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India — Export Controls

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SCOMET list structure and classification rules

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India's SCOMET list (Special Chemicals, Organisms, Materials, Equipment and Technologies) comprises dual-use items that have both civil and military applications, including items capable of contributing to weapons of mass destruction and their delivery systems. The SCOMET list is published as Appendix 3 to Schedule 2 of the ITC(HS) Classification of Export and Import Items and is periodically updated to align with the control lists of the multilateral export control regimes—the Missile Technology Control Regime (MTCR), Wassenaar Arrangement (WA), Australia Group (AG), and Nuclear Suppliers Group (NSG)—as well as India's obligations under the Biological Weapons Convention (BWC) and United Nations Security Council Resolution 1540.

Nine-category structure. The SCOMET list is organized into the following nine categories (0 through 8):

  • Category 0: Nuclear materials, nuclear-related other materials, equipment and technology (aligned with NSG)
  • Category 1: Materials, Chemicals, Micro-organisms and Toxins (aligned with AG and BWC)
  • Category 2: Materials Processing (aligned with MTCR, Wassenaar, NSG)
  • Category 3: Electronics (aligned with Wassenaar, NSG)
  • Category 4: Computers (aligned with Wassenaar)
  • Category 5: Telecommunications and Information Security (aligned with Wassenaar)
  • Category 6: Munitions List items (aligned with Wassenaar munitions list; effective September 2024, Department of Defence Production (DDP) is the licensing authority for Category 6 exports for military end use)
  • Category 7: Navigation and Avionics, Marine, Aerospace and Propulsion (aligned with MTCR, Wassenaar)
  • Category 8: Technology (technology required for the development, production, or use of items controlled under Categories 0 through 7)

Each category is further subdivided into alphanumeric item codes (e.g., 3A001, 6A022) that mirror the numbering conventions of the international control lists.

Classification methodology. Exporters must determine whether a proposed export item, component, or technology falls within the SCOMET list by applying Note 1 to Appendix 3: "If items are prima facie, classifiable under two or more headings, the heading which provides the most specific description shall be preferred to heading providing a more general description. The end-use of the item would be a relevant criteria in determining the classification." This specificity principle mirrors the General Rules of Interpretation for the Harmonized System, prioritizing detailed technical specifications over general descriptions.

Incorporated components. Note 3 to the SCOMET list imposes a controlled-component rule: "The object of the controls contained in this Schedule should not be defeated by the export of any non-controlled goods containing one or more controlled components when the controlled component or components are the principal element of the goods and can feasibly be removed or used for other purposes." In judging whether a controlled component is the principal element, exporters must weigh the quantity, value, and technological know-how embodied in the component relative to the finished good. A non-SCOMET assembly that incorporates a Category 3 electronic component as its principal element would itself become controlled.

Software and technology exclusions. Unless otherwise specified for a particular item code, the SCOMET list does not control software that is (i) in the public domain, or (ii) generally available to the public by being sold from stock at retail selling points without restriction and designed for installation by the user without further substantial support by the supplier. This carve-out parallels the general software note in the Wassenaar Arrangement. Category 8 technology controls are defined by the General Technology Note, which governs the export of "technology required for the development, production or use" of items controlled under Categories 0 through 7.

Used items and re-exports. The DGFT FAQ clarifies that the SCOMET list includes used items falling under any of the nine categories. Re-export of imported SCOMET items requires authorization; exporters may use the one-time General Authorization for Export after Repair in India (GAER) if the item is returned to the same entity abroad after repair, subject to quarterly post-reporting under Paragraph 10.12 of the Handbook of Procedures, 2023.

Classification resources. DGFT maintains a digitized search tool at dgft.gov.in/CP/?opt=itchs-import-export allowing exporters to query 8-digit HS codes and retrieve the corresponding SCOMET applicability. Exporters unable to self-classify may submit a formal classification query to DGFT (Headquarters) in New Delhi. The SCOMET list was most recently updated in September 2024, superseding all prior notifications via DGFT Notification No. 5/2015-2020 dated 24 April 2017 (as amended).

