Paragraphs 4 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
This article is on the Handbook only. These paragraphs have no counterpart of their own in the Foreign Trade Policy, 2023. They decide which exports count when made before an authorisation is issued (paragraphs 4.27 and 4.28), how the Regional Authority monitors the obligation (4.43), the application for fulfilment (4.46), the Bond Waiver Certificate and the Export Obligation Discharge Certificate (4.47) and the transitional rule for authorisations issued up to 31.03.2023 (4.48).
The procedure is taken from Chapter 4 of the Handbook of Procedures, 2023 as published on the DGFT website (file of July 2026), consulted on 2 October 2026. This article is based on the chapter-wise text of the Foreign Trade Policy, 2023 published on the DGFT website, as consulted on 2 October 2026; the copy carries no "updated up to" date. Later Public Notices should be checked. A holder with a lapsed period or a missing document can discuss the position first in a legal consultation.
Exports made from the date of the EDI-generated file number may count towards the obligation (paragraph 4.27(a)), but exports in anticipation are at the exporter's risk (4.28). The holder files the application online within six months of the expiry of the export obligation period, linking shipping bills (4.43(b)); the application is made in ANF 4F (4.46). On fulfilment the Regional Authority issues an EODC or, where exports came first, a Bond Waiver Certificate (4.47). Failure invites a show-cause notice and penal action (4.43(b), (f)).
Exports in anticipation of the authorisation: paragraphs 4.27 and 4.28
Paragraph 4.27 is headed as exports and deemed export supplies in anticipation of, or after, the issue of an authorisation.
- (a) Exports or deemed export supplies made from the date of the EDI-generated file number may be accepted towards discharge of the obligation. Shipping bills or tax invoices must be endorsed with the file number or authorisation number to show the link, and must contain the details of exempted materials or inputs consumed and the technical characteristics of export and import items, as the case may be.
- (b) If the application is approved, the authorisation is issued on the norms in force on the date the Regional Authority received the application. If the norms change in between, the authorisation is issued in proportion to the provisional exports already made till the amendment; for the rest, the Policy and Procedures in force on the date of issue apply.
- (c) Export of SCOMET items is not permitted against an authorisation until the requisite SCOMET authorisation is obtained.
- (d) Inputs with a pre-import condition are not considered for replenishment against exports made before the import of those inputs.
Paragraph 4.28 adds that exports or supplies made in anticipation of the grant of an Advance Authorisation are entirely on the risk and responsibility of the exporter. In practice, the pre-authorisation exports can be counted under paragraph 4.27(a) only if the file number exists and the application is approved. For SCOMET, see our guide on SCOMET export controls and the catch-all provision.
Monitoring: paragraph 4.43
| Sub-paragraph | What it requires |
|---|---|
| (a) | The Regional Authority with which the undertaking is executed keeps a master register showing start and closing dates of each obligation period; the data may also be generated from the computer system. |
| (b) | Within six months from the date of expiry of the export obligation period, the holder files an online application linking shipping bill details to the authorisation; otherwise the Regional Authority may start action under the Act, including a show-cause notice. |
| (c) | For online filing, all exports are linked on the DGFT system by file or authorisation number with shipping bills, bills of export or invoices. |
| (d) | For non-EDI shipping bills and Chapter 7 supplies, details are filed manually on the DGFT website within two months of expiry; copies of shipping bills go to the Regional Authority in the same time. |
| (e) | The e-BRC or EDPMS export realisations, where available, are linked within six months of expiry or as per the realisation period set by RBI; no action is taken for non-linking before then if other documents show fulfilment. |
| (f) | If the holder fails to complete the obligation or to submit the information, the Regional Authority enforces the conditions of the authorisation and undertaking and starts penal action as per law, including refusal of further authorisation. |
The show-cause notice and penalties rest on the Act: see our articles on sections 13 and 14 of the FTDR Act and section 11 of the FTDR Act. The Handbook is issued by the Director General under section 6 (section 6 of the FTDR Act), supporting a Policy made under section 5 (section 5 of the FTDR Act).
Fulfilment, bond waiver and discharge: paragraphs 4.46 and 4.47
Paragraph 4.46: the holder files an online application in ANF 4F to the Regional Authority and uploads the prescribed documents in support of fulfilment. ANF 4F is named only.
Paragraph 4.47(a): Bond Waiver Certificate
Where the holder exports first, before effecting imports, using imported or indigenously procured inputs, it may seek a waiver of the bond condition on evidence of exports made and payment realised to that extent. If exports are less than the obligation, a pro-rata waiver can be considered.
