Sanguine Logistics Pvt. Ltd is an ISO 9001:2015 Certified Integrated Logistics Solution Provider & Indian Customs House Licensed Brokerage Company. With AEO Certification confirming our compliant & secure customs clearance processes, we strive to deliver logistics solutions with transparency, efficiency & innovation.
marketing@sanguinelogistics.com
+91 90439 99950
New Customs Regulation Alert : Export Entry Conversion Made Easier
The CBIC (Central Board of Indirect Taxes and Customs) has issued Notification No. 21/2025-Customs, introducing the Export Entry (Post Export Conversion in Relation to Instrument-Based Scheme) Regulations, 2025. This new regulation replaces the earlier 2022 regulations and brings in some much-needed clarity and structure to the process of converting export declarations after goods have been exported.
Why this is Important for Exporters?
In line with recent reform measures—like faster drawback credit, simplified AD code registration, and expanded RoDTEP benefits—this update simplifies the post-export amendment process while ensuring customs compliance. This is especially useful for exporters who missed claiming export incentives due to initial documentation errors or scheme mismatches.
🧾 What is Post Export Conversion?
Sometimes exporters file their shipping bills or export entries under one export benefit scheme, but later realize they could have availed better benefits under a different instrument-based scheme (like Advance Authorisation, EPCG, etc.).
This regulation allows exporters to amend or convert their export declaration (Shipping Bill, Post Parcel entry, Courier entry, etc.) after the export has taken place, provided certain conditions are met.
🔍 Key Highlights of the New Regulation
1. What Is “Export Entry”?
The term “Export Entry” now includes all types of export declarations, whether made under Shipping Bills, Courier Bills, or Post Parcels. This ensures that the new regulation covers all modes of export.
2. Extended Time Window for Changes
Exporters now have up to one year from the date of clearance (under Sections 51, 69, or 84 of the Customs Act) to apply for changes. In certain cases, this window can be extended by:
- ✔️ 6 months by the Commissioner of Customs, and
- ✔️ Another 6 months by the Chief Commissioner, with valid reasons recorded in writing.
For export entries filed before February 22, 2022, the one-year period starts from the regulation’s publication date (April 3, 2025).
3. Scope of Conversion
Exporters can request conversion:
- ✔️ From one instrument-based scheme to another (e.g., from Drawback to RoDTEP)
- ✔️ For entries made under Section 84 (Post and Courier modes)
- ✔️ From drawback to other schemes (subject to benefit reversal)
4. Conditions to be Met
- ✔️ The exporter must not have availed the benefits of the previous scheme or must reverse them.
- ✔️ Amendments can only be made based on documents that existed at the time of export.
- ✔️ The export must not be under any pending investigation or legal contravention.
- ✔️ The export entry should relate to an incentive scheme, drawback, export obligation, or their combination.
5. Specific Amendments Need Higher Approval
Certain sensitive changes to Shipping Bills (as per Customs Circular) require Additional/Joint Commissioner approval. These include:
- Port of Loading / Discharge
- Country of Final Destination
- AD Code / Invoice Value
- HS Code / Description / Quantity
For conversion of shipping bills to a different scheme (e.g., drawback to RoDTEP), approval from the Commissioner of Customs is required.
6. Digital Implementation
The update includes:
- ✔️ Electronic processing of amendments (Section 149)
- ✔️ Online handling of provisional assessments
- ✔️ Re-transmission of corrected export data to relevant agencies
The DG Systems will be releasing a detailed advisory shortly with technical implementation guidelines.
💼 What Are the Benefits?
- ✔️ Gives exporters flexibility if an error or change in strategy happens after export.
- ✔️ Helps maximize benefits from various incentive schemes.
- ✔️ Provides a structured, time-bound mechanism for rectifying genuine cases.
- ✔️ Increases compliance transparency and reduces disputes.
🚀 What Exporters Should Do???
- ✅ Review recent exports to identify any entries needing conversion
- ✅ Prepare supporting documentation that existed at the time of export
- ✅ Act within the time limits to ensure eligibility
- ✅ Coordinate with your CHA / Customs Broker for timely filing
This change offers a second chance to exporters who may have missed out on claiming the right scheme at the time of shipping.
📝 Conclusion
This amendment reflects CBIC’s intent to streamline post-export procedures and make benefit schemes more accessible — while also tightening compliance. If you’re an exporter, talk to your CHA or logistics partner to understand if any of your past shipments are eligible for this conversion.
At Sanguine Logistics, we help clients with documentation, customs processes, and post-export benefit claims. If you need assistance with conversion or any export-import matter — we’re here to help.
📧 Contact us today to review your exports and explore possible benefits!