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RoDTEP Benefits

Every rupee of embedded tax paid on electricity, transport, mandi fees, state cesses, and other non-refundable levies embedded in your export cost structure is money you are entitled to recover — but only if your RoDTEP claim is computed correctly, filed on schedule, and backed by robust documentation.

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Every rupee of embedded tax paid on electricity, transport, mandi fees, state cesses, and other non-refundable levies embedded in your export cost structure is money you are entitled to recover — but only if your RoDTEP claim is computed correctly, filed on schedule, and backed by robust documentation. RoDTEP (Remission of Duties and Taxes on Exported Products) replaced the earlier MEIS scheme effective 1 January 2021 under the Foreign Trade Policy framework, and its administration sits at the intersection of DGFT, Customs, and the GST architecture. PNPC Global has managed export incentive claims for Indian manufacturers and exporters since the scheme's inception. We handle every stage — eligibility mapping, rate schedule analysis, scroll generation, scrip utilisation, and compliance documentation — so you capture every rupee the scheme authorises without exposing yourself to the regulatory risks that come from incorrect claim computation.

What it costs

Govt. feesGovernment & statutory fees as applicable to your case
Professional feeFixed professional fee — confirmed in writing before we start

No hidden charges. The exact figure is set in your engagement letter.

What RoDTEP Benefits is

RoDTEP — Remission of Duties and Taxes on Exported Products — is an export incentive scheme notified by the Government of India under the Foreign Trade Policy framework, effective from 1 January 2021. It replaced the Merchandise Exports from India Scheme (MEIS) and was designed in response to an adverse WTO ruling that found MEIS to be a prohibited export subsidy. RoDTEP is structured as a remission — not a subsidy — because it is explicitly calibrated to offset only the embedded taxes and levies that are genuinely incurred in the export production process but are not otherwise refunded under any other mechanism (customs drawback, GST input tax credit, CENVAT). The underlying principle is that exported goods should leave India free of any domestic tax burden — a well-established international trade standard known as the destination principle of taxation.

The RoDTEP benefit takes the form of a transferable Duty Credit Scrip (e-scrip) generated electronically in ICEGATE and credited to the exporter's ICEGATE account. The scrip can be used for payment of Basic Customs Duty on future imports, or transferred to another importer who pays for it in Indian rupees. The rate schedule — which specifies the percentage of FOB export value remissible for each export product category identified by an ITC-HS code — was released by the inter-ministerial RoDTEP Committee (chaired by Cabinet Secretary) and published in the RoDTEP Schedule Appendix 4R to the Foreign Trade Policy. Rates vary significantly by product: from 0.01% to over 4.3% of FOB value, with some categories currently at zero rate or excluded entirely. The rates are notified periodically and are subject to revision based on studies of actual embedded tax incidence conducted by the RoDTEP Committee.

To claim RoDTEP, an exporter must declare their RoDTEP claim against each shipping bill at the time of filing with Customs (ICEGATE). The claim is made line-by-line at the item level — each export product in the shipping bill must be mapped to the correct ITC-HS code in the RoDTEP Schedule, and the applicable rate applied to the FOB value of that line item. Once the shipping bill is processed and the Export General Manifest (EGM) is filed by the carrier, the system processes the RoDTEP claim and generates an electronic scroll. The exporter then logs into ICEGATE, selects pending scrolls, and generates the e-scrip — which appears in their ICEGATE LEDGER account and can be transferred or used for duty payment.

The embedded taxes that RoDTEP is designed to remit include: electricity duties paid on power consumed in manufacturing; fuel taxes (VAT/state excise on HSD, LDO, furnace oil) not covered by GST credits; mandi taxes and agricultural cesses on procured inputs; stamp duties on trade documents; environment and pollution control fees; and other state and local levies that form part of the cost of goods exported but are not recoverable under GST ITC or Customs Drawback. The scheme explicitly excludes duties and taxes already refunded under any other mechanism — so correct sequencing of the RoDTEP claim with GST refund claims and Drawback claims is essential to avoid double-claiming, which carries severe penalty consequences under the FTDR Act and Customs Act.

When RoDTEP is directly applicable to your business

You are a manufacturer-exporter or merchant exporter making physical exports of goods (not services) classified under ITC-HS codes that appear in the RoDTEP Schedule with a non-zero rate — covering a wide range of sectors including textiles, engineering, chemicals, pharmaceuticals, agro-products, and consumer goods

Your export production process involves genuine embedded costs of electricity duties, state fuel taxes, mandi fees, environment cesses, or stamp duties — and these are not already being recovered through GST ITC refunds or Customs Duty Drawback

You ship goods from Indian ports or ICDs and file Shipping Bills under Customs that support an IGST refund or Drawback claim — the same Shipping Bill is the basis for the RoDTEP claim and the infrastructure already exists

You are currently claiming RoDTEP but without a systematic rate verification process — the risk that incorrect ITC-HS mapping results in under-claiming (leaving money on the table) or over-claiming (triggering recovery demand) is material in both directions

You hold transferable Duty Credit Scrips from RoDTEP that you are not fully utilising for your own imports — they can be sold in the secondary market to importers who will pay cash, converting the scrip to immediate revenue

Your export volumes are growing and the aggregate RoDTEP entitlement has crossed a threshold where professional management pays for itself many times over in correct claim computation and reduced audit risk

When RoDTEP does not apply or another route is more appropriate

Your exports are of services — RoDTEP is limited to goods exports; services exports are supported through a separate framework (SEIS under the FTP, or its successor mechanism) and are not eligible for RoDTEP scrips

Your export product is in the excluded categories: Special Economic Zone (SEZ) exports processed from within SEZ units are governed by the SEZ Act and are not eligible for RoDTEP; Advance Authorisation imports that benefit from duty-free input imports also have restrictions on simultaneous RoDTEP claims — the schedules specify the intersection

Your product's ITC-HS code is currently in the RoDTEP Schedule at a zero rate or is excluded from the Schedule entirely — in which case there is no current benefit available, though the schedule may be revised

Your business model involves re-export of imported goods without any value-addition or manufacturing in India — the scheme is targeted at goods with Indian production and embedded Indian taxes; re-export without manufacturing generally does not qualify

You are an EOU (Export Oriented Unit) — EOUs have their own duty-free import mechanism under the EOU scheme; the RoDTEP eligibility for EOUs has specific conditions and product-level restrictions that must be separately verified against the latest notifications

The claim amounts for your export volumes are so small that they do not justify the administrative overhead — though this is relatively rare given that even modest export volumes generate meaningful RoDTEP entitlements at even 0.5% of FOB value

Structure Comparison

RoDTEP compared to other export incentive instruments available to Indian exporters