- The application is online with shipping bills, the e-BRC or EDPMS realisations and the other documents of ANF 4F; for deemed exports or non-EDI ports, proof goes to the Regional Authority's counter.
- If the obligation is fulfilled, the Regional Authority issues the Bond Waiver Certificate and sends a copy to Customs at the port of registration. The waiver does not stop Customs from taking a bond under the Customs notification.
- While waiving the bond, the Regional Authority may revalidate the authorisation for a further six months to replenish consumed inputs, if the applicant asks in ANF 4D, pays the fee for revalidation and has not obtained revalidation earlier under paragraph 4.39(c). The maximum validity including this revalidation shall not exceed 24 months from the date of issue.
- A copy of the certificate goes to Customs at the port of registration, eventually by EDI.
Paragraph 4.47(b): EODC
On completion of exports and imports, the holder files the online application in ANF 4F. If the obligation is fulfilled, the Regional Authority may issue the EODC or redemption certificate and send a copy to Customs at the port of registration, with the proof details; a copy is also endorsed to Customs by EDI so that Customs need not call for documents again.
Paragraph 4.47(c) and (d): redemption is not the end
Ordinarily, redemption of the Bank Guarantee or Legal Undertaking does not stop Customs from random checks and action for misrepresentation, mis-declaration or default detected later under the Customs Act. The Regional Authority acts against a holder who has not submitted Appendix 4H or 4-I, or for misstatement in them, and makes an endorsement in the redemption certificate. See also our article on paragraphs 4.12 to 4.15 of the Policy and paragraphs 4.29 and 4.51 of the Handbook.
Paragraph 4.48: authorisations issued up to 31.03.2023
Advance Licences, including those for Annual Requirement, issued up to 31.03.2023 are governed by the provisions of the earlier Handbooks which the paragraph lists, one by one, as amended from time to time. The exceptions are clubbing and extension of the export obligation period, which follow paragraphs 4.36 and 4.40 of the present Handbook, and any other provision notified by the DGFT. Where Customs duty is to be paid on unutilised material, it is paid with interest as notified by the Department of Revenue (paragraph 4.48(b)). The paragraph gives no further detail. See our article on paragraph 4.36 of the Handbook.
A worked example
Reddy Garments Private Limited, an invented exporter, has an Advance Authorisation whose export obligation period has just ended. Within six months of that expiry it must file the online application linking shipping bills (paragraph 4.43(b)). Because it exported first, it seeks a Bond Waiver Certificate, and the Regional Authority may revalidate for six months within the 24-month ceiling (paragraph 4.47(a)(iii)). Once the obligation is complete, it applies in ANF 4F for the EODC.
Need help with discharge?
A missed six-month window or an unlinked shipping bill is far easier to deal with early. Our team can review your authorisation file and the documents for the discharge application in a legal consultation.
Key takeaways
- Pre-authorisation exports count from the EDI file number, at the exporter's risk (paragraphs 4.27 and 4.28).
- File the online application within six months of expiry of the export obligation period (paragraph 4.43(b)); manual details for non-EDI bills within two months (4.43(d)).
- ANF 4F is the application for fulfilment (paragraph 4.46).
- Bond Waiver Certificate where exports come first; EODC on completion (paragraph 4.47).
- Revalidation with bond waiver is for six months and the whole validity cannot exceed 24 months (paragraph 4.47(a)(iii)).
- Authorisations issued up to 31.03.2023 follow the earlier Handbooks, except clubbing and extension (paragraph 4.48).
Read next
- Paragraphs 4.49 and 4.50 of the Handbook of Procedures, 2023: regularisation of bona fide default
- Paragraph 4.22 of the Foreign Trade Policy, 2023: export obligation period and extension
- Paragraph 4.17 of the Foreign Trade Policy, 2023: validity, revalidation and enhancement
- Advance Authorisation: export obligation, clubbing and the EODC
Disclaimer: Based on the chapter-wise text of the Foreign Trade Policy, 2023 and the Handbook of Procedures, 2023 published on the DGFT website, and on the later Notifications named in this article, as consulted on 2 October 2026. The copies carry no "updated up to" date. Notifications, Public Notices, Trade Notices, the ITC(HS) schedules, Appendices and forms change often; the current text on the DGFT website should be checked before acting. This article is general information, not legal advice; check the official text before acting.