Welcome To Dwarkadhish Overseas Private Limited
DGFT, Customs and Export Compliance Support Across India
EPCG Authorisation, Compliance and EODC Closure Services in India
Import or procure eligible capital goods under the Export Promotion Capital Goods Scheme and manage every compliance requirement from the initial DGFT application to final Export Obligation discharge and Customs closure.
Dwarkadhish Overseas assists manufacturers, merchant exporters and eligible service providers with EPCG eligibility, Chartered Engineer nexus certification, application filing, Customs registration, installation, amendments, Export Obligation monitoring, extensions, reconciliation, regularisation, EODC and release of the Customs Bond, LUT or Bank Guarantee.
What Is an EPCG Authorisation?
An EPCG Authorisation is the approval issued by DGFT permitting an eligible applicant to import or procure specified capital goods against an Export Obligation.
The authorisation may record:
IEC holder
Applicant branch
Capital-goods description
ITC-HS classification
Quantity and value
Duty Saved Amount
Export product or service
Specific Export Obligation
Average Export Obligation
Installation premises
Supporting manufacturer
Port of registration
Applicable conditions
Import-validity period
Export-obligation period
The application for a new EPCG Authorisation is filed in ANF 5A with the prescribed supporting records.
What Is the EPCG Scheme?
EPCG stands for Export Promotion Capital Goods.
The scheme facilitates the import of eligible capital goods for pre-production, production and post-production at zero Customs duty, subject to the negative list and specific conditions in Appendix 5F.
Capital goods imported against physical exports can also receive exemption from IGST and Compensation Cess under the applicable Department of Revenue notification. Eligible capital goods can alternatively be procured from indigenous manufacturers through the prescribed process.
EPCG Licence Versus EPCG Authorisation
“EPCG Licence” is the expression commonly used by exporters, manufacturers, banks and Customs professionals.
The formal terminology used by DGFT is:
EPCG Authorisation
Both terms can be included naturally for SEO, but official applications, DGFT filings, amendments and EODC documentation should use the term EPCG Authorisation.
capital
What Capital Goods Can Be Covered Under EPCG?
Subject to the policy, capital-goods definition, technical nexus and Appendix 5F restrictions, EPCG can cover:
Capital goods in complete form
Capital goods in CKD or SKD condition
Machinery
Production equipment
Pre-production equipment
Post-production equipment
Computer systems forming part of imported capital goods
Software forming part of imported capital goods
Spares
Moulds
Dies
Jigs
Fixtures
Tools
Refractories
Catalysts for the initial charge
Catalysts for one subsequent charge
The proposed goods must have a demonstrable nexus with the goods to be exported or services to be rendered.
Capital Goods Not Permitted or Restricted Under Appendix 5F
Appendix 5F contains capital goods that are not permitted or are permitted only for specified sectors or uses.
Capital goods
Current EPCG position
Cables
Permitted only as an integral part of capital goods
Railway wagons, except specified specialised tractors
Not permitted
Tractors
Not permitted
Trucks, tippers and dumpers
Permitted only for the mining sector
Motor cars and SUVs
Not permitted
Airport ground-handling equipment
Not permitted
Furniture and certain interior items
Limited to specified hotel-industry use
Construction equipment such as cranes
Permitted only for providing services
Construction material such as sheds, cement and steel
Not permitted
Standalone computers and printers
Not permitted
Second-hand capital goods
Not permitted
Standalone computers and printers
Not permitted
Capital goods for export or supply of electrical power
Not permitted under the specified entries
Certain PUF panels and doors
Permitted only for specified chilled-room or cold-storage uses
The current Appendix 5F must be reviewed before confirming the machinery order, making an advance payment or filing the EPCG application.
Eligibility
Who Can Apply for EPCG?
The EPCG Scheme covers:
- Manufacturer exporters
- Manufacturer exporters with supporting manufacturers
- Merchant exporters tied to supporting manufacturers
- Service providers
- Eligible Common Service Providers
- Eligible EOU or relocated SEZ units converting to DTA
Where a merchant exporter uses a supporting manufacturer, the supporting manufacturer must be correctly endorsed before installation of the capital goods at its premises.
Manufacture
Manufacturer Exporter EPCG
A Manufacturer Exporter can apply where the capital goods will be installed and used for manufacturing the goods endorsed for export.
The application should establish:
- Manufacturing premises
- Production process
- Existing machinery
- Proposed capital goods
- Technical capacity
- Export product
- Machinery-to-export-product nexus
- Current export performance
- Ability to meet EO
Documents may include:
- Factory licence
- Udyam Registration
- Industrial licence or IEM
- GST Registration
- Production-process note
- Existing machinery list
- Machinery quotation
- Technical literature
- Export records
- Chartered Engineer nexus certificate
merchant
Merchant Exporter EPCG
A Merchant Exporter can apply when tied to an eligible supporting manufacturer.