FeatureRoDTEPDuty Drawback (DBK)Advance Authorisation (AA)EPCG Scheme
PurposeRemit embedded state/local taxes not otherwise recoverableRefund customs duty on inputs used in exported goodsDuty-free import of inputs for export productionDuty-free import of capital goods for export manufacturing
Scheme chapter / authorityFTP 2023 Appendix 4R — DGFT / CBICSection 75, Customs Act — CBIC Drawback ScheduleChapter 4, FTP 2023 — DGFTChapter 5, FTP 2023 — DGFT
Benefit formTransferable Duty Credit Scrip (e-scrip) — ICEGATE ledgerCash refund into bank account (All Industry Rate) or creditUpfront duty saving — no import duty paidUpfront duty saving — no import duty paid on capital goods
When benefit is receivedPost-export — after EGM filed and scroll generatedPost-export — typically 3–6 months lag for AIR claimsPre-export — at the time of import, before productionPre-import — at the time of capital goods import
Cash flow impactPost-export scrip — monetised by use or saleCash refund — liquidity benefit post-exportUpfront duty saving — strongest cash flow advantageUpfront duty saving on capex — large one-time benefit
Export obligation binding?No binding EO — entitlement based on each export shipmentNo binding EO — claim per shipmentYes — mandatory EO within 18 months (extendable)Yes — EO typically 6x duty saved over 6 years (extendable)
What taxes/duties are coveredElectricity duty, fuel tax, mandi fees, state cesses, stamps — not covered by GST or DrawbackBasic Customs Duty and Additional Customs Duty on imported inputs used in export goodsBCD, SWS, ADD on imported raw materials, components, packingBCD, SWS on imported capital goods (machinery, equipment)
Can they be combined?Yes — but not on the same inputs as Drawback; RoDTEP and AIR Drawback can be claimed simultaneously if Drawback rate is the partial (Section 75A) rateAIR Drawback and RoDTEP are jointly available but governed by schedule conditions — full AIR Drawback may exclude RoDTEP on the same goodsAA and RoDTEP have specific schedule restrictions — some AA products are excluded from RoDTEPEPCG and RoDTEP can be used simultaneously — EPCG covers capex, RoDTEP covers production levies
AdministrationShipping Bill declaration at Customs; e-scrip generated on ICEGATE; scroll-based claimDrawback schedule claim — filed with Customs; brand rate fixation for non-AIR categoriesDGFT portal — ANF 4A; SION/norm based; DGFT redemption required post-exportDGFT portal — EPCG application; EO certificate; DGFT redemption
Transferability of benefitE-scrip fully transferable — can be sold to third-party importersCash refund — not transferableAA licence is not transferable (except within a group company in limited cases)EPCG licence — limited transferability
WTO compliance positionDesigned explicitly as WTO-compliant remission — offsets only actual embedded taxesAll Industry Rate Drawback — considered WTO-compliant remission; brand rate also compliantSubject to WTO scrutiny if norms are excessive — has been a historic area of trade disputeSubject to WTO scrutiny on export performance conditionality

These schemes are not mutually exclusive and the optimal combination depends on the exporter's product, input structure, and cash flow priorities. RoDTEP and Duty Drawback can frequently be claimed simultaneously but require careful rate schedule verification to avoid double-claiming on the same tax incidence. PNPC advises on the optimal multi-scheme strategy for each exporter's product and production profile.

How it works
#Stage & What PNPC DoesCA Advice Portals Never GiveTimeline
1Pre-Claim Eligibility Mapping — ITC-HS code verification and rate schedule analysisBefore any Shipping Bill is filed, PNPC verifies the RoDTEP Schedule (Appendix 4R) to confirm: (a) the ITC-HS code of each export product appears in the Schedule, (b) the applicable rate is non-zero, (c) any product-level exclusions apply (such as AA-imported input restrictions), and (d) whether the client is in an excluded category (SEZ unit, EOU with specific restrictions). A product misclassified at ITC-HS level can result in either claiming a rate that does not apply (over-claim — triggers recovery demand) or missing the applicable rate entirely (under-claim — money left unclaimed). We also review whether Duty Drawback is being claimed on the same goods and verify that the Drawback rate selected (AIR with or without customs component) is consistent with the RoDTEP claim per the Schedule conditions.Day 1–3 — before the first export Shipping Bill is filed or as a retrospective review for existing exporters
2ICEGATE Account Setup and IEC LinkageRoDTEP e-scrips are generated and maintained in the exporter's ICEGATE account — specifically in the ICEGATE Duty Credit Scrip Ledger. The account must be correctly linked to the exporter's IEC. For exporters who have never used ICEGATE for scrip management (as opposed to merely for Shipping Bill filing through their CHA), PNPC sets up the direct access, verifies IEC-ICEGATE linkage, and confirms that the Authorised Dealer bank is correctly updated on DGFT for the export proceeds FEMA compliance. Without ICEGATE login access to the scrip ledger, generated scrips remain uncollected — a frequently seen situation in our onboarding reviews.Day 1–5 — initial setup; reviewed with each new export product or DGFT update
3Shipping Bill RoDTEP Declaration — Item-level claim at time of filingThe RoDTEP claim must be declared against each line item of the Shipping Bill at the time of filing with Customs — it cannot be added post-facto after the Shipping Bill is processed. Each item entry requires: the correct ITC-HS code (8-digit), the declared FOB value, and the RoDTEP rate claim. PNPC prepares a pre-filing checklist for the exporter and their CHA — specifying the ITC-HS code and applicable RoDTEP rate for each product line — so the CHA can include the declaration accurately in the Shipping Bill filing. A Shipping Bill filed without the RoDTEP declaration cannot be subsequently amended to include it in most cases — the claim is lost for that shipment.Per shipment — pre-filing checklist provided by PNPC for each export consignment
4Export General Manifest Filing and Scroll GenerationAfter the vessel/aircraft departs, the carrier files the Export General Manifest (EGM) with Customs. Once the EGM is filed and the Shipping Bill is 'Let Export' processed, the ICEGATE system generates a RoDTEP scroll — a record of the entitlement. The scroll is visible in the ICEGATE system. The exporter must log into ICEGATE, navigate to the RoDTEP module, select pending scrolls, and generate the e-scrip. PNPC monitors scroll generation for each shipment and initiates e-scrip generation on behalf of the exporter. Scrolls that are not converted to e-scrips within the prescribed period (subject to current ICEGATE time limits) may lapse.Per shipment, within days of EGM filing — PNPC monitors ICEGATE and generates scrips
5E-Scrip Utilisation or Transfer DecisionOnce the e-scrip is generated in the ICEGATE ledger, the exporter has two options: (a) use it directly against their own import Customs duties — the scrip is debited at the time of Bill of Entry filing, or (b) transfer it to another importer (who cannot generate scrips themselves but can use transferred scrips for import duty payment). Transfer is done through ICEGATE — the receiving importer's ICEGATE ID and IEC are required. In the secondary market, RoDTEP scrips typically trade at a discount to face value (the discount reflecting the supply-demand dynamics of the scrip market). PNPC advises on the utilisation vs transfer decision based on the client's own import pipeline and current secondary market pricing.Within days of scrip generation — PNPC advises on optimal utilisation strategy
6Drawback and RoDTEP ReconciliationWhere the exporter is also claiming Duty Drawback on the same exports, PNPC reconciles the two claims to ensure compliance with the Schedule conditions. The All Industry Rate (AIR) Drawback schedule distinguishes between rates that include a customs component and rates that are customs-only — the former precludes RoDTEP on the same goods; the latter is compatible. For clients using Brand Rate Drawback (fixed for their specific product), the interaction with RoDTEP is separately assessed. PNPC prepares a claim reconciliation register — product-by-product, shipment-by-shipment — that documents the basis for both claims and demonstrates no double-claiming.Quarterly — or at each Shipping Bill if volumes are high
7FEMA Compliance — Export Proceeds Realisation and BRC/FIRCRoDTEP claims are linked to the Shipping Bill's export proceeds. FEMA requires that export proceeds be realised within the prescribed period (generally 9 months for Indian exporters into normal countries — shorter for specific categories). PNPC monitors BRC/FIRC receipt for each export Shipping Bill to which a RoDTEP claim is attached. If export proceeds are not realised within the FEMA period, the RBI and DGFT implications must be managed before the scrip entitlement is treated as final. We integrate RoDTEP scrip tracking with the FEMA export proceeds monitoring already in place for our export clients.Quarterly — matched against BRC/FIRC register for each Shipping Bill
8Annual RoDTEP Entitlement Report and Tax TreatmentThe aggregate RoDTEP e-scrips generated in a financial year represent income under the Income-tax Act. The correct tax treatment: RoDTEP scrips are taxable as income of the exporter in the year of receipt (scroll generation is treated as the point of recognition). They are not separately deductible as a reverse of input costs — they are incentive income. For tax purposes, scrips used for import duty payment are deductible against the cost of imports. Transferred scrips generate sale proceeds taxable as business income. PNPC prepares the annual RoDTEP entitlement statement and provides the accounting treatment guidance for year-end financial statement preparation.Annually — pre-March and post-March close
9Audit Response and Compliance DefenseCustoms or DGFT may audit RoDTEP claims — querying the ITC-HS classification used, the rate applied, the FOB values declared, and the consistency with Drawback claims filed. PNPC maintains the complete RoDTEP claim file: Shipping Bills, ITC-HS rate schedule references, Drawback claim register, and e-scrip statements. On receipt of an audit notice, we prepare the factual and legal response demonstrating that the rate claimed was the scheduled rate for the declared ITC-HS code, applied correctly to the FOB value, with no overlap with Drawback or AA benefit. The defence file is prepared at the time of each shipment — not assembled in response to an audit query.As needed — PNPC maintains live claim files for audit readiness
10Retrospective Review for Existing Exporters — Recovery of Unclaimed EntitlementsMany exporters have been shipping goods since January 2021 without correctly claiming RoDTEP (filing without the declaration, filing with an incorrect ITC-HS rate, or generating scrolls but not converting them to e-scrips). PNPC conducts a retrospective eligibility review: we access the Shipping Bill history, identify unclaimed or under-claimed shipments, and evaluate whether amendment or supplementary claim mechanisms are available. Where the claim window has not expired, we initiate recovery of the unclaimed entitlement. Where it has, we document the loss and put in place forward-looking claim procedures.One-time — on initial engagement of existing exporters
11FTP Policy Update Monitoring and Rate Revision ResponseThe RoDTEP rate schedule is subject to periodic revision by the inter-ministerial RoDTEP Committee. When rates are revised — upward or downward — the effective date and transition provisions matter for shipments straddling the revision date. Product additions and deletions from the Schedule also occur. PNPC monitors DGFT notifications and trade circulars, updates the client's rate schedule master, and communicates the revised rates and their effective date to the export team before the next Shipping Bill filing.Continuous — PNPC issues client advisories on all RoDTEP rate/schedule changes
12RoDTEP for SEZ and EOU Exporters — Specific Eligibility DeterminationSEZ units exporting from within the SEZ are generally not eligible for RoDTEP (their export mechanism is governed entirely by the SEZ Act). However, DTA (Domestic Tariff Area) units supplying to SEZ units may have specific claims. EOUs have partial eligibility — the Schedule specifies which products and categories are eligible for EOU exporters. PNPC separately assesses EOU and SEZ-adjacent clients and provides a written eligibility opinion before any claim is filed — incorrect eligibility determination by an EOU exporter has resulted in demand and penalty in multiple CBIC enforcement actions.At onboarding and on each regulatory change affecting EOU/SEZ RoDTEP scope

