Alerts & Updates 4th Nov 2025
Dear Reader,
We are writing to you with an important update concerning the Special Chemicals, Organisms, Materials, Equipment and Technologies (SCOMET) policy. The Directorate General of Foreign Trade (DGFT) has circulated a draft document containing Management System Requirements for Internal Compliance Program for the exports of dual-use items and is seeking stakeholder consultations.
| Background | The DGFT maintains the SCOMET list, which includes dual-use items i.e., the goods, software, and technologies that can be used for both civilian and military applications, including weapons of mass destruction. The list is organized into eight (8) categories. Export of SCOMET list items is permitted only with export authorization from the government, unless the item concerned is specifically exempted or prohibited for export. At present, the departments concerned, including the DGFT and the Department of Defence Production (DDP) prescribe separate application formats for seeking export authorisation, depending inter alia on the category of SCOMET item, end user, and end use type. |
| Draft ANF | The DGFT, vide Trade Notice No. 07/2025-26 dated October 31, 2025, has circulated the draft amended ANF proposing a single, consolidated format for seeking export authorisation for all categories of SCOMET items. This marks a shift from the existing practice, where different departments (such as DGFT and the DDP) prescribe separate formats. The draft ANF seeks to standardize and streamline the export authorisation process by introducing a unified application form applicable across categories such as technology, equipment, and general authorizations (e.g., GAEC, GAED, GAICT). The proposed format consolidates details inter alia relating to:
Through this initiative, the DGFT aims to simplify administrative processes, enhance traceability of applications, and promote consistency in data submission for SCOMET authorizations. |
| ELP’s Preliminary Remarks | ELP welcomes this initiative as a positive step towards harmonising India’s SCOMET export authorisation procedures. The introduction of a unified ANF reflects DGFT’s effort to create a more structured and transparent application process, which could reduce duplication of information and improve efficiency for both applicants and regulators. However, exporters should note that while a single ANF format is proposed, the underlying approval mechanism and inter-departmental coordination (particularly between DGFT, DDP, and other line ministries) may continue to require distinct scrutiny processes based on item category and end-use sensitivity. Accordingly, clear procedural guidance and harmonization between authorities will be essential to ensure the intended ease of compliance is achieved. |
| Way Forward/What should companies do? | While we at ELP would be making our comments to the DGFT, we would request Stakeholders to:
ELP would be happy to assist stakeholders in reviewing the draft form and preparing inputs for submission to the DGFT. |
For any queries or comments on this update, please feel free to contact us at elptrade@elp-in.com or the authors: sanjaynotani@elp-in.com, ambarishsathianathan@elp-in.com, harikabakaraju@elp-in.com and shantanusingh@elp-in.com.
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