The supporting manufacturer’s name should be endorsed before installation at its premises.
The application may require:
- Merchant Exporter IEC
- Supporting manufacturer GSTIN
- Supporting manufacturer factory details
- Industrial registration
- Manufacturing-process note
- Authorisation or agreement between the parties
- Export-product details
- Machinery-installation location
- Chartered Engineer nexus certification
A pure trading structure without a genuine supporting manufacturing arrangement should not be presented as an eligible EPCG manufacturing case.
Service
EPCG for Service Providers
Eligible service providers may apply where the capital goods have a direct nexus with the export or supply of the permitted service.
Examples can include qualifying:
- Hospitality services
- Healthcare services
- Testing services
- Technical services
- Construction or equipment-based services
- Logistics-related services
- Professional or infrastructure-based services
Eligibility depends on:
- Service activity
- Capital-goods use
- Service-export evidence
- Foreign-exchange earnings
- Installation location
- Applicant category
- Appendix 5F restrictions
- Specific and Average EO feasibility
common
Common Service Provider EPCG
The policy can cover a Common Service Provider certified by DGFT Headquarters in a Town of Export Excellence or a PM MITRA Park.
Conditions include:
- Capital goods installed within the applicable approved area
- Users identified to the Regional Authority
- EPCG details mentioned in the relevant export documents
- Exports counted only once
- Bank Guarantee equivalent to Duty Saved Amount, subject to the applicable conditions
- Ordinary common utility services such as electricity, water, sanitation or telecommunication are excluded from this facility
Eligibility
Basic EPCG Eligibility Requirements
An applicant should generally have:
- Active IEC
- Updated DGFT profile
- Valid RCMC where applicable
- Correct GSTIN and branch details
- Eligible Manufacturer, Merchant or Service Provider status
- Identified capital goods
- Machinery quotation or Proforma Invoice
- Technical specifications
- Proposed installation address
- Identified export product or service
- Nexus between machinery and exports
- Chartered Engineer certification
- Existing or projected export capacity
- Ability to complete Specific EO
- Ability to maintain Average EO
- Suitable Customs port of registration
- No disabling DGFT or Customs restriction
common
Chartered Engineer Nexus Certificate
A new EPCG application requires a nexus certificate from an independent Chartered Engineer in Appendix 5A.
The Chartered Engineer examines:
- Capital-goods description
- Model number
- Technical specifications
- Quantity
- Proposed installation location
- Manufacturing or service process
- Export product or service
- Stage at which machinery will be used
- Reasonable installation wastage, where applicable
The engineer must act within the engineer’s professional area of competence.
Checklist
Documents Required for a New EPCG Authorisation
The checklist depends on the applicant, capital goods, sector and proposed EO.
Document or information
Purpose
IEC Certificate
DGFT identification
GST Registration
Business and installation-unit verification
RCMC
Export-sector registration
PAN and constitution documents
Legal-entity verification
Authorised-signatory details
Application signing
Technical literature
Nexus and classification
Capital-goods ITC-HS code
Import classification
Existing machinery list
Capacity and nexus assessment
Manufacturing-process flow
Chartered Engineer assessment
Export-product or service details
EO endorsement
Export-product ITC-HS code
Product identification
Previous three years’ export data
Average EO calculation
Current-year export data
EO feasibility
Existing EPCG details
Outstanding obligation disclosure
Installation-location documents
Actual User location
Chartered Engineer certificate
Appendix 5A nexus
Supporting manufacturer documents
Merchant Exporter application
Port of registration
Customs registration
EFC approval
Restricted capital goods or export items
Development Commissioner NOC
Applicable EOU or SEZ conversion case
Our Process
Status Holder Certificate Application Process
Eligibility assessment
We review: Applicant category, Capital-goods eligibility, Appendix 5F restrictions, Import classification, Export product or service, Existing export performance, Estimated Duty Saved Amount, Specific EO, Average EO, Import and installation plan.
Duty-saving calculation
We estimate: Assessable value, Basic Customs Duty, Applicable duties, taxes and cess, Estimated net Duty Saved Amount, Proposed CIF value, Specific Export Obligation .
Export-obligation assessment
We calculate: Specific EO, Average EO, First-block target, Balance EO, Applicable reduced-EO benefit, Expected export requirement.
Chartered Engineer certification
The capital-goods nexus, manufacturing or service process and technical justification are documented.