RoDTEP is a per-shipment entitlement — it is claimed at the Shipping Bill level and generated as a scrip after EGM filing. There is no annual registration or advance licence required. The process is simpler than Advance Authorisation but requires accurate ITC-HS classification, rate schedule vigilance, and consistent scroll-to-scrip conversion to avoid losing entitlements. PNPC manages this as a continuous compliance process rather than a one-time filing.

Document Checklist
Export Infrastructure Documents (one-time setup)

Valid IEC (Importer Exporter Code) — active and annually updated via DGFT portal; IEC must be linked to the current ICEGATE account for scrip generation

GST registration certificate — mandatory for claiming RoDTEP; GST number must be declared on the Shipping Bill

ICEGATE account login credentials — direct access to the exporter's ICEGATE ledger for monitoring scrolls and generating e-scrips; not just CHA delegate access

Authorised Dealer Bank details — name, IFSC, and account number registered with DGFT for FEMA export proceeds monitoring; must be updated if bank account changes

RCMC (Registration-cum-Membership Certificate) from the relevant Export Promotion Council — required for certain RoDTEP-eligible categories, particularly where the schedule specifies EPC membership

List of export products with 8-digit ITC-HS codes and verified RoDTEP rate from the current Schedule Appendix 4R — PNPC prepares this master rate list as part of the onboarding process

Per-Shipment Export Documents

Shipping Bill (SB) — the primary document; must include RoDTEP declaration at item level, with correct ITC-HS code and rate; obtained from ICEGATE post-processing

Commercial Invoice — showing the FOB value per product line; the FOB value is the basis for computing the RoDTEP entitlement (rate% × FOB value per item)

Packing List — supporting the item-level quantities and values declared in the Shipping Bill

Bill of Lading / Airway Bill — confirming the export shipment; required for EGM filing by the carrier, which triggers scroll generation

Export General Manifest (EGM) — filed by the carrier post-departure; PNPC tracks EGM filing dates for each shipment to monitor scroll generation timing

Let Export Order from Customs — confirming the Shipping Bill has been cleared for export; the LET Export date is the basis for the RoDTEP entitlement date

FEMA and Proceeds Realisation Documents

Bank Realisation Certificate (BRC) — issued by the AD bank confirming receipt of export proceeds; required for RoDTEP compliance and FEMA closure of the export transaction

Foreign Inward Remittance Certificate (FIRC) — for wire transfer proceeds; proves the foreign exchange was received against the specific export invoice

Export invoice with HS code, FOB value, and buyer details — must match the Shipping Bill declaration; discrepancies between the invoice and the SB are a frequent audit trigger

Export Declaration Form (EDF) — the exchange control declaration filed with the AD bank at the time of export (the earlier GR/SDF/PP forms were consolidated into the EDF); linked to the Shipping Bill and tracked through to BRC/FIRC closure

Scrip Management Documents

ICEGATE RoDTEP Scroll Statement — downloaded from ICEGATE showing pending scrolls awaiting conversion to e-scrips; PNPC downloads this monthly for each client

E-Scrip Certificate — generated from ICEGATE on conversion of scroll; contains scrip number, value, validity date, and transferability details

Scrip Transfer Request (if selling/transferring) — buyer's IEC, ICEGATE ID, and transfer value; documentation for the transfer transaction on ICEGATE

Scrip Utilisation Record (if using against imports) — Bill of Entry number, scrip amount debited, import duty paid via scrip; maintained as part of the duty payment record

Drawback and Multi-Scheme Reconciliation Documents

Duty Drawback claim statements (Form DBK-I / shipping bill drawback endorsement) — required to verify that the Drawback rate claimed does not include the customs component that would exclude RoDTEP eligibility on the same goods

Advance Authorisation utilisation register — where the exporter also holds active AAs, PNPC verifies that inputs imported under the AA are correctly excluded from the RoDTEP rate calculation where the Schedule so requires

RoDTEP-Drawback reconciliation register — maintained by PNPC per product category showing the rate basis, the claim amount, and the non-overlap certification; produced for each quarter and available for audit

Accounting and Tax Documents

Annual RoDTEP entitlement statement — e-scrips generated during the financial year, organised by quarter and Shipping Bill; provided by PNPC for the statutory auditor and income-tax return preparation

Scrip sale proceeds statements — where scrips were transferred/sold in the secondary market; treated as business income and reflected in the P&L account

Scrip utilisation against import duty — accounting entry: debit import duty expense, credit scrip utilisation (assets ledger); PNPC provides the accounting guidance for each transaction type

Income tax computation note — PNPC provides a brief note for the ITR filing explaining the RoDTEP income recognition and treatment, ensuring the statutory auditor and the tax team are aligned

