1. Verify HSN Classification on Your Import Bills of Entry
One of the most common — and costly — mistakes in Customs compliance is incorrect HSN code
classification. A 4-digit error can mean paying 10–22% excess Basic Customs Duty (BCD).
Action Steps
- Pull your last 5 Bills of Entry from ICEGATE
- Cross-check the HSN code against the Customs Tariff
- Check if a concessional rate applies under:
- Notification 50/2017-Customs (capital goods, project imports, specific sectors)
- Free Trade Agreements — India-ASEAN, India-Korea (CEPA), India-Japan (CEPA),India-UAE (CEPA)
Paid Excess Customs Duty?
File a refund claim under Section 27 of the Customs Act within 2 years of the date of duty payment.
2. Use MOOWR Scheme to Defer Customs Duty on Capital Goods Imports
Setting up a new manufacturing unit? Don’t pay Basic Customs Duty + IGST upfront and block your
working capital.
The MOOWR (Manufacture and Other Operations in Warehouse Regulations) scheme allows you
to:
- Import capital goods and raw materials duty-free into a bonded warehouse
- Manufacture finished goods in-bond
- Pay Customs duty only when clearing finished goods or even capital goods into domestic market
- Pay zero duty if you export the finished goods or even capital goods
How to Apply
- Identify your manufacturing premises
- Apply to your jurisdictional Commissioner of Customs
- Approval typically takes 30–45 days
Key Benefit: Unlike EPCG, MOOWR also defers Anti-Dumping Duty — see Point #4 below.
3. Submit e-BRC for Drawback Exports — Delays Can Cost More Than the Benefit
If you’ve claimed Duty Drawback on export of goods, you must submit the e-Bank Realisation
Certificate (BRC) to Customs within the prescribed with 9 months of exports
Consequences of Non-Submission
- Recovery of the entire Drawback amount
- Interest at 15% p.a.
- Penalty proceedings under Customs Act
4. EPCG Won’t Save You from Anti-Dumping Duty — But MOOWR Will
Importing capital goods under the EPCG (Export Promotion Capital Goods) scheme? You get
exemption from Basic Customs Duty (BCD), but Anti-Dumping Duty (ADD) is still payable in full.
The Problem
Many importers assume EPCG covers all duties. It doesn’t. If your capital goods are subject to Anti-
Dumping Duty, you’ll pay ADD even under EPCG.
The Solution: MOOWR
Under MOOWR, even Anti-Dumping Duty is deferred. If you export such capital goods after their life
time, ADD is never payable.
When to Choose MOOWR Over EPCG
- mporting goods subject to ADD
- Want to defer duties rather than take permanent exemption with export obligation
5. Your Exported Goods Got Rejected? Here’s How to Bring Them Back Duty-Free
If your buyer rejects the goods or the shipment fails quality inspection abroad, you can re-import
without paying Customs Duty — but only if you follow the correct procedure.
Conditions for Duty-Free Re-Import
- Re-import must happen within 3 years of export (extendable to 5 years)
- Goods must be the same as originally exported — no alteration abroad
Process
- File Bill of Entry for re-import citing Notification 45/2017-Customs
- Ensure shipping bill and Bill of Entry are linked
- Provide rejection/return documentation to Customs
Caution: If goods were altered or repaired abroad (not just rejected), different rules apply — duty
may be payable on the value of repairs.
6. Claim FTA Benefits — Even Retrospectively
Imported goods from ASEAN, Korea, Japan, or UAE without claiming the Free Trade Agreement
concessional duty rate? You may have paid 5–15% more than necessary.
Good News
You may claim FTA benefits retrospectively by filing a refund application under Section 27 of the
Customs Act within 2 years of duty payment, if it is allowed in the specific FTA between India and FTA
trading country
For Future Imports- Set up a compliance checklist with your CHA to ensure COO is obtained before
shipment. Key FTAs to consider:
Frequently Asked Questions
What is MOOWR scheme and how does it save Customs duty?
MOOWR (Manufacture and Other Operations in Warehouse Regulations) allows you to import capital
goods and raw materials duty-free into a bonded warehouse, manufacture in-bond, and pay
Customs duty only when clearing finished goods into domestic market. If you export the finished
goods, duty on raw material is never payable. Unlike EPCG, MOOWR also covers Anti-Dumping Duty.
EPCG vs MOOWR — which is better?
It depends on your situation. EPCG provides permanent BCD exemption but doesn’t cover Anti-
Dumping Duty and has export obligation. MOOWR defers all duties (including ADD) until domestic
clearance, with no duty if you export. MOOWR is often better for exporters and when importing
goods subject to ADD.
Need Help Implementing These Savings?
Every business has a unique GST and Customs profile. What works for a manufacturer may not apply
to a service exporter or trader.
If you’d like us to run a quick diagnostic on your GST and Customs position, reach out with your
GSTIN and a brief description of your import/export activity. We’ll flag specific opportunities you
might be missing.