ANF 5A preparation
The application is prepared with: Capital-goods details, Export-item or service details, Installation premises, Supporting manufacturer, Duty calculation, Port of registration, ector classification, Indigenous-procurement request, where applicable, Supporting documents.
Electronic signing and fee payment
The application is digitally signed and the prescribed DGFT application fee is paid.
DGFT review
Any deficiency concerning machinery, nexus, value, classification, export item, manufacturer or supporting documents is answered.
Authorisation issuance
After approval, the EPCG Authorisation and condition sheet are downloaded and verified.
Customs registration
The authorisation is registered at the approved Customs port before duty-free import clearance.
Fee
EPCG Government Application Fee
The current application-fee structure is: ₹1 per ₹1,000, or part thereof, of the Duty Saved Amount. subject to: Minimum fee: ₹500, Maximum fee: ₹1,00,000
The fee is payable separately from professional, Chartered Engineer and Customs-related charges.
Duty Saved Amount
Indicative DGFT fee
₹50 lakh
₹5,000
₹1 crore
₹10,000
₹2 crore
₹20,000
₹5 crore
₹50,000
₹10 crore or more
Maximum ₹1,00,000
EPCG Professional Charges
New EPCG Authorisation
The starting professional fee applies to a standard scope involving:
₹
29,999
/ starting*
- One legal entity
- One proposed installation location
- Clearly identified capital goods
- Standard technical nexus
- Available export records
- No restricted capital goods
- No complex existing EPCG default
- Standard application filing and deficiency support
Separately chargeable items
- DGFT application fee
- Chartered Engineer certificate
- CA, CMA or CS certification
- Customs registration
- Bond or LUT preparation
- Bank Guarantee work
- Multiple machinery groups
- Multiple installation locations
- Supporting-manufacturer endorsement
- EFC approval
- Indigenous procurement
- Invalidation or ARO
- Installation Certificate
- Amendments
- EO monitoring
- Block-wise reporting
- EO extension
- Clubbing
- Regularisation
- EODC
- Customs Bond closure
- Site visits
- Legal representation
Pricing disclaimer
₹29,999 is the starting professional fee for standard EPCG Authorisation application assistance. DGFT fees, Chartered Engineer charges, professional certifications, Customs charges, statutory payments, travel and other services are separate. Approval, Customs registration, EO extension and EODC cannot be guaranteed.
Import Validity of EPCG Authorisation
An EPCG Authorisation is valid for import for 24 months from the date of issue. The current FTP states that revalidation of the EPCG Authorisation is not permitted.
Important planning points
Before the 24-month period expires, the exporter should plan:
- Machinery supplier
- Purchase contract
- Advance payment
- Shipment
- Bill of Lading
- Customs registration
- Bill of Entry
- Import clearance
- Capital-goods installation
An expired EPCG Authorisation cannot ordinarily be revalidated for additional imports under the current FTP.
Actual User Condition
Capital goods imported under EPCG remain subject to the Actual User condition until:
- Export Obligation is completed, and
- EODC is issued
The machinery should not be freely sold, transferred or disposed of before the applicable conditions are fulfilled.
Registration of EPCG Authorisation at Customs
The EPCG Authorisation is issued with a single port of registration for imports. Exports for EO fulfilment may be made through permitted ports under the applicable procedure.
Customs-stage assistance may include
- DGFT-to-ICEGATE transmission review
- Port registration
- IEC and GSTIN verification
- Authorisation-condition review
- Bond or LUT
- Bank Guarantee
- Capital-goods matching
- Duty-debit monitoring
- Bill of Entry verification
- Customs-query response
- Actual Duty Saved reconciliation
Installation Certificate
The current amended HBP permits submission of the Installation Certificate within three years from completion of import.
The certificate may be issued by:
- Jurisdictional Customs authority, or
- Independent Chartered Engineer
Where the exporter uses an independent Chartered Engineer, a copy should also be sent to the jurisdictional Customs authority.
The Regional Authority may permit delayed submission up to the valid EO period on payment of ₹10,000 for each year of extension.
Installation Certificate documents
- EPCG Authorisation
- Condition sheet
- Bills of Entry
- Machinery invoices
- Packing lists
- Machinery serial numbers
- Installation address
- Photographs
- Production-process information
- Chartered Engineer report
- Existing machinery details
- Customs intimation
Our Installation Certificate service
- Completion-of-import date review
- Capital-goods reconciliation
- Serial-number verification
- Installation-location verification
- Chartered Engineer coordination
- Capital-goods reconciliation
- Certificate preparation
- DGFT submission
- Customs intimation
- Delayed-filing assessment
Shifting Capital Goods to Another Unit
Capital goods can be shifted during the EO period to another eligible unit recorded in the IEC and RCMC.