Ongoing obligations
PhaseTriggered ByPNPC CA GuidanceRisk If Ignored
Rate Schedule VerificationNew export product or ITC-HS code change, or RoDTEP schedule revision notificationPNPC verifies the ITC-HS code in the current RoDTEP Schedule Appendix 4R, confirms the applicable rate, and checks for any product-specific exclusions (AA imports, EOU status, SEZ). Updates the client's master rate list.Filing Shipping Bills with an incorrect ITC-HS code or rate — either over-claiming (recovery demand plus interest plus penalty) or under-claiming (permanent revenue loss, as past SBs cannot usually be amended).
Shipping Bill DeclarationEach export shipmentPNPC provides the CHA with a per-consignment declaration checklist specifying the ITC-HS code and RoDTEP rate for each export product line. The CHA includes this in the Shipping Bill item entry before filing.A Shipping Bill filed without RoDTEP declaration cannot be amended post-facto in most cases. The RoDTEP entitlement for that shipment is permanently lost — no appeal or correction mechanism exists after Let Export Order.
EGM Filing and Scroll GenerationVessel/aircraft departure and carrier EGM filingPNPC monitors the shipping bill status on ICEGATE to confirm EGM filing and scroll generation. Typically within 3–7 days of vessel departure. PNPC flags delays — if EGM is not filed, the scroll is not generated and the scrip does not appear.Carrier EGM delays or errors (wrong IEC, HS code mismatch) can block scroll generation. Without monitoring, these go undetected for months. Scroll generation windows may be time-bound under ICEGATE system parameters.
E-Scrip GenerationScrolls visible in ICEGATEPNPC logs into ICEGATE, selects pending scrolls, and converts them to e-scrips. The e-scrip is issued with a validity period. PNPC confirms the scrip amount matches the expected entitlement (rate × FOB). Discrepancies are queried with ICEGATE helpdesk.Scrolls not converted to e-scrips within validity limits are forfeited — permanent entitlement loss. Many exporters who manage their own ICEGATE access have months of unconverted scrolls sitting in their accounts.
Utilisation or Transfer DecisionE-scrip in ICEGATE ledgerPNPC evaluates the exporter's import pipeline: if significant customs duty imports are expected within 12 months, utilisation is preferred (face value realised). If imports are unlikely, transfer is advised — PNPC identifies buyers (typically large importers) and coordinates the ICEGATE transfer at the agreed price.E-scrips that expire before utilisation or transfer are permanently lost. Scrips have a defined validity period and cannot be extended. For exporters who do not monitor their scrip ledger, expiry of accumulated scrips is a known and preventable loss.
Drawback ReconciliationQuarterly, or at the time of Drawback claim filingPNPC reconciles the Drawback schedule rate used for each product (AIR with or without customs component) against the RoDTEP claim — confirming that the combination is permitted under the Schedule conditions. A reconciliation register is maintained and updated each quarter.Claiming both AIR Drawback (customs component) and RoDTEP on the same goods is double-claiming — a violation of both the Customs Act and the FTDR Act. CBIC enforcement actions for double-claiming have resulted in demand of double the benefit amount plus penalty.
FEMA Proceeds MonitoringEach export Shipping Bill linked to RoDTEP claimPNPC integrates RoDTEP tracking with the FEMA export proceeds register. BRC/FIRC receipt is monitored for each Shipping Bill. Unrealised proceeds beyond the FEMA deadline (generally 9 months) are escalated to the exporter for regularisation before the RBI compound application window.Unrealised export proceeds where RoDTEP has been claimed attract both FEMA enforcement (compounding proceedings with the RBI) and a question over the validity of the scrip issued on the unreaised shipment.
Annual Tax AccountingFinancial year-endPNPC prepares the annual RoDTEP entitlement statement — total scrips generated, scrips used for duty, scrips transferred, scrips outstanding. This forms the basis for the RoDTEP income line in the statutory accounts and the relevant income-tax return disclosure (ITR-3/ITR-5/ITR-6 depending on whether the exporter is a proprietorship, partnership/LLP, or company). The correct accounting standard (AS-12 for government grants or revenue recognition) is applied based on the nature of the scrip.Incorrect income recognition — especially deferring recognition of scrips to the period of utilisation rather than generation — can result in incorrect advance tax computation and disallowance questions during income-tax scrutiny.
Audit DefenceCBIC or DGFT audit notice — can occur 2–5 years after shipmentPNPC maintains the complete claim file: SB copies, rate schedule reference, FOB value computation, Drawback claim cross-reference, and e-scrip statements. On audit notice, PNPC prepares the factual response within 15 days — demonstrating the correct ITC-HS, the correct rate, and the non-overlap with other benefits.Exporters who cannot produce the original SBs, rate schedule reference, and Drawback cross-reference for audited shipments face presumptive disallowance of the claim and demand for recovery plus interest from the date of scrip utilisation.
Frequently asked
What is RoDTEP and how does it differ from MEIS?

RoDTEP — Remission of Duties and Taxes on Exported Products — replaced the MEIS (Merchandise Exports from India Scheme) effective 1 January 2021. MEIS provided a fixed percentage benefit on FOB value as a general export incentive — it was ruled a prohibited export subsidy by the WTO Dispute Settlement Body (DS541 — India — Export Related Measures). RoDTEP was redesigned as a remission-based scheme: it only compensates exporters for actual embedded taxes that are genuinely incurred in the production and export process but not otherwise recoverable under GST or Customs Drawback. The benefit form also changed: MEIS issued paper scrips; RoDTEP generates electronic e-scrips directly in the ICEGATE system, making the process faster and more transparent. The RoDTEP rates are set by an inter-ministerial committee based on actual tax incidence studies — not on FOB value as a proxy for export support.

Practitioner noteExporters who benefited from MEIS should be aware that RoDTEP rates for many product categories are lower than equivalent MEIS rates were — because RoDTEP is calibrated to actual embedded tax incidence, not as a broad export promotion tool. Revenue planning and pricing should reflect the current RoDTEP rate, not the MEIS rate from pre-2021 calculations.
Who is eligible to claim RoDTEP?

RoDTEP is available to exporters making physical exports of eligible goods under a Shipping Bill filed with Indian Customs (ICEGATE). The exporter must have a valid IEC (Importer Exporter Code), be registered for GST, and export products whose ITC-HS code appears in the RoDTEP Schedule (Appendix 4R of the FTP) at a non-zero rate. Both manufacturer-exporters (who produce the goods they export) and merchant exporters (who buy and export goods produced by third parties) are eligible. Service exporters are not eligible for RoDTEP — services have a separate incentive framework.

Practitioner noteMerchant exporters can claim RoDTEP on goods they export even if they did not manufacture them. The scheme is based on the export Shipping Bill — not on the identity of the manufacturer. However, the RoDTEP rate reflects the embedded taxes on the production of the goods, which the merchant exporter did not directly pay. The scheme's calibration to actual tax incidence is at the sector/product level, not the individual taxpayer level.
How is the RoDTEP benefit amount calculated?

The RoDTEP benefit is calculated as a percentage of the FOB (Free On Board) value of the exported goods at the item level in the Shipping Bill. The applicable percentage is the rate specified in the RoDTEP Schedule (Appendix 4R) for the ITC-HS code of the export product. For example, if the rate for a product is 1.5% and the FOB value of the exported goods in a Shipping Bill is ₹10 lakh, the RoDTEP entitlement for that line item is ₹15,000. Where a Shipping Bill contains multiple products with different ITC-HS codes, each line item is computed separately using the applicable rate for that product's HS code. The aggregate across all eligible line items is the total scroll value.

Practitioner noteThe FOB value declared in the Shipping Bill is the basis — not the invoice value or the realised proceeds. Discrepancies between the invoice value, the Shipping Bill FOB value, and the bank realised amount are common in foreign exchange fluctuation scenarios and need to be documented carefully to avoid audit questions.
Which product categories are currently included in the RoDTEP Schedule?

