Moowr registration regarding the query

[Mathi]

Dear Sir / Madam

We are Star export House holder and we are planning to move for MOOWR registration. In MOOWR registration, we need to submit trible duty bond for registration. As status holder shall get Exemption to submit the bond or should need need to submit the Bond . Please guide

[Sanjeev Agarwal]

Yes - if you are proposing to register your unit under MOOWR (Section 65 of the Customs Act), being a "Star Export House/Status Holder does not, by itself, exempt you from executing the triple-duty bond.

Position

Under the MOOWR framework, Regulation 4 of the Manufacture and Other Operations in Warehouse (No. 2) Regulations, 2019 requires the applicant to undertake to execute the prescribed bond.

More importantly, Section 59 of the Customs Act, 1962 requires the owner/importer of warehoused goods to execute a triple-duty bond. CBIC Circular No. 34/2019-Customs dated 1 October 2019 specifically clarifies that the bond prescribed in its Annexure C serves the requirements of both:

1. the MOOWR Regulations; and

2. Section 59 of the Customs Act. (Bangalore Customs)

Therefore:

Issue	Position
Star Export House / Status Holder	Does not automatically give exemption
MOOWR registration under Section 65	Bond required
Triple-duty bond under Section 59	Required
Separate MOOWR bond + triple-duty bond	Generally one prescribed bond (Annexure C) serves both requirements
Bank guarantee/security	Needs to be examined separately based on the applicable warehouse provisions

Important distinction

There are various benefits/concessions available to Status Holders under FTP/customs notifications, but those should not be automatically extended to the MOOWR triple-duty bond.

The MOOWR-specific CBIC clarification is quite direct: Section 59 requires the triple-duty bond for warehoused goods, and the prescribed MOOWR bond is designed to satisfy that requirement. (TaxGuru)

I also checked the materials available in your reference library, but they do not contain the specific MOOWR/Section 59 provision needed to establish a Status Holder exemption. The GST material on LUT/bond is a different bond regime and should not be confused with the MOOWR customs bond.

My recommendation for your case

Proceed on the basis that the triple-duty bond is required, unless your jurisdictional Customs Commissionerate gives you a specific written exemption/dispensation under an applicable notification or circular.

AI Summary

MOOWR registration bond requirement: status-holder export houses seek clarity on exemption from furnishing a three-times duty bond.
MOOWR registration is queried in relation to the requirement for a three-times duty bond. The issue concerns whether an export house holding status-holder recognition is exempt from furnishing that bond or must comply with the bond requirement when seeking registration.