SME chatroom: Clearing doubts on deferred Customs duty and PVC import curbs

Key compliance clarifications on using RoDTEP scrips for deferred customs duty and MIP rules for PVC imports under the Advance Authorisation scheme.

As an Eligible Manufacturer Importer (EMI) availing duty deferment under CBIC Circular No. 08/2026-Customs dated February 28, 2026, can we pay the deferred duty through a RoDTEP scrip? Please give the relevant legal provisions. 

Yes, but the RoDTEP (Remission of Duties and Taxes on Exported Products ) scrip must be used when the bill of entry is assessed, not later when the deferred-duty challan becomes payable. The customs broker must declare the scrip details in the licence table of the bill of entry. The Basic Customs Duty (BCD) debited from the scrip is thereby discharged immediately; only the balance duty payable in cash is deferred. RoDTEP credit can be used only for BCD specified under Notification No. 76/2021-Customs (N.T.) dated September 23, 2021. It cannot be used for Social Welfare Surcharge, Integrated Goods and Services Tax (IGST), compensation cess, anti-dumping duty, safeguard duty or other levies, which must be paid through the prescribed cash-payment mechanism. The relevant provisions are the proviso to Section 47(1) and Section 51B of the Customs Act, 1962; the Deferred Payment of Import Duty Rules, 2016; the Customs (Electronic Duty Credit Ledger) Regulations, 2021; Notification Nos. 76/2021-Customs (N.T.) and 12/2026-Customs (N.T.); and Circular No. 08/2026-Customs.  

Therefore, do not wait until the deferred-duty challan becomes payable to offer the scrip. The EMI facility, introduced through Notification No. 12/2026-Customs (N.T.), operates from April 1, 2026 until March 31, 2028 and is governed by the eligibility and compliance conditions specified in Circular No. 08/2026-Customs and the amended Deferred Payment Rules. The facility is therefore temporary, not an indefinite entitlement. 

DGFT Notification No. 25/2026-27 dated July 24, 2026 prescribes a minimum CIF (cost, insurance, and freight) value of more than $0.766 per kg for imports of suspension-grade PVC for six months. Our lower-priced consignment was shipped before the notification. Are goods in transit protected? As an Advance Authorisation holder, can we sell in the DTA goods manufactured from inputs imported under the minimum import price (MIP) exemption? 

Yes. If the goods were shipped before July 24, the MIP restriction should not apply merely because they arrived later. Paragraph 1.05(b) of the Foreign Trade Policy (FTP), 2023, protects imports already made before a policy change from “free” to “restricted”, “prohibited”, “state trading” or “otherwise regulated”. Under Paragraph 2.17(a) of the Handbook of Procedures, 2023, read with Paragraph 11.11, for policy purposes, the date for sea imports is the shipment/dispatch date appearing on the bill of lading, not their arrival date. This protection is unavailable for high-sea-sale imports. Imports shipped after the notification may nevertheless be allowed if backed by an irrevocable commercial letter of credit opened before the restriction, subject to registration with the jurisdictional regional authority within 15 days and limited to the balance quantity, value and period available under the letter of credit. 

The MIP exemption under an Advance Authorisation does not permit sale of the imported PVC in the domestic tariff area (DTA). Under Para 4.16 of the FTP, the input remains subject to actual-user condition and is non transferable even after export obligation is completed. However, sale in the DTA of finished products manufactured 

from the duty-free input after completion of export obligation is permitted.

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