Faceless Assessment in Indian Customs: Trade Challenges and the Need for Practical Reforms

Introduction

In recent years, the Indian Customs system has undergone significant changes, mainly due to digital reforms aimed at making customs processes more transparent, efficient, and business-friendly. A key reform is the 'Faceless Assessment' system introduced as part of the 'Truant Customs' program. This system aims to reduce the need for in-person meetings between trade stakeholders and customs officers, improve assessment consistency, shorten clearance times, and promote a technology-based customs process. With Faceless Assessment, import documents submitted at one customs location can be evaluated by officers anywhere in the country through special Faceless Assessment Groups (FAGs).

While this reform modernises customs procedures, it has also led to various problems for importers, exporters, and customs brokers. These issues include delays, repetitive questions, inconsistent assessments, disputes over how goods are valued, and communication difficulties. This article will discuss the challenges trade stakeholders face with Faceless Assessment and suggest practical reforms to improve its effectiveness.

Objectives Behind Faceless Assessment

The Faceless Assessment system was introduced with several key goals:

• Reduce direct contact between trade and customs officers
• Increase transparency in customs assessments
• Ensure consistent classification and valuation of goods
• Speed up cargo clearance
• Limit individual officer discretion and local influence
• Develop a technology-driven national assessment approach

Although the initiative seems progressive and aligns with international customs practices, there are still challenges in its implementation.

Lack of Technical Understanding of Imported Goods

One major problem for importers is that customs officers assessing their goods often lack technical knowledge of the products. Many imported items, such as specialised machinery, chemicals, electronic parts, and medical devices, require specific technical expertise for accurate classification and valuation. Officers unfamiliar with these industries often ask vague or repetitive questions, even when detailed information has been provided, causing unnecessary delays and increasing the importer's compliance burden. In many cases, importers need to repeatedly explain the nature and purpose of their goods, even when similar items were previously approved without issues. Implementing a specialised assessment mechanism and improving officer training could help reduce these disputes.

Excessive and Repetitive Queries

Another common problem is the officer's tendency to ask too many repetitive questions. Importers frequently have to resubmit documents that have already been uploaded through online systems such as ICEGATE and e-Sanchit. This often results in multiple rounds of fragmented queries instead of a single comprehensive list. Examples of these repeated requests include:

• Product catalogues
• Manufacturer details
• Chartered Engineer certificates
• End-use declarations
• Documentation for valuation justification
• Price list

These excessive queries delay the clearance process, increase costs, disrupt supply chains and defeat the objective of the scheme. A standardised approach to queries and holding officers accountable for unnecessary delays is necessary to improve trade situations.

Delay in Customs Clearance

One of the main advantages of Faceless Assessment was supposed to be quicker customs clearance for imported goods. However, delays remain a significant issue for traders. Assessment delays are especially common for:

• Machinery imports
• Chemical shipments
• Special Valuation Branch-related transactions
• Exemption notifications
• Valuation disagreements
• Initial inspections
• Rules of Origin Criteria
• PGA-related consignments

Since assessments are conducted by officers at various locations, coordination problems frequently occur, resulting in lengthy wait times. Delays in responding to inquiries, requests for reassessment or amendments to the bill of entry, or in selecting and examining cargo can cause shipments to remain at customs for extended periods, raising costs and disrupting manufacturing schedules. An effective monitoring and tracking system with defined timelines, transparent procedures, and escalation protocols is essential to address these delays. The current TSK (Truant Seva Kendra) is insufficient to meet the needs of importers and other stakeholders.

Inconsistent Classification Practices

Faceless Assessment was intended to create uniformity in customs evaluations nationwide. However, in practice, variations in classification still occur. Similar goods are sometimes classified differently by different assessment groups, leading to confusion and inconsistencies. This undermines the intended goals of the Faceless Assessment system.

By addressing these issues, the Faceless Assessment can truly enhance the efficiency and reliability of the customs process in India.