Source: DGFT, Appendix 3 – SCOMET List (Updated 2 September 2024) Source: DGFT, Foreign Trade Policy 2023 Chapter 10 – SCOMET Source: DGFT, Handbook of Procedures 2023 Chapter 10 – SCOMET Source: DGFT, Frequently Asked Questions – SCOMET v1.0

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Catch-all end-use and end-user controls for non-SCOMET items

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India's export control system imposes a catch-all control that extends beyond the SCOMET list to cover items not explicitly controlled when the exporter has been notified by DGFT or knows—or has reason to believe—that the item may be diverted to weapons of mass destruction (WMD) programs, missile systems, or military end use (including by terrorists and non-state actors). This provision closes the gap between the static SCOMET list and the dynamic risk landscape.

Statutory foundation. The catch-all control is authorized under Paragraph 10.05 of the Handbook of Procedures 2023 ("Additional controls on Non-SCOMET items for dual use (Catch-all controls)") and traces its legal authority to Chapter IVA of the Foreign Trade (Development and Regulation) Act, 1992, as amended in 2010, which incorporated controls on brokering, transhipment, and export of items with WMD applications in alignment with the Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 (WMD Act, Act No. 21 of 2005). The WMD Act, which came into force on November 17, 2006, obligates India to prevent export, transfer, re-transfer, transit, and trans-shipment of "material, equipment or technology of any description" identified by the Central Government as relevant to India as a nuclear weapon state, to national security, or to India's international obligations under bilateral, multilateral, or international treaties relating to WMD or their delivery systems.

Trigger: knowledge or official notification. The catch-all obligation arises under two trigger conditions:

  1. DGFT written notification. The exporter has been notified in writing by DGFT that a specific item not on the SCOMET list poses a potential risk of use in or diversion to WMD, missile systems, or military end use (including by terrorists and non-state actors).
  1. Exporter knowledge or reason to believe. The exporter knows or has reason to believe that the non-SCOMET item has a potential risk of use in or diversion to WMD, missile systems, or military end use (including by terrorists and non-state actors).

The "reason to believe" standard imposes an affirmative duty on exporters to investigate red-flag indicators—such as vague or evasive end-user descriptions, end-user locations in countries subject to multilateral WMD-related restrictions, requests for modifications inconsistent with the stated civilian application, or refusal by the buyer to provide an end-use certificate—even in the absence of formal DGFT notification.

Definition: "Military use." The Handbook of Procedures defines "military use" to mean "incorporation into items listed under SCOMET Category 6 or for the use, development, or production of military items listed in" Category 6 (Munitions List). This definition is narrower than the broader WMD Act reference to any military end use, but in practice the IMWG examines both WMD-relevant military applications and broader defense-industrial end uses on a case-by-case basis.

Authorization requirement. If either trigger condition is met, the exporter shall apply for a SCOMET authorisation using the same procedure specified for controlled SCOMET items in Paragraphs 10.05 and 10.06 of the Handbook of Procedures. The export of the catch-all item may be denied or permitted as per the SCOMET licensing procedure, which involves submission of application form ANF 10A and review by the Inter-Ministerial Working Group (IMWG) comprising members from the Ministry of External Affairs (MEA), Department of Defence Production (DDP), Department of Space (ISRO), DRDO, Department of Atomic Energy (DAE), Department of Chemicals and Petrochemicals, and the Cabinet Secretariat. The IMWG meets monthly under the chairmanship of the Additional DGFT and decides by consensus.

End-use assurances. DGFT may require additional formal assurances, as deemed appropriate, including end-use and non-transfer undertakings from the government of the recipient country. Additional end-use conditions may be stipulated in the authorization based on an assessment of proliferation concerns and other factors. Exporters must submit an End-Use Certificate (EUC) in the prescribed proforma (Appendix 10J(i)) filled by all entities in the chain of supply—foreign buyer, consignee, end-user, and any intermediaries—on the letterhead of the respective entity, duly signed in ink and stamped by the authorized signatory.

Non-state actors and terrorists. The explicit reference to "terrorists and non-state actors" in Paragraph 10.05 reflects India's obligations under United Nations Security Council Resolution 1540, which obliges all countries to prohibit access to WMD and their delivery systems by non-state actors, particularly for terrorist purposes. The WMD Act Section 4(g) defines a "non-State actor" as "a person or entity not acting under the lawful authority of any country." Exporters must screen end users to exclude entities acting outside state control, including terrorist organizations, unaffiliated armed groups, and other non-governmental actors seeking WMD-relevant capabilities.

Effective date. Chapter IVA of the FT(D&R) Act was incorporated by the 2010 Amendment; the WMD Act came into force on November 17, 2006. The catch-all control in Paragraph 10.05 appears in the current Foreign Trade Policy 2023 and Handbook of Procedures 2023, which supersede prior policy editions.

Source: DGFT, Foreign Trade Policy 2023 Chapter 10 – SCOMET, Paragraph 10.05 Source: DGFT, Handbook of Procedures 2023 Chapter 10 – SCOMET, Paragraph 10.05 Source: Weapons of Mass Destruction and their Delivery Systems (Prohibition of Unlawful Activities) Act, 2005 (Act No. 21 of 2005)

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Deemed exports: intangible technology and technical assistance transfers

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India's SCOMET export control system governs not only the physical export of dual-use goods but also the intangible transfer of controlled technology and technical assistance—often called "deemed exports" in trade-compliance practice. Transfer of SCOMET-controlled technology to a foreign national in India, electronic transmission of technical data abroad, provision of training or consulting services that disclose controlled know-how, or cloud-hosted software development that makes controlled source code available to foreign persons can all trigger the same licensing requirement as a physical shipment of hardware. Many exporters fail to recognize these intangible transfers as regulated "exports," creating substantial compliance risk.

Statutory authority. Chapter IVA of the Foreign Trade (Development and Regulation) Act, 1992, as amended in 2010, extends export-control jurisdiction to "goods, services and technology" with WMD applications. The SCOMET list, published as Appendix 3 to Schedule 2 of the ITC(HS) Classification, explicitly includes Category 8 (Technology) and defines technology controls in the General Technology Note that governs all nine SCOMET categories. Paragraph 1 of the General Technology Note states: "The export of 'technology' which is 'required' for the 'development', 'production' or 'use' of items controlled in Category 8 is controlled according to the provisions in each sub-category. This 'technology' remains under control even when applicable to any uncontrolled item." This last clause is critical: technology for the development, production, or use of a SCOMET item remains controlled even if transferred independently of the physical item or applied to a non-SCOMET end product.

Definition: "Technology." The Ministry of External Affairs (MEA) and NASSCOM joint guidance on Internal Compliance Programmes defines "technology" as "information (including information embodied in software) other than information in the public domain, that is capable of being used: in the development, production or use of any goods or software; in the development of, or the carrying out of, an industrial or commercial activity or the provision of a service of any kind in relation to an item specified under India's SCOMET list." This definition sweeps broadly across design data, manufacturing processes, quality-control methods, system-integration know-how, and application-specific configuration parameters—any information that enables a recipient to develop, produce, or operate a SCOMET item.

Forms of controlled technology. Appendix 3 to the SCOMET list defines two forms in which controlled technology may be transferred:

  1. "Technical data" may take forms such as blueprints, plans, diagrams, models, formulae, tables, engineering designs and specifications, manuals and instructions written or recorded on other media or devices such as disk, tape, read-only memories, or cloud storage.
  1. "Technical assistance" may take forms such as instruction, skills, training, working knowledge, consulting services. Technical assistance may involve transfer of technical data (for example, training materials distributed during an on-site engineering workshop).

Both forms require authorization from DGFT (or the Department of Atomic Energy for Category 0 nuclear-related technology, or the Department of Defence Production for Category 6 munitions technology) if the technology is controlled under the relevant SCOMET category.

