT install machinery at an address not mentioned in the EPCG authorization.

Do NOT allow machinery to remain uninstalled beyond the allowed timeframe.

2. Document Errors & Mismatches

Do NOT use incorrect or mismatched HS codes, model numbers or specifications.

Do NOT ignore missing export documents like e-BRCs or shipping bills.

Do NOT file EODC/redemption without reconciling export data.

3. Export Obligation Risks

Do NOT wait until the last year to start fulfilling EO.

Do NOT assume that EO extension is automatic—apply before deadline.

Do NOT count domestic sales or deemed exports toward EO unless permitted.

4. Non-Compliance Triggers

Do NOT ignore DGFT notices—penalties apply if not replied timely.

Do NOT delay filing Installation Certificate—this is a major reason for penalties.

Do NOT mis-declare EPCG number in Bills of Entry or export documents.

Key Reminder for All Staff

“Every EPCG import saves duty today — but must be justified through exports, installation & documentation tomorrow.” Failure to comply can lead to full duty + interest + penalties.

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