A fresh Installation Certificate should be submitted within six months of the shifting.
Before shifting machinery, review:
- New unit’s IEC record
- GSTIN
- RCMC
- DGFT amendment
- Customs intimation
- Supporting-manufacturer endorsement
- Fresh installation timeline
EPCG Export Obligation
The standard Specific Export Obligation is:
Six times the duties, taxes and cess saved
It must ordinarily be fulfilled within:
Six years from the EPCG Authorisation issue date
The authorisation is also generally subject to an Average Export Obligation.
Specific Export Obligation
Specific EO is directly linked with the Duty Saved Amount under the EPCG Authorisation.
Specific EO = Duty Saved Amount × 6
Example
Suppose:
- Duty Saved Amount: ₹50 lakh
- EO multiplier: Six times
Then:
Specific Export Obligation = ₹50 lakh × 6
= ₹3 crore
This is generally in addition to the maintenance of the applicable Average Export Obligation.
Average Export Obligation
Average EO is normally based on the arithmetic mean of exports of the same or similar products during the preceding three licensing years.
The Average EO must generally be maintained during each financial year until the obligation is completed.
Only exports above the Average EO are ordinarily counted toward the Specific EO.
Why this matters
A company may have substantial export turnover but still fail EPCG compliance where:
- Annual exports fall below the prescribed average
- Exports above the average are insufficient for Specific EO
- Export products do not match the endorsed products
- Exports belong to another unit or IEC
- eBRC or realisation records are missing
versus
Specific EO Versus Average EO
- Particular
- Specific EO
- Average EO
- Basis
- Duty Saved Amount
- Historical export performance
- Standard amount
- Six times Duty Saved
- Average of preceding three years
- Time period
- Normally six years
- Maintained during applicable EO period
- Product
- Endorsed goods or services
- Same or similar goods or services
- Monitoring
- Authorisation-specific
- Financial-year and block-specific
- EODC impact
- Must be fulfilled or regularised
- Must be maintained or adjusted
Fulfilment
Block-Wise Fulfilment of Export Obligation
Under the current EPCG framework, Specific EO is divided into two blocks:
Period from issue date
Minimum Specific EO
First to fourth year
50%
Fifth and sixth year
Balance EO
The holder should intimate the Regional Authority regarding Specific and Average EO fulfilment within three months of completing the block.
1st block Extension
Composition fee when filed within six months
A request for extension of the first block should ordinarily be submitted within six months after the first block expires.
Duty Saved Amount
Composition fee
Up to ₹2 crore
₹5,000
Above ₹2 crore and up to ₹10 crore
₹10,000
Above ₹10 crore
₹15,000
Composition fee after six months but within six years
Duty Saved Amount
Composition fee
Up to ₹2 crore
₹10,000
Above ₹2 crore and up to ₹10 crore
₹20,000
Above ₹10 crore
₹30,000
Separate regularisation fees can apply where the application is made after the six-year period.
EPCG Export Obligation Report
The holder must submit an online report after expiry of the first four-year block and continue reporting until the valid EO period expires.
The report can contain:
- Shipping Bill number and date
- Export invoice
- Bill of Export
- FIRC
- eBRC
- Export product or service
- Specific EO value
- Average EO value
The statement must be certified by a Chartered Accountant, Cost Accountant or Company Secretary.
Our EO-reporting service
- Authorisation-wise export statement
- Shipping Bill mapping
- nvoice mapping
- eBRC review
- FIRC review
- Specific EO calculation
- Average EO calculation
- First-block fulfilment
- Shortfall identification
- Professional-certification coordination
- Online report filing
Which Exports Can Count Toward EPCG EO?
Subject to the applicable conditions, EO may be fulfilled through:
- Direct physical exports
- Permitted third-party exports
- Eligible deemed exports
- Eligible exports under Advance Authorisation
- DFIA exports
- Duty Drawback exports
- RoSCTL exports
- RoDTEP exports
- Eligible services
- Royalty receipts in freely convertible currency
- Foreign-exchange receipts for R&D services
- Permitted Rupee realisations
- Certain ITA-I supplies
- Eligible supplies to SEZ units
The same export should not be improperly counted more than once.
Third-Party Exports Under EPCG
Third-party exports can be counted where the prescribed documentation and manufacturing conditions are met.
