Part Delivery of Out of Charged Cargo at CFSs - A Major Trade Facilitation Measure by JNCH.

Vide Public Notice No. 57/2026 dated 15.05.2026, issued by Jawaharlal Nehru Custom House, an important trade facilitation measure has been introduced permitting Container Freight Stations (CFSs) to allow 'part delivery' of cargo once the Bill of Entry has been granted Out of Charge (OOC) by the RMS Facilitation Centre, without requiring separate permission from Customs authorities.

This reform marks another significant step toward 'Ease of Doing Business', reduction of physical interface between trade and Customs, and improvement in logistics efficiency at India's largest container port.

Background of Earlier Procedure

Under Public Notice No. 184/2016 dated 02.01.2017, where imported cargo covered under a single Bill of Entry was intended to be cleared in multiple lots, importers were required to:

• Obtain Out of Charge (OOC) from RMS Facilitation Centre;
• Thereafter separately approach the AC/DC, Docks for permission for 'part delivery';
• Submit manual requests and supporting documents;
• Wait for approval before the CFS could release goods in parts.

Although the system ensured regulatory control, it resulted in:

• Additional procedural delays;
• Increased transaction costs;
• Unnecessary physical interaction with Customs officials;
• Congestion at CFSs and port premises;
• Delayed evacuation of cargo.

In modern supply chain operations, import consignments are often large and intended for staggered movement to factories, warehouses, project sites, or multiple branches. The earlier requirement for repeated permissions was inconsistent with digital customs clearance initiatives under RMS and faceless assessment.

Recognizing these operational challenges, JNCH has now delegated authority directly to CFSs to permit part delivery after OOC.

Key Highlights of Public Notice No. 57/2026

The Public Notice provides that:

• Once a Bill of Entry receives Out of Charge (OOC) from RMS Facilitation Centre;
• The jurisdictional CFS itself may allow part delivery of cargo;
• Importers are no longer required to obtain separate approval from AC/DC, Docks;
• CFSs must maintain proper records of such partial deliveries.

This reform substantially simplifies post-clearance logistics.

Need and Justification for the Facility

1. Alignment with Ease of Doing Business

The Government has consistently focused on reducing dwell time and transaction costs in international trade. Removal of redundant approvals directly supports:

• Faceless and paperless Customs;
• Faster cargo evacuation;
• Reduction in compliance burden.

2. Reduction in Logistics Congestion

Importers frequently face practical difficulties such as:

• Insufficient warehouse capacity;
• Limited truck availability;
• Production scheduling constraints;
• Multiple consignee locations.

Allowing staggered clearance avoids congestion at CFSs and facilitates smoother cargo movement.

3. Support for Manufacturing and Just-in-Time Supply Chains

Industries operating on lean inventory models often require phased inward movement of imported inputs. Part delivery enables:

• Better inventory management;
• Reduced warehousing costs;
• Timely production scheduling;
• Efficient working capital utilization.

4. Reduction in Human Interface

Earlier permissions required physical applications and interactions with Customs officers. The revised mechanism:

• Minimizes discretionary approvals;
• Improves transparency;
• Reduces administrative workload for Customs formations.

5. Better Utilization of Transport Infrastructure

Instead of arranging multiple containers/trailers simultaneously, importers can optimize transport movement based on operational requirements.

Procedure under GST Laws for Movement of Part Deliveries on Same Bill of Entry

While Customs law now permits part delivery without separate approval, GST compliance for movement of such goods remains equally important.

The following GST implications arise:

1. Bill of Entry as a Valid Tax-Paying Document

Under Section 16 of the CGST Act read with Rule 36 of CGST Rules, the Bill of Entry serves as a valid document for availing Input Tax Credit (ITC) of IGST paid on imports.

Even if goods are received in parts, the same Bill of Entry continues to remain the principal tax document.

2. Movement of Goods in Multiple Lots

Where imported goods are cleared in multiple lots from the CFS:

• Each movement constitutes a separate transportation event;
• Appropriate delivery documentation must accompany each lot.

Normally, importers maintain:

• Copy of Bill of Entry;
• Delivery challan/part delivery challan;
• Transport documents issued by CFS;
• Gate pass/warehouse release order.

3. Requirement of E-Way Bill for Part Deliveries

Applicability

Under Rule 138 of the CGST Rules, an E-Way Bill is required where:

• Movement of goods exceeds prescribed threshold value (generally Rs. 50,000);
• Goods are moved from CFS to factory/warehouse/place of business.

Accordingly, each part delivery generally requires generation of a separate E-Way Bill.

4. Documents for E-Way Bill Generation

Since the tax invoice may not exist at the time of import clearance, importers generally generate E-Way Bills based on:

• Bill of Entry; and/or
• Delivery Challan.

The following approach is commonly followed:

5. Separate E-Way Bill for Each Lot

Where cargo is cleared in phases:

• Separate E-Way Bills should ideally be generated for each vehicle/load;
• Quantity and taxable value should correspond to actual quantity moved.

This ensures proper reconciliation during audit and transit verification.

6. ITC Availment under GST for Goods Received in Lots

A very important issue arises regarding timing of ITC availment.

Relevant Legal Provision

Section 16(2) of the CGST Act provides that where goods are received in lots or instalments against a single invoice/document, ITC shall be available only upon receipt of the last lot or instalment.

Accordingly, in case of imported goods cleared through part deliveries:

• ITC of IGST paid on import should ideally be availed only after receipt of the final lot covered under the Bill of Entry.

This provision becomes particularly relevant where:

• Goods remain at CFS for staggered clearance;
• Deliveries are spread over multiple dates.

Practical Compliance Approach for Importers

Importers should maintain:

• Lot-wise delivery records;
• Vehicle-wise E-Way Bills;
• Gate passes issued by CFS;
• Quantity reconciliation statements;
• Final receipt confirmation for complete BOE quantity.

ITC should preferably be availed:

• Upon receipt of the final consignment/last lot;
• After ensuring full quantitative reconciliation with the Bill of Entry.

Suggested Documentation Matrix

Compliance Challenges and Safeguards

Though the relaxation is highly beneficial, importers and CFSs should exercise caution regarding:

• Proper quantity tracking;
• Prevention of duplicate deliveries;
• Matching of E-Way Bills with actual movement;
• Timely closure of pending BOE quantities;
• ITC timing compliance under Section 16(2).

CFSs must also maintain robust audit trails since responsibility for record maintenance has now been specifically cast upon them under the Public Notice.

Conclusion

Public Notice No. 57/2026 represents a progressive and pragmatic reform in customs cargo handling procedures. By authorizing CFSs to permit part delivery of OOC cargo without separate Customs approval, JNCH has significantly reduced procedural bottlenecks and improved trade facilitation.

The measure is expected to:

• Reduce cargo dwell time;
• Improve logistics efficiency;
• Lower compliance costs;
• Enhance port productivity;
• Strengthen India's Ease of Doing Business framework.

However, importers must simultaneously ensure proper GST compliance, particularly regarding:

• Generation of E-Way Bills for each movement;
• Maintenance of lot-wise records;
• Deferred availment of ITC until receipt of the final lot under the Bill of Entry.

The reform therefore balances operational flexibility with statutory accountability and reflects the continuing shift toward trust-based, technology-driven customs administration in India.