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Export Obligation (EO) for EPCG Licenses reduced proportionately for FY 24-25

Vivek Jalan
EPCG export obligation reduction applies proportionately for declining sectors, with endorsement and recordkeeping requirements for discharge applications. Export obligation under EPCG licences is to be reduced proportionately for FY 2024-25 where the relevant sector or product group has recorded an export decline of more than 5 per cent compared with FY 2023-24. Where the decline has continued over consecutive years, the year after the decline began is treated as the base year for comparison. Regional Authorities are to re-fix the annual average export obligation on a proportionate basis and record the reduction in the licence file and amendment sheet. (AI Summary)

Under Customs, Policy Circular No. 10/2025-26 dated 26.02.2026 is a significant compliance update for EPCG license holders. Let's break it down into a structured, operational checklist for quick application in practice:

Compliance Checklist: EO Reduction under Para 5.17 (FTP 2023)

1. Eligibility

Check if your sector/product group exports declined >5% in FY 2024-25 compared to FY 2023-24.

If decline is continuous over consecutive years, use the year after which decline began as the base year.

2. DGFT Communication

DGFT will notify Regional Authorities (RAs) of eligible sectors/product groups within 7 months of FY close.

Refer to Policy Circular No. 10/2025-26 (26.02.2026) for the official list of product groups with decline percentages.

3. Action by Regional Authorities

RAs will re-fix annual average EO proportionately for FY 2024-25.

Reduction must be endorsed in:

  • License file
  • Amendment sheet issued to EPCG Authorisation holder

4. Exporter's Responsibility

Ensure EO reduction endorsement is reflected in your license records.

While applying for EO discharge (EODC):

5. Risk Mitigation

Maintain documentation of sector decline (DGFT circular + export data).

Keep a check-sheet for EODC applications to ensure Para 5.17 relief is applied.

If EO shortfall exists, rely on cumulative relief provisions across past FTPs.

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