Records may need to show:
- EPCG Authorisation holder
- Supporting manufacturer
- Third-party exporter
- EPCG Authorisation number
- Shipping Bill
- GST invoice
- eBRC or realisation evidence
- Movement of goods
- Production at the approved premises
- Payment from third party to the authorisation holder
- Disclaimer against duplicate EO use
The export documents must accurately identify the relevant parties and EPCG Authorisation.
Reduced Export Obligation
Certain eligible cases can receive reduced Specific EO.
Indigenous procurement
Specific EO is 25% lower than the standard EO.
Green Technology products
Specific EO is 75% of the standard EO.
North Eastern States, Jammu and Kashmir and Ladakh
For qualifying manufacturing units, Specific EO is 25% of the standard EO.
Early EO fulfilment
Where at least 75% of Specific EO and 100% of the applicable Average EO have been completed in half or less than half of the original EO period, the balance Specific EO may be condoned and the authorisation redeemed.
Only one of the specified overlapping benefits is ordinarily available.
Exemption From Average Export Obligation
Qualifying exports in the following sectors can be exempt from Average EO:
- Handicrafts
- Handlooms
- KVIC industries
- Agriculture
- Aquaculture
- Fisheries
- Pisciculture
- Animal husbandry
- Dairying
- Floriculture
- Horticulture
- Poultry
- Viticulture
- Sericulture
- Carpets
- Coir
- Jute
The exemption does not apply to specified fishing trawlers, boats, ships and similar items.
Capital goods, except tools, imported under this exemption may also remain subject to a five-year transfer restriction even after EO completion.
Indigenous Procurement Under EPCG
An EPCG holder can procure eligible capital goods from an Indian manufacturer through:
- Invalidation Letter, or
- Advance Release Order
For indigenous procurement:
- EO is calculated using notional Customs duties, taxes and cess saved on the FOR value
- Specific EO is 25% lower than the ordinary Specific EO
- Average EO remains unchanged where applicable
- The domestic manufacturer may be eligible for applicable deemed-export treatment
Our indigenous-procurement service
- Supplier and machinery review
- Capital-goods details
- Duty-saving calculation
- Invalidation request
- ARO coordination
- Domestic supplier mapping
- EO recalculation
- Installation records
- EODC documentation
EPCG Amendments
An issued EPCG Authorisation may require amendment relating to:
- Capital-goods addition
- Capital-goods deletion
- Capital-goods description
- Quantity
- Value
- ITC-HS code
- Export-product addition
- Export-product deletion
- Service addition
- Installation addres
- Supporting manufacturer
- Port of registration
- Sector classification
- Duty Saved Amount
- Company information
Import-item amendment
An amendment to the import list can be requested while the authorisation remains valid for import.
A fresh Chartered Engineer nexus certificate and justification may be required.
Export-item amendment
An amendment to export goods or services can be requested while the EO period remains valid and the capital goods have nexus with the new export item.
Automatic Reduction or Enhancement Based on Utilisation
Where actual Duty Saved utilisation differs from the authorised value:
Excess utilisation up to 10%
The authorisation can be treated as automatically enhanced proportionately.
The exporter must pay the additional application fee at the time of EODC, and the EO increases proportionately.
Excess utilisation above 10%
Regional Authority approval may be required, together with additional BG or LUT.
Lower utilisation
Specific EO is reduced proportionately with reference to actual utilisation.
obligation
EPCG Export Obligation Monitoring
EPCG compliance should be monitored throughout the six-year period rather than reviewed only when the authorisation is nearing expiry.
Our monitoring dashboard can track
Authorisation number
Issue date
Import-validity date
EO expiry date
Duty Saved Amount authorised
Actual Duty Saved utilisation
Capital-goods imports
Indigenous procurement
Original Specific EO
Revised Specific EO
Average EO
Annual export performance
Shipping Bills
Export invoices
eBRC
FIRC
Third-party exports
First-block target
First-block fulfilment
Balance EO
Installation Certificate
Extensions
Amendments
Customs Bond status
EODC readiness
Deliverables
Monthly or quarterly EPCG MIS
Shipping Bill-wise export statement
Average EO report
Specific EO report
Block-wise compliance report
Expiry alerts
Shortfall alerts
Missing-eBRC report
Missing-installation-certificate report
EODC-readiness report
Composition Fee
EPCG Export Obligation Extension
For authorisations governed by the current extension framework, the Regional Authority may consider: Two extensions of one year each, or, A two-year extension in one application.
The extension can take the EO period from six years up to eight years, subject to the prescribed fees and timelines.
Duty Saved Amount
Composition fee
Up to ₹2 crore
₹20,000
Above ₹2 crore and up to ₹10 crore
₹30,000
Above ₹10 crore
₹60,000
Application timing
The request should ordinarily be made within six months after expiry of the original EO period.