The RoDTEP Schedule (Appendix 4R of the FTP) covers a wide range of manufacturing sectors including: textiles and apparel, engineering goods, chemicals, plastics, leather, agro-processed goods, marine products, gems and jewellery (with conditions), pharmaceuticals, electrical and electronic products, and various consumer goods. Not all ITC-HS codes within these sectors are at non-zero rates — the Schedule specifies rates at the 8-digit ITC-HS level for each eligible product. Certain categories are currently at zero rate (meaning the notified rate is 0.00%) or are excluded from the Schedule entirely. Zero rate products may have their rates revised upward in subsequent Schedule updates.

Practitioner noteThe RoDTEP Schedule is a detailed document spanning hundreds of pages — verifying the applicable rate for a specific 8-digit ITC-HS code requires careful reading of the schedule, including any footnotes and conditions attached to specific entries. We see frequent errors where exporters apply a rate for a 6-digit parent code when the 8-digit sub-heading has a different (or zero) rate.
When must the RoDTEP declaration be made — can it be added after the Shipping Bill is filed?

The RoDTEP declaration must be made at the item level in the Shipping Bill at the time of filing with Customs (ICEGATE). The CHA (Customs House Agent) who files the Shipping Bill must include the RoDTEP claim against each product line before the Shipping Bill is submitted. Once the Shipping Bill is processed — Let Export Order granted by Customs — it generally cannot be amended to add or change the RoDTEP declaration. CBIC has not provided a general amendment mechanism for RoDTEP declarations on processed Shipping Bills. An unclaimed Shipping Bill means that RoDTEP entitlement is permanently lost for that shipment.

Practitioner noteThis is the most consequential process requirement in RoDTEP. We have onboarded exporters whose CHAs were filing Shipping Bills without RoDTEP declarations because they were not instructed to include it — the exporter did not realise the entitlement was being lost with every shipment. We immediately audit the last 12 months of Shipping Bills on onboarding to identify unclaimed entitlements and assess recovery options.
What is an ICEGATE scroll and how does the e-scrip get generated?

After the export Shipping Bill is processed and the carrier files the Export General Manifest (EGM) confirming the goods have departed India, the ICEGATE system automatically generates a RoDTEP scroll — an electronic record of the claim entitlement for that Shipping Bill. The scroll appears in the exporter's ICEGATE account. The exporter (or their authorised agent) must then log into ICEGATE, navigate to the RoDTEP module, select the pending scrolls, and click to generate the e-scrip. The e-scrip is then credited to the ICEGATE Duty Credit Scrip Ledger with a unique scrip number, value, and validity period. The e-scrip can be used for Customs duty payment or transferred to another party.

Practitioner noteThe step from scroll to e-scrip is manual — it requires someone to log into ICEGATE and take the conversion action. Many small and medium exporters are unaware of this step (their CHA handles the Shipping Bill filing but does not manage the scrip ledger), and their ICEGATE accounts accumulate months of unconverted scrolls. We take over ICEGATE scrip management for all export clients as part of our RoDTEP service.
Can RoDTEP e-scrips be transferred or sold?

Yes. RoDTEP e-scrips are fully transferable. An exporter who does not have sufficient import duty liability to utilise the scrips themselves can transfer them to another party — typically an importer who needs to pay Customs duty on their imports. The transfer is executed through ICEGATE: the scrip holder initiates a transfer specifying the recipient's IEC and ICEGATE account, and the scrip is moved from the sender's ledger to the recipient's ledger. The recipient can then use the transferred scrip against their import Customs duty. In the secondary market, RoDTEP scrips typically trade at a discount to face value — the discount varies based on scrip supply, market demand from importers, and current import duty collection trends.

Practitioner noteThe ability to transfer scrips means RoDTEP has a cash equivalent value even for exporters who have no imports. We help exporters identify scrip buyers — typically large importers in the auto, FMCG, or infrastructure sector who have predictable import duty bills and prefer to buy RoDTEP scrips at a discount over paying full duty cash. The pricing is negotiated and PNPC facilitates the transaction.
What is the validity period of RoDTEP e-scrips?

RoDTEP e-scrips are issued with a validity period — as notified by CBIC from time to time. The current validity period and any extension notifications must be checked against the applicable CBIC circular at the time of scrip generation, as the government has periodically extended validity for scrips affected by operational delays. An e-scrip that expires before being used or transferred is permanently lost — there is no reissuance or extension of individual expired scrips. This makes timely scrip generation and active ledger management essential.

Practitioner noteWe issue a quarterly ICEGATE scrip ledger report for each client — showing scrips by generation date, value, validity, and utilisation status. Any scrip within 90 days of expiry triggers an immediate action plan: either identify an import to apply it against, or initiate a transfer to a buyer. Scrip expiry is an avoidable loss and we track it proactively.
Can RoDTEP and Duty Drawback be claimed simultaneously on the same export?

This requires careful analysis of the Drawback rate claimed. The All Industry Rate (AIR) Drawback schedule lists two types of rates for each product: a rate that includes both customs and central excise components, and a rate that covers customs duty only. The RoDTEP Schedule specifies whether a product is eligible for RoDTEP and whether the drawback restriction applies. Generally, where the Drawback AIR rate claimed includes the customs component, the product may be restricted from also claiming RoDTEP — to prevent double recovery of the same duty. Where only the customs-specific rate is claimed under Drawback, RoDTEP may be available for the residual state/local levies component. The exact treatment is specified in the applicable notifications and schedule footnotes.

Practitioner noteThis is an area of genuine complexity and frequent error. We prepare a product-level reconciliation matrix for each client — showing Drawback rate type, RoDTEP eligibility, and the permitted combination. An incorrect combination (claiming both full AIR Drawback and full RoDTEP) is double-claiming under the Customs Act — it is not a technical error, it is a statutory violation that attracts demand of twice the excess benefit plus penalty.
Is RoDTEP available on exports made against Advance Authorisation?

Goods exported against an Advance Authorisation (AA) — where duty-free inputs were imported under the AA — have a specific position in the RoDTEP Schedule. The Schedule specifies which product categories are eligible for RoDTEP even when AA inputs were used, and which are excluded or restricted. The rationale is that if the exporter has already received the benefit of duty-free input imports under the AA, the embedded tax component that RoDTEP is designed to remit may be lower — and the Schedule calibrates accordingly. Exporters using AA must verify on a product-by-product basis whether their goods are eligible for RoDTEP and at what rate.

Practitioner noteClaiming RoDTEP at the full scheduled rate on exports where AA inputs were used — where the Schedule restricts this — is an over-claim. CBIC has issued enforcement circulars on this specific combination. We verify AA/RoDTEP eligibility for each product category before the first Shipping Bill is filed under a new AA.
Are SEZ and EOU exporters eligible for RoDTEP?

SEZ units exporting goods from within the Special Economic Zone are generally not eligible for RoDTEP under the standard scheme — their export mechanism is governed by the SEZ Act and they benefit from a comprehensive duty and tax exemption framework within the zone. DTA (Domestic Tariff Area) units supplying to SEZ units may have separate eligibility depending on whether the supply is treated as a deemed export. EOUs (Export Oriented Units) have partial and product-specific eligibility — certain categories of EOU exports are eligible for RoDTEP and certain are excluded or at zero rates, as specified in the RoDTEP Schedule and the EOU notifications. EOU eligibility was introduced in a phased manner and the applicable conditions must be verified against the current notifications.

Practitioner noteEOU clients frequently contact us after claiming RoDTEP without verifying EOU-specific eligibility conditions — and then facing CBIC queries. We provide a written eligibility opinion for EOU and SEZ-adjacent businesses before any claim is filed, updated each time CBIC issues a fresh notification on EOU/RoDTEP eligibility.
What embedded taxes does RoDTEP actually remit — what is it based on?