Public-domain and basic-scientific-research exclusions. Paragraph 3 of the General Technology Note provides: "Controls do not apply to 'technology' 'in the public domain', to 'basic scientific research' or to the minimum necessary information for patent applications." The SCOMET list defines "in the public domain" as technology that has been made available without restrictions upon its further dissemination—for example, published academic journal articles, standards documents publicly available for purchase, or open-source software repositories accessible without confidentiality obligations. Technology disclosed subject to a non-disclosure agreement, proprietary license restriction, or export-control clause is not in the public domain. "Basic scientific research" means experimental or theoretical work undertaken principally to acquire new knowledge of fundamental principles of phenomena, not primarily directed toward a specific practical aim or application.

Minimum-necessary exclusion for installation, operation, maintenance, and repair. Paragraph 2 of the General Technology Note carves out an important operational exclusion: "Controls do not apply to that 'technology' which is the minimum necessary for the installation, operation, maintenance (checking) or repair of those items which are not controlled or whose export has been authorised." If an Indian exporter has already obtained a SCOMET authorization for the physical export of a controlled item (for example, a Category 3 electronic sub-assembly), the exporter may subsequently transfer the minimum necessary installation manual, calibration procedure, and troubleshooting guide to enable the foreign buyer to install, operate, maintain, and repair that specific unit without obtaining a separate technology-export authorization. The exclusion is tightly scoped: it covers only the minimum information needed for those four functions, not design modifications, reverse-engineering data, or manufacturing process documentation; and it applies only to items whose physical export was already authorized or to non-controlled items.

Authorization requirement and licensing authority. Export of controlled SCOMET technology requires an export authorization from the same licensing authority that governs the corresponding item category: DGFT for Categories 1, 2, 3, 4, 5, 7, and 8; the Department of Atomic Energy (DAE) for Category 0 nuclear-related technology; and the Department of Defence Production (DDP) for Category 6 munitions technology for military end use. The exporter must file application form ANF 10A (or ANF 10B for Global Authorization for Intra-Company Transfer, GAICT) through DGFT's electronic system at dgft.gov.in. The application undergoes Inter-Ministerial Working Group (IMWG) review under the same case-by-case criteria applied to physical exports, including end-user credentials, proliferation-risk assessment, and compliance with India's obligations under the Missile Technology Control Regime (MTCR), Wassenaar Arrangement, Australia Group, and Nuclear Suppliers Group. For technology exports, the application must include "an explanation of the process, product, specification (catalogue), size and output capacity of all items to be produced with the technology, if applicable, or other description that delineates, defines, and limits the" scope of the technology transfer, submitted on the exporter's letterhead. End-Use Certificates (Appendix 10J(i)) are required in the same manner as for physical exports, with the recipient certifying that the technology will not be re-transferred or used for WMD-related purposes without Government of India consent.

Intra-company technology transfers and GAICT. India operates a streamlined General Authorization for Intra-Company Transfer (GAICT) scheme that permits specified SCOMET items, software, and technology to be transferred between related corporate entities (Indian parent and foreign subsidiary, or Indian subsidiary and foreign parent) without individual case-by-case licensing. GAICT is available for transfers involving "design, encryption, research, development, delivery, validation, calibration, testing, related services, etc." to specified countries, subject to a three-year validity and quarterly post-export reporting to DGFT. The exporter must hold ANF 10B authorization and submit a Master Service Agreement or contract documenting the corporate relationship and the nature of the technology transfer. GAICT does not exempt the exporter from classification, end-use screening, and recordkeeping obligations; it streamlines the approval process for low-risk intra-corporate transfers.

Recordkeeping. India's Foreign Trade Policy requires retention of all SCOMET or export-control-related application documents, including correspondence with the buyer/intermediary/consignee/end-user/government, contracts, end-user certificates, financial records, shipping and trade-related documents, for five years. For technology transfers, this includes records of the technical decision to classify the technology under the SCOMET list, the unit or employee who made that determination, end-user and end-use screening documentation, and records of technology transfers and relevant electronic communication (emails disclosing technical data, access logs for cloud repositories hosting controlled source code, training attendance rosters for technical-assistance sessions).

Effective date. Chapter IVA's extension to services and technology came into force with the 2010 Amendment to the FT(D&R) Act. The General Technology Note appears in the current SCOMET list updated 2 September 2024, superseding the April 2017 notification.

Source: DGFT, Appendix 3 – SCOMET List (Updated 2 September 2024), General Technology Note Source: Foreign Trade (Development and Regulation) Act, 1992, as amended Source: Ministry of External Affairs & NASSCOM, Elements of an Effective Internal Compliance Programme Source: DGFT, Foreign Trade Policy 2023 Chapter 10 – SCOMET

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Application procedure, IMWG review process, and authorization validity

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Obtaining a SCOMET export authorization requires submission of application form ANF 10A (or ANF 10B for Global Authorization for Intra-Company Transfer, GAICT) through DGFT's electronic SCOMET portal at dgft.gov.in, followed by Inter-Ministerial Working Group (IMWG) review and, if approved, issuance of a time-limited export authorization. This section sets out the procedural mechanics exporters must navigate.

Pre-requisites. The exporter must hold a valid Importer-Exporter Code (IEC) number from DGFT and link that IEC to the user profile in the SCOMET portal. The application must be digitally signed using a valid Digital Signature Certificate (DSC) registered in the system or authenticated via e-Sign.

Application filing: ANF 10A. Applications for individual export authorizations are filed in form ANF 10A. The exporter submits the application electronically through the SCOMET portal. The application must include:

  • Detailed description of the SCOMET item(s) to be exported, including technical specifications, model numbers, part numbers, quantity, unit of measure, and freely convertible currency (FCC) value;
  • SCOMET category and sub-category classification (e.g., 3A001, 5D002);
  • Foreign buyer, consignee, and end-user details, including complete legal name, address, and contact information for each entity in the supply chain;
  • End-Use Certificate (EUC) in prescribed proforma Appendix 10J(i), filled by all entities in the chain of supply (foreign buyer, consignee, end-user, and any intermediaries) on the letterhead of the respective entity, duly signed in ink and stamped by the authorized signatory. The original hard-copy EUC(s) must be submitted to the SCOMET Section at DGFT Headquarters, New Delhi, even though the application is filed electronically; PDF copies are uploaded online;
  • Purchase order or contract excerpt demonstrating the commercial transaction;
  • Past export history for the same SCOMET item(s) over the prior three years, including all previously issued authorization numbers and export quantities;
  • Correspondence with the buyer, consignee, or end-user relevant to the transaction;
  • For technology exports: an explanation of the process, product, specification (catalogue), size, and output capacity of all items to be produced with the technology, or other description that delineates, defines, and limits the scope of the technology transfer, on the exporter's letterhead;
  • Legal undertaking on stamp paper of Rs. 200/- (if required under Paragraph 10.06 of the Handbook of Procedures for certain categories or end-use scenarios).

The exporter may add multiple SCOMET items to a single ANF 10A application. DGFT provides a bulk upload feature: exporters can download a sample Excel file from the portal, fill in item details offline, and upload the file to populate the application's item table.

The application fee is INR 1,000 for each authorization application, paid electronically through the SCOMET portal at the time of submission.

IMWG review. Once submitted, the application is examined by the Inter-Ministerial Working Group (IMWG), which comprises members from the Ministry of External Affairs (MEA), Department of Defence Production (DDP), Department of Space (ISRO), Defence Research and Development Organization (DRDO), Department of Atomic Energy (DAE), Department of Chemicals and Petrochemicals, the National Authority Chemical Weapons Convention (NACWC), and the Cabinet Secretariat. The IMWG normally meets once every month, under the chairmanship of the Additional DGFT in charge of exports, to decide on applications on a case-by-case basis. The IMWG evaluates each application against the guidelines and criteria set out in Paragraph 10.06 of the Handbook of Procedures, including:

  • The credentials and proliferation-risk profile of the foreign buyer, consignee, and end-user;
  • The nature, end-use, and end-user of the SCOMET item;
  • India's obligations under the Missile Technology Control Regime (MTCR), Wassenaar Arrangement, Australia Group, and Nuclear Suppliers Group, including the control lists' Sensitive List, Very Sensitive List, and Warning List;
  • India's national security and India's relations with the destination country.