A request filed after six months but within the extendable period may attract a late fee of ₹10,000.
A regularisation request from the sixth to eighth year made after expiry can attract a late fee of ₹15,000 in addition to the applicable composition fee.
The ordinary Regional Authority route does not permit an extension beyond eight years from the Authorisation issue date.
Temporary 2026 EPCG Extension
For EPCG Authorisations where the original or extended EO period was expiring between 1 March 2026 and 31 May 2026, the period was automatically extended to 31 August 2026.
The same relief was introduced for qualifying block-wise EO periods expiring during that period.
No composition fee was required for this automatic extension.
Website update instruction
Remove or revise this section after 31 August 2026 unless DGFT issues a further extension.
Relief in Average Export Obligation
Where exports of a sector or product group decline by more than 5% compared with the preceding year, DGFT may provide a proportionate reduction in Average EO for the affected sector.
The eligible sector or product groups are communicated separately for the relevant year.
Our Average EO relief review
- Product-group identification
- Sector notification review
- Export-decline percentage
- Original Average EO
- Revised Average EO
- Authorisation-wise impact
- Regional Authority request
- EODC calculation
Maintenance of Average Export Obligation
Excess exports made toward Average EO during one year can be used to offset a shortfall in another year, provided the Average EO is maintained on an overall basis within the applicable block or EO period.
This makes year-wise reconciliation essential before assuming an Average EO default.
EPCG Clubbing
Two or more EPCG Authorisations issued to the same holder may be clubbed where the applicable conditions are satisfied.
Current core conditions include:
- Same authorisation holder
- Same or similar export products
- Authorisations issued by the same Regional Authority
- Application in ANF 5C
After clubbing:
- Duty Saved Amounts are consolidated
- EO is refixed
- The authorisations are treated as one
- The EO period is generally reckoned from the earliest Authorisation issue date
- The applicable Average EO must be reviewed
Our clubbing service
- Authorisation eligibility review
- Export-product comparison
- Duty Saved consolidation
- Specific EO recalculation
- Average EO review
- ANF 5C preparation
- DGFT filing
- Post-clubbing EODC preparation
EPCG Redemption and EODC
EODC stands for Export Obligation Discharge Certificate.
After completing the applicable Specific and Average Export Obligations, the holder applies online for redemption in ANF 5B.
The application must be supported by the professional certificate in Appendix 5C.
After satisfaction, the Regional Authority issues EODC and transmits it electronically to ICEGATE for action by the jurisdictional Customs authority where the BG or LUT was executed.
Documents Required for EPCG EODC
Core records
EPCG Authorisation
Condition sheet
Amendments
Import utilisation details
Bills of Entry
Indigenous-procurement records
Duty Saved Amount
Installation Certificate
Export-obligation period
Extension orders
Export products or services
Specific EO statement
Average EO statement
Block-wise reports
Shipping Bills
Export invoices
Bills of Export
eBRC
FIRC
Deemed-export records
Third-party-export records
CA, CMA or CS certificate
Appendix 5C
ANF 5B information
Clubbing order
Duty and interest payment proof, where applicable
Customs Bond, LUT or BG details
For goods exports
Export order
Shipping Bill
Bill of Export
Bill of Lading
Airway Bill
Export invoice
eBRC
GST invoice
Transport evidence
Books of account
For service exports
Service invoice
Contract
eBRC
FIRC
Foreign-exchange earning statement
Bank certificate
CA-certified realisation statement
Books of account
Our Process
Our EPCG EODC Process
Authorisation audit
We verify: Policy period, Authorisation conditions, Import validity, Capital-goods imports, Duty Saved Amount, Installation, Amendments, Export-obligation period, Extensions.
Import reconciliation
We match: Authorised capital goods, Bills of Entry, Quantity, CIF value, Duty Saved, Indigenous procurement, Actual utilisation, Excess or lower utilisation.
Export reconciliation
We match: Export product or service, Shipping Bills, Invoices, EPCG Authorisation number, FOB value, eBRC, FIRC, Export date, Third-party records.
Specific EO calculation
We calculate: Original Specific EO, Revised EO, First-block fulfilment, Balance EO, Shortfall, if any.
Average EO calculation
We assess: Historical average, Financial-year exports, Overall maintenance, Sector relief, Exemption eligibility, Shortfall, if any.
Professional Certification
Make the appropriate professional certificate along with Appendix 5C.
ANF 5B Application
Fill the online EODC application.
Deficiency Response
Share the required documents for DGFT queries.