RoDTEP is designed to remit the following categories of embedded duties and taxes incurred in the production and export of goods, to the extent they are not otherwise recoverable under GST ITC refunds or Customs Drawback: (a) electricity duties/development cess paid on power consumed in manufacturing; (b) VAT/state excise on fuel (HSD, LDO, furnace oil) used in production — since GST does not cover petroleum products, these fuel taxes are not claimable as ITC; (c) mandi fees and agricultural market committee cesses on agricultural produce inputs; (d) stamp duties on trade documents; (e) environment protection fees and pollution control cesses at the state level; (f) embedded CGST/SGST/IGST paid on inputs that does not flow into exportable ITC for technical reasons. The RoDTEP rate for each product category is set by studying the average incidence of these taxes across producers of the export product.

Practitioner noteThe rates are calibrated at the sector level based on average embedded tax incidence — individual companies may have higher or lower actual embedded taxes. There is no mechanism to claim a higher rate based on actual embedded cost — you are limited to the scheduled rate. This means efficient manufacturers with lower embedded tax costs benefit relatively more from the scheme.
What is the RoDTEP rate schedule — where is it published and how often is it updated?

The RoDTEP rate schedule is published as Appendix 4R of the Foreign Trade Policy, as periodically notified by the Ministry of Commerce and Industry. The original Schedule was released via a Gazette Notification in August 2021 with effect from exports on or after 1 January 2021. Subsequent revisions and additions to the Schedule have been made through fresh Gazette notifications — typically covering product categories that were initially at zero rate or excluded. The Schedule is maintained online on the DGFT website (dgft.gov.in) and the Ministry of Commerce website. Any revision to rates has a specific effective date — rates do not apply retrospectively to shipments before the revision date.

Practitioner noteThe schedule is a large document and navigating it accurately for a client's specific ITC-HS codes requires careful reading — including footnotes, conditions, and cross-references to other policy instruments. We maintain a client-specific rate sheet updated within one week of any DGFT or Ministry of Commerce notification revising the Schedule.
How does RoDTEP work for exports of goods with multiple ITC-HS codes in a single Shipping Bill?

A Shipping Bill can contain multiple line items, each with a different ITC-HS code, FOB value, and quantity. The RoDTEP claim is computed separately for each line item — the applicable rate for each product's ITC-HS code is applied to the FOB value of that line item. Products with a zero RoDTEP rate or excluded from the Schedule contribute zero to the total claim. The sum of all eligible line items' RoDTEP entitlements is the total scroll value for that Shipping Bill. The CHA must declare the RoDTEP claim against each eligible line item individually in the Shipping Bill — a single lump sum declaration for the whole Shipping Bill is not supported by the ICEGATE system.

Practitioner noteFor exporters with diverse product ranges in a single Shipping Bill, the per-item rate verification and declaration process is where most errors occur. We provide the CHA with a pre-filing declaration template that lists each product line, its ITC-HS code, the applicable RoDTEP rate, and the estimated entitlement — making the CHA's filing work more accurate and reducing the risk of missed or incorrect declarations.
Is RoDTEP income taxable under the Income-tax Act?

Yes. RoDTEP e-scrips represent an economic benefit received by the exporter and are taxable as business income under the applicable income-tax law. The correct tax treatment: RoDTEP income should be recognised as business income in the year in which the scrip is generated (scroll converted to e-scrip in ICEGATE). It is not a capital receipt. When scrips are used to pay Customs duty on imports, the scrip utilisation reduces the duty payment cost (not separately deductible — the import cost is net of the scrip used). When scrips are transferred/sold, the sale proceeds are taxable as business income in the year of sale. There is no specific income-tax exemption carved out for RoDTEP receipts.

Practitioner noteWe see clients who have not accounted for RoDTEP scrips as income for 2–3 years after the scheme started — treating them as off-balance-sheet items. When the ITR is scrutinised, the ICEGATE scrip data is available to CBIC and can be accessed by income-tax authorities through data sharing. Unaccounted scrips create both income-tax and accounting compliance gaps. We regularise this in the year of onboarding. Clients should confirm the current return-filing form and section references with us each year, since income-tax provisions and form numbers are periodically renumbered/updated.
Can past Shipping Bills be revised to claim RoDTEP that was missed at the time of filing?

CBIC has not provided a general mechanism to amend processed Shipping Bills retrospectively to add a RoDTEP declaration that was omitted at the time of filing. In general, a Shipping Bill processed with Let Export Order cannot be amended to add new claims — the ICEGATE system does not support this for RoDTEP declarations post-processing. CBIC has issued limited special windows for specific periods and product categories, but these are exceptional and not a standard feature of the scheme. Exporters who have been missing RoDTEP declarations must treat the historical unclaimed amounts as a permanent loss (except in any officially notified correction window) and implement the correct process going forward.

Practitioner noteThis is why we conduct the historical Shipping Bill review immediately on onboarding — to assess the scale of unclaimed entitlement and determine whether any correction mechanism is currently available. We also quantify the prospective annual entitlement so the client understands the financial impact of the historical miss and the forward benefit of correct compliance.
What are the consequences of over-claiming RoDTEP — claiming a higher rate or incorrect ITC-HS code?

Over-claiming RoDTEP — whether by applying a higher rate than the schedule specifies for the product's ITC-HS code, misclassifying the product to a higher-rate HS code, or claiming on products that are excluded from the Schedule — constitutes a statutory violation under the FTDR Act 1992 and the Customs Act 1962. Consequences include: recovery of the excess scrip value (or equivalent cash if the scrip has been utilised), interest on the excess amount from the date of scrip generation, and penalty which can extend to the excess scrip value (i.e., effectively doubling the recovery). If the over-claim is systemic (same error across many Shipping Bills), the aggregate demand can be significant. The CBIC has the right to audit RoDTEP claims for a period of years after the scrip is generated.

Practitioner noteOver-claiming is treated as seriously as customs fraud — the scrip is equivalent to money, and over-claiming is misappropriation of public funds. We take a conservative approach to rate verification: if there is any doubt about the correct ITC-HS classification or whether a product-specific exclusion applies, we take a written position based on the Schedule and applicable notifications before the first Shipping Bill is filed.
What FEMA obligations does an exporter have in connection with RoDTEP claims?

RoDTEP claims are based on Shipping Bills — each Shipping Bill represents an export transaction where foreign exchange proceeds are expected from the overseas buyer. Under FEMA (Foreign Exchange Management Act), an exporter must realise and repatriate export proceeds within the prescribed period — generally 9 months from the date of export for exports to most countries (shorter periods apply to certain categories and destinations). Where RoDTEP has been claimed on a Shipping Bill and the export proceeds are not realised within the FEMA period, the situation creates both a FEMA violation (unrealised proceeds) and a question on the RoDTEP scrip issued — since the export may be contested as incomplete. PNPC manages FEMA proceeds monitoring alongside RoDTEP claim tracking to ensure the two are consistent.

Practitioner noteFor exporters who write off bad debts on export transactions — where the overseas buyer does not pay — the Shipping Bill remains open under FEMA. Any RoDTEP scrip generated on that Shipping Bill should be reviewed for write-back if the export is ultimately treated as non-realised. This is a nuanced area requiring both FEMA and income-tax analysis.
How is RoDTEP treated in the company's accounts — under which accounting standard?