DGFT may circulate the application to IMWG member agencies for comments, views, or no-objection certificates (NOCs) before the IMWG meeting. If no comments, views, or NOC are received within the stipulated period, the case is placed before the IMWG for decision. The IMWG decides by consensus. Where a case has been deferred in an IMWG meeting and subsequently NOC(s) are received from all concerned agencies with no divergence in views, authorization may be issued with the approval of the Chairman, IMWG, and the case is brought before the IMWG in its subsequent meeting for ex-post facto approval. Cases where a decision could not be arrived at in the IMWG are placed before the Director General of Foreign Trade for appropriate decision.

Simplified repeat-order procedure. For repeat orders for export of the same SCOMET item to different countries or entities, approval is granted by the Chairman, IMWG, after verification of the credentials of the foreign buyer, consignee, and end-user only, without full IMWG review. Subsequent to issuance of the export authorization, the IMWG through relevant agency(ies) may verify exports made under repeat orders.

Deficiency and correction. If the application is marked as deficient in the system, the exporter must log into the portal, navigate to "My Dashboard > Submitted Applications," view the deficiency remarks, and respond or upload corrected documents. The application re-enters the queue once corrected.

Approval and issuance. If approved, DGFT issues the export authorization electronically. The exporter can view and download the approved authorization via "My Dashboard > Submitted Applications" in the SCOMET portal. The authorization specifies the authorized items, quantities, destination country, consignee, end-user, validity period, and any special conditions (such as pre-license checks, post-shipment verification requirements, or reporting obligations).

Validity period. Unable to confirm as of 2026-06-01.

Revalidation. An export authorization for SCOMET items may be revalidated, on merits, for a period of six months at a time. The exporter applies for revalidation through the SCOMET portal. The application fee for revalidation is INR 500. DGFT FAQ Q36 confirms the six-month revalidation period.

Amendment. Exporters may request amendments to an issued authorization, including adding new items, decreasing the quantity of items, or modifying the unit of measure (UOM). The application fee for amendment or correction is INR 200. Amendments are filed through the SCOMET portal.

Non-transferability. SCOMET authorizations are non-transferable. The authorization may be used only by the named exporter.

Post-reporting obligations. Exporters holding General Authorizations (such as GAER for repair and re-export, GAICT for intra-company transfers, or GAED for drones) must submit post-shipment details on a quarterly basis to DGFT. For GAER, post-reporting is due quarterly. For stock-and-sale or stockist-abroad arrangements, the exporter must submit details of stocks transferred to end-users in specific countries during the period 1 October to 31 December of each calendar year by 31 January of the following year. Failure to submit mandatory reports or documents within prescribed timelines may result in penalty, cancellation, suspension, or revocation of the authorization.

Processing time. Because the IMWG normally meets once every month, and applications are circulated to member agencies for review in advance of each meeting, the typical processing time from submission to IMWG decision is approximately one to two months, depending on the application's position in the queue, the complexity of the item and end-use, and the time required for member agencies to respond. Repeat-order applications processed by the Chairman, IMWG, may be approved more quickly. No statutory or regulatory guarantee of a specific processing time is published. Exporters should plan lead time accordingly and avoid submitting applications immediately before an intended shipment date.

Recordkeeping. India's Foreign Trade Policy requires retention of all SCOMET or export-control-related application documents, including correspondence with the buyer/intermediary/consignee/end-user/government, contracts, end-user certificates, financial records, and shipping and trade-related documents, for five years. For technology transfers, this includes records of the technical decision to classify the technology under the SCOMET list, end-user and end-use screening documentation, and records of technology transfers and relevant electronic communication.

Source: DGFT, Handbook of Procedures 2023 Chapter 10 – SCOMET, Paragraphs 10.06, 10.07, 10.12 Source: DGFT, Frequently Asked Questions – SCOMET v1.0, Q27, Q28, Q32, Q35, Q36, Q38, Q42 Source: DGFT, Foreign Trade Policy 2023 Chapter 10 – SCOMET, Paragraph 10.04

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