EODC and Customs closure
After EODC issuance: Certificate status is verified, ICEGATE transmission is checked, Customs Bond or LUT cancellation is followed up, Bank Guarantee release is coordinated, Final closure records are organised.
EODC Processing Timeline
The HBP provides that EODC applications should ordinarily be processed within 30 days.
Deficiencies should normally be raised together, and once all documents and information are complete, discharge should ordinarily be processed within 30 days of receipt of the complete records.
This is a procedural target and not a guaranteed service-delivery period.
EPCG Regularisation of Default
Where the full EO has not been fulfilled, the holder can assess regularisation.
The applicable action can include:
Proportionate Customs duty
Applicable taxes and cess
Interest
EO extension
First-block extension
Average EO relief
Clubbing
Adjustment of eligible exports
Suo motu payment
Policy-relaxation application
EODC after payment
Under the current HBP, a holder failing to complete EO must pay duties, taxes and cess proportionate to the shortfall along with applicable Customs interest.
Surrender of EPCG Authorisation
An unutilised EPCG Authorisation can be surrendered without penalty or fee under the current HBP.
Where capital goods have already been imported or procured, the case requires a wider utilisation, EO and Customs review rather than ordinary unused surrender.
Maintenance of EPCG Records
The EPCG holder should maintain true and proper records for two years from the date of redemption.
Records should include:
EPCG Authorisation
Amendments
Bills of Entry
Duty calculations
Installation Certificate
Shipping Bills
Invoices
eBRC
FIRC
Export contracts
Third-party records
Annual EO reports
EODC
Customs closure
Professional certificates
The current HBP prescribes a two-year post-redemption record-maintenance period.
Re-Export, Repair or Replacement of Capital Goods
Capital goods found defective or unfit may, subject to DGFT and Customs permission: Be re-exported to the foreign supplier within the prescribed period, Be replaced under the applicable procedure, Be sent abroad for repairs.
The EO can require refixation depending on the transaction, duty effect and replacement or repair cost.
Troubleshooting
Common Status Holder Certificate Problems
Machinery does not establish nexus with the export product
The proposed capital goods may not have a direct or reasonable connection with the goods or services to be exported.
Our approach: We review: Technical specifications, Manufacturing flow, Production stage, Export product, Expected output, Chartered Engineer justification.
Capital goods are prohibited under Appendix 5F
The proposed equipment may fall within a prohibited or sector-restricted category.
Our approach: We check Appendix 5F and the ITC-HS classification before filing or finalising the purchase.
Second-hand machinery was proposed
Second-hand capital goods are not currently permitted under EPCG.
Our approach: We assess alternative import or financing routes rather than filing an ineligible EPCG application.
Incorrect Duty Saved calculation
The application may use an incomplete Customs-duty calculation.
Our approach: We prepare an estimated import-duty comparison and separate the amounts that can form part of the net Duty Saved calculation.
Average EO was ignored
The exporter calculated only the six-times Specific EO
Our approach:We calculate historical Average EO and identify exports available above the average.
Existing EPCG Authorisations were not disclosed
The applicant may have outstanding EPCG obligations.
Our approach:We prepare an authorisation-wise pending-obligation statement.
Supporting manufacturer was not endorsed
The machinery may have been installed at an unendorsed manufacturer’s premises.
Our approach:We assess amendment, endorsement and Customs-intimation requirements.
EPCG Authorisation expired before import
The 24-month import-validity period may have expired.
Our approach: We assess: Whether the authorisation was utilised, Whether unused surrender is possible, Whether partial utilisation occurred, Remaining machinery plan, Alternative scheme route. Revalidation is not permitted under the current FTP.
Installation Certificate was not submitted
Capital goods were imported and installed, but the certificate remains pending.
Our approach: We identify: Completion-of-import date, Three-year due date, Valid EO period, Applicable ₹10,000-per-year extension fee, Chartered Engineer records, Customs intimation.
Machinery was moved without compliance
Capital goods may have been shifted to another unit without a fresh Installation Certificate.
Our approach: We review the unit’s IEC, GSTIN and RCMC and prepare the applicable DGFT and Customs records.
Shipping Bills do not mention the EPCG Authorisation
Exports may not appear automatically in DGFT records or may not be accepted toward EO.
Our approach: We review: Contemporaneous invoice, Shipping Bill, GST records, eBRC, Production records, Customs amendment possibility, Professional certification. Acceptance cannot be guaranteed.
Shipping Bills do not appear in the EODC application
Possible reasons include: Incorrect EPCG number, ICEGATE transmission issue, Wrong IEC, Missing Shipping Bill repository data, Export through third party, Missing supporting manufacturer.