RoDTEP scrips are government assistance and their accounting treatment is governed by AS-12 (Accounting Standard for Government Grants) or its IND-AS equivalent (IAS 20 under IND-AS framework). The e-scrip, once generated in ICEGATE, represents a measurable government grant — it should be recognised as income in the year of generation (income approach — most commonly applied) or netted against the related export cost (netting approach, less common). The scrip balance in the ICEGATE ledger is an asset to be shown in the balance sheet (current assets — duty credit scrip) until utilised or transferred. At year end, PNPC provides the scrip ledger balance and movement summary for the statutory auditor.

Practitioner noteSome clients argue for recognition on utilisation rather than generation — deferring the tax liability. We advise against this: the scrip is a freely transferable liquid asset the moment it is generated. Deferring recognition creates a timing mismatch that income-tax scrutiny routinely picks up on. Consistent with-generation recognition is the cleaner and more defensible position.
Can a 100% EOU claim RoDTEP on its exports?

EOU (Export Oriented Unit) eligibility for RoDTEP has been notified in a phased and product-specific manner. CBIC initially excluded EOUs from the RoDTEP scheme when it launched in January 2021. Subsequently, the government extended RoDTEP benefits to EOUs for specific product categories, subject to conditions notified in specific Customs/DGFT circulars. The eligible categories and applicable rates for EOU exports may differ from the standard Appendix 4R rates applicable to DTA (Domestic Tariff Area) exporters. An EOU contemplating RoDTEP claims must verify the current notification applicable to its product category and the conditions attached (including whether the EOU-specific rate is the same as or different from the DTA rate).

Practitioner noteEOU clients need a separate eligibility opinion — not just a reference to Appendix 4R. The EOU eligibility framework for RoDTEP has been amended multiple times and the applicable notification at the time of each export is what governs eligibility. We maintain a separate EOU RoDTEP eligibility tracker and update it with each CBIC circular.
Is there a minimum export value threshold to claim RoDTEP?

There is no minimum export value threshold specified in the RoDTEP scheme for eligibility. Any exporter with a valid IEC and Shipping Bill for an eligible product can claim RoDTEP — whether the export is ₹1 lakh or ₹100 crore. However, the scrip is generated at the ICEGATE level — very small scrip amounts (in the range of hundreds of rupees on small export shipments) are technically generated but may be impractical to transfer in the secondary market. Practically, the scheme is most impactful for exporters with recurring export volumes and meaningful absolute scrip values.

Practitioner noteWe have onboarded small exporters whose per-shipment RoDTEP is a few thousand rupees — but where aggregate annual scrips add up to several lakhs. Even small scrips are worth claiming and accumulating for use against imports or transfer in bulk. The process overhead per shipment is low once the rate master and CHA briefing are set up.
What is a Brand Rate under Duty Drawback and how does it interact with RoDTEP?

A Brand Rate of Drawback is a product-specific, company-specific Drawback rate fixed by CBIC for an exporter whose actual duty on inputs exceeds the All Industry Rate (AIR) for their product. Brand Rate fixation requires the exporter to apply with detailed input cost data and the customs duty actually paid on inputs. Brand Rate Drawback can be higher than AIR, is fixed for a defined period, and requires annual renewal application. The interaction with RoDTEP: where a Brand Rate includes recovery of customs duty on inputs, the same RoDTEP Schedule exclusion logic applies as with AIR Drawback — double recovery of the same duty incidence is prohibited. The specific treatment depends on whether the Brand Rate covers only customs duty, or also central excise surrogate levies, and whether the RoDTEP Schedule permits the combination for that product.

Practitioner noteBrand Rate exporters are a smaller subset — typically manufacturers with unique or complex input structures. If you have a Brand Rate, the RoDTEP eligibility analysis requires a line-by-line comparison of what the Brand Rate covers versus what RoDTEP is designed to remit for your product category. This is a bespoke analysis and cannot be generalised from the standard AIR Drawback logic.
Can RoDTEP be claimed on exports made to Nepal, Bhutan, or other neighbouring countries with special trade arrangements?

RoDTEP is available on exports made under Shipping Bills filed with Indian Customs — the destination country does not affect eligibility in principle. Exports to Nepal and Bhutan have historically used a specific documentary procedure (export under treaty arrangements) and the Shipping Bill mechanism applies. However, RoDTEP eligibility should be verified against the specific notification and any trade-treaty-specific exclusions that may apply. Exports under the SAARC Preferential Trading Arrangement (SAPTA) or bilateral trade agreements do not automatically restrict RoDTEP unless a specific notification excludes such exports. In practice, most physical goods exports to neighbouring countries via normal Shipping Bill procedures are eligible.

Practitioner noteFor Nepal and Bhutan exports specifically — where truck consignments often use a streamlined border documentation process rather than the standard ICEGATE Shipping Bill — confirming that the export is recorded in ICEGATE under a standard Shipping Bill is a prerequisite for any RoDTEP claim. Export documentation that bypasses ICEGATE cannot generate a RoDTEP scroll.
What happens if the ITC-HS code of an export product changes due to reclassification?

ITC-HS codes are periodically updated through Customs Tariff notifications aligned with the international HS Convention review cycles (typically every 5 years) and through domestic clarification circulars. When an export product's ITC-HS code changes: (a) the applicable RoDTEP rate for the new code may be different from the previous code — it must be verified in the updated Schedule, (b) Shipping Bills filed after the reclassification date must use the new code, (c) historical Shipping Bills used the old code which is appropriate for that period. An ITC-HS reclassification that results in a higher RoDTEP rate is beneficial; one that results in a lower rate (or zero/excluded status) requires immediate review of the product's incentive economics.

Practitioner noteWe monitor the Customs Tariff for HS code amendments and immediately update the client's rate master when a change affects their export products. An exporter who continues to use an old HS code after the reclassification date on ICEGATE may be filing with an invalid code — which can cause processing errors or incorrect rate claims.
Are export samples and gifts eligible for RoDTEP?

Export samples and gifts are exported under a Shipping Bill and in principle follow the same eligibility rules as commercial exports. However, export samples are frequently shipped at nil value or notional value — the RoDTEP entitlement is a percentage of the declared FOB value, so a nil-value or very low-value sample generates a correspondingly negligible RoDTEP entitlement. Export of gifts up to the free allowance thresholds under the Customs Act may use a different Shipping Bill type. In either case, the RoDTEP declaration mechanism at the Shipping Bill level applies — if the CHA includes the RoDTEP claim, an entitlement (however small) is generated.

Practitioner noteWe generally advise clients not to focus on RoDTEP for samples — the entitlement is negligible and the cost of error (incorrect HS code on a sample Bill) is disproportionate. The effort is better directed at ensuring commercial export Shipping Bills are consistently declared correctly.
Does RoDTEP apply to re-exports?

Re-export of imported goods (without manufacturing or value addition in India) generally does not attract RoDTEP — the scheme is designed to remit embedded taxes incurred in Indian production. A purely commercial re-export with no Indian value addition involves no embedded state or local taxes in Indian manufacturing. The Shipping Bill for a re-export will typically use a different Shipping Bill type (re-export under Section 26 of the Customs Act) and the RoDTEP declaration on such bills would be inappropriate. Additionally, if the goods were imported under a customs duty exemption (e.g., under an AA or Customs exemption notification) and are being re-exported, the re-export procedure may have its own drawback mechanism.

Practitioner noteClients who operate as trading intermediaries — importing finished goods and re-exporting without processing — should not be claiming RoDTEP. If a trading intermediary claims RoDTEP by treating re-exports as standard exports, it is an improper claim under the scheme.
How does PNPC manage RoDTEP for exporters with large volumes — hundreds of Shipping Bills per month?