Our approach:We reconcile Customs, DGFT and exporter records.
eBRC is missing
Exports were completed but realisation records are not available or incorrectly mapped.
Our approach: We review: IRM, eBRC generation, Invoice mapping, Shipping Bill mapping, Bank realisation, EDPMS status where relevant.
First-block EO was not fulfilled
The exporter did not complete 50% of Specific EO in the first four years.
Our approach: We assess: Exports already completed, Extension eligibility, Applicable composition fee, Regularisation, Full-period completion.
EO period expired
The exporter still has a Specific or Average EO shortfall.
Our approach: We assess: Ordinary EO extension, Late application, Temporary 2026 relief, Clubbing, Average EO relief, Proportionate duty and interest.
xports were counted under another EPCG Authorisation
The same Shipping Bill may have been allocated twice.
Our approach:We perform Shipping Bill-level de-duplication before professional certification.
Third-party exports lack proper documentation
The Shipping Bill, GST invoice, movement records or disclaimer may be incomplete.
Our approach: We review the full third-party-export documentary chain before including the exports.
Customs Bond remains open after EODC
DGFT may have issued the EODC, but Customs closure is pending.
Our approach: We verify: EODC, ICEGATE transmission, Port registration, Bond or LUT, Bank Guarantee, Customs closure application.
Why Dwarkadhish overseas
Why Choose Dwarkadhish Overseas?
Complete lifecycle assistance
The same team can assist from eligibility and application through EODC and Customs closure.
EO planning before filing
We calculate Specific and Average EO before the importer commits to the machinery benefit.
Appendix 5F and nexus review
We assess whether the proposed capital goods are permitted and genuinely related to exports.
Shipping Bill and eBRC reconciliation
We maintain authorisation-wise export and realisation records.
DGFT and Customs coordination
EPCG requires action at both the DGFT and Customs stages.
Legacy EPCG assistance
Older, expired and partially fulfilled authorisations can be reviewed according to the policy applicable on their issue date.
Export Compliance Outsourcing
EPCG monitoring can be included in a recurring monthly compliance scope.
Related Services
IEC Registration
Obtain or update the IEC required for DGFT applications.
RCMC Registration
Register with the appropriate Export Promotion Council or Commodity Board.
eBRC Generation
Generate and reconcile export-realisation records used in Status Holder assessments.
Advance Authorisation
Import eligible inputs duty-free against export obligations.
Certificate of Origin
Obtain preferential and non-preferential Certificates of Origin.
Status Holder Certificate
Apply for One Star to Five Star Export House recognition.
Export Compliance Outsourcing
Outsource ongoing DGFT, Customs, incentive and authorisation management.
Client Experiences
What Our Clients Say
“Dwarkadhish Overseas supported us with our export documentation and compliance requirements. Their team was responsive and kept us informed throughout the process.”
Nishu Vishwas
[Company Name]
Service: Advance License
“We approached the team for our pending refund-related work. They reviewed the documents carefully and helped us understand the issues and required next steps.”
[Client Name]
[Company Name]
Service: IGST Refund Support
“The team assisted us with DGFT and Customs requirements in a professional and organised manner. Communication and follow-up were consistent.”
[Client Name]
[Company Name]
Service: Export Compliance Support
Pan India
Status Holder Certificate Services Across India
Dwarkadhish Overseas provides remote Status Holder eligibility, reconciliation and application support to exporters across India.
Mumbai
Delhi NCR
Bengaluru
Chennai
Ahmedabad
Surat
Hyderabad
Kolkata
Pune
Indore
Jaipur
Ludhiana
Tiruppur
Rajkot
Coimbatore
Kochi
Vadodara
Noida
Gurugram
FAQ
Frequently Asked Questions
EPCG stands for Export Promotion Capital Goods.
The formal document issued by DGFT is an EPCG Authorisation. EPCG Licence is the commonly used commercial term.
Eligible capital goods can be imported at zero Customs duty against fulfilment of the applicable Export Obligation.
Manufacturer Exporters, Merchant Exporters tied to supporting manufacturers and eligible Service Providers can apply.
No. Appendix 5F currently lists all second-hand capital goods as not permitted.
Eligible exports under these schemes can count toward EPCG EO.
The current ordinary route allows up to two additional years, subject to fees and timelines.
EODC is the Export Obligation Discharge Certificate issued after satisfactory completion or regularisation.
It is ₹1 per ₹1,000 of Duty Saved Amount, subject to a minimum of ₹500 and maximum of ₹1 lakh.
Most assessment, reconciliation and DGFT filing can be completed remotely. Installation certification and Customs representation may require location-specific support.