For high-volume exporters, PNPC implements a systematic RoDTEP management process: (1) a master rate table by ITC-HS code is prepared and updated with each Schedule revision, (2) a standing pre-filing instruction is issued to the CHA specifying the RoDTEP declaration for each product line — reviewed and updated each quarter, (3) a monthly Shipping Bill tracking register is maintained — listing each SB, the declared RoDTEP, the expected scroll value, and the actual scroll generated, (4) ICEGATE is monitored daily or weekly for scroll generation, and scrips are converted to e-scrips within days of scroll generation, (5) quarterly reconciliation confirms that declared vs generated amounts match within acceptable tolerance, and (6) an annual entitlement report is prepared for tax and audit purposes.

Practitioner noteHigh-volume exporters face process risk at scale — a single rate error repeated across 500 Shipping Bills can create a very large exposure. We have found errors in existing client processes during onboarding where a wrong HS code had been used for 18 months across all shipments of a product — requiring a complete retrospective assessment. Systematic setup from the start is far less expensive than remediation.
What is the role of PNPC's CAs specifically in RoDTEP — what does the CA do that the CHA or an export consultant cannot?

A Customs House Agent (CHA) is responsible for the customs port filing — the Shipping Bill, Bill of Entry, and related customs documentation. The CHA can include the RoDTEP declaration in the Shipping Bill if instructed — but is not equipped to: verify the correct ITC-HS classification and Rate Schedule applicability (a classification issue), determine the AA/Drawback/RoDTEP overlap (a statutory compliance analysis), account for RoDTEP income in the financial statements (an accounting and tax matter), advise on FEMA implications of unrealised export proceeds against which RoDTEP was claimed (a foreign exchange law matter), or represent the exporter in a CBIC audit query on RoDTEP claims (a legal compliance matter). PNPC as a practising CA firm provides all of these advisory and compliance functions as an integrated service, coordinating with the CHA for the port filing layer while handling everything else.

Practitioner noteMany exporters treat RoDTEP as a CHA function — because the declaration is made in the Shipping Bill which the CHA files. This conflates port filing with the broader compliance framework. The CHA is the hands on the keyboard; PNPC is the brain behind what gets typed and the oversight that catches errors.
How does PNPC handle an existing exporter who has never claimed RoDTEP — what is the onboarding process?

For an exporter who has been shipping goods since January 2021 without claiming RoDTEP, PNPC's onboarding process is: (1) historical Shipping Bill review — we access or request the Shipping Bill register for all shipments since January 2021 and identify which bills carried eligible products, (2) unclaimed entitlement quantification — we calculate the RoDTEP entitlement that should have been generated on each eligible unclaimed Shipping Bill, (3) correction window assessment — we determine whether any CBIC-notified correction window is currently available for unclaimed bills (these have been notified for limited periods), (4) ICEGATE access setup — we ensure the exporter has direct ICEGATE ledger access, (5) forward compliance setup — master rate table, CHA instruction template, monthly monitoring calendar, (6) FEMA and tax retrospective review — assess whether historical exports have BRC closures and income recognition for any scrips that may have been generated but not collected.

Practitioner noteThe onboarding process is comprehensive and typically takes 2–3 weeks for a medium-sized exporter with 2–5 years of shipping history. The historical entitlement quantification alone often demonstrates the financial case for the engagement cost many times over.
What should an exporter do if the RoDTEP scroll value in ICEGATE is lower than expected?

If the generated scroll value is lower than the expected entitlement (based on the declared FOB value and the applicable RoDTEP rate), the discrepancy may be due to: (a) only some line items in the Shipping Bill carried RoDTEP declarations — others were missed at the time of filing, (b) the system applied a different rate than the one expected — possible if the ITC-HS code was entered incorrectly in the Shipping Bill, (c) the FOB value in the Shipping Bill was lower than the commercial invoice value (possible due to exchange rate adjustment), or (d) a system processing error in ICEGATE. PNPC identifies the reason by comparing the Shipping Bill item details against the scroll and the expected computation. Where the discrepancy is due to a Shipping Bill error (wrong HS code or missing declaration), the options are limited — post-filing amendments are generally not available. Where it is a system error, an ICEGATE helpdesk query can be lodged.

Practitioner noteWe catch scroll discrepancies during our monthly ICEGATE review. The comparison of expected vs actual scroll for each Shipping Bill is a standard item in our monthly report. Early identification of a systematic error (e.g., a CHA using a wrong HS code for a product) limits the cumulative loss.
How does PNPC's RoDTEP service integrate with its broader export compliance practice?

PNPC manages the full export compliance ecosystem for exporter clients: IEC registration and annual updates, RCMC maintenance, Advance Authorisation applications and redemptions, EPCG scheme management, Duty Drawback claims, FEMA export proceeds monitoring, GST ITC refund claims on exports, customs audit support, and RoDTEP management. RoDTEP sits within this ecosystem — it is managed as one stream in a coordinated compliance process, not as an isolated transaction. The integration ensures that the interactions between schemes (AA/RoDTEP restrictions, Drawback/RoDTEP rate schedule conditions, IGST refund/Drawback election) are managed consistently and that the exporter does not make siloed decisions in one stream that create problems in another.

Practitioner noteWe have inherited export compliance situations from clients where AA, Drawback, RoDTEP, and GST refund were each managed by a different advisor — with no coordination between them. The result was systematic conflicts: Drawback claimed at rates that excluded RoDTEP; AA redemptions incomplete because the GST team had taken a different IGST position; FEMA BRC not linked to GST refund claims. Unified management under PNPC eliminates these conflicts.
What is the inter-ministerial RoDTEP Committee and what is its role?

The RoDTEP Committee is an inter-ministerial body chaired by the Cabinet Secretary and comprising representatives from the Ministry of Commerce and Industry, Ministry of Finance (Revenue), and other relevant ministries. Its role is to: (a) conduct studies of the actual embedded tax incidence across export sectors and product categories, (b) recommend RoDTEP rates for each ITC-HS code based on the incidence studies, (c) recommend inclusions, exclusions, and rate revisions in the Schedule, and (d) respond to representations from Export Promotion Councils regarding sectors that consider their current RoDTEP rate inadequate. The Committee's recommendations are notified as Ministry of Commerce Gazette notifications and become effective from the specified date. The process of rate revision is not continuous — it occurs in periodic review cycles.

Practitioner noteExport Promotion Councils actively represent their sectors to the RoDTEP Committee for rate revisions. Exporters who believe their product category's current rate is below actual embedded tax incidence can raise representations through their EPC. PNPC assists clients in preparing data for EPC representations by computing actual embedded tax costs from the client's cost records — this is the kind of analysis that supports a rate revision argument.
What are the penalties for filing a fraudulent RoDTEP claim?

A fraudulent RoDTEP claim — claiming a rate not applicable to the product, misclassifying the product to inflate the rate, claiming on excluded categories, or double-claiming with Drawback on the same tax incidence — is subject to proceedings under the FTDR Act 1992 and the Customs Act 1962. Penalties can include: recovery of the excess scrip value with interest, penalty of up to twice the excess claimed, suspension or cancellation of the exporter's IEC (disabling all future export business), and in cases of deliberate fraud, prosecution under the FTDR Act. CBIC has designated officers to audit RoDTEP claims and has the authority to call for all original documents supporting any claim for a period of years after scrip generation.

Practitioner noteFraudulent claims are distinct from errors — over-claiming due to a good-faith ITC-HS misclassification is treated differently from deliberate product misclassification to inflate the rate. However, the line between error and fraud is determined by the enforcement officer's assessment of the exporter's knowledge and intent. Systematic errors across many Shipping Bills are harder to defend as good-faith mistakes. The cleaner the documentation trail showing the rate basis, the stronger the good-faith defence if an error is subsequently identified.
What is the timeline from export shipment to RoDTEP e-scrip generation?

The typical timeline from export shipment to e-scrip generation: (1) Shipping Bill filed — at the time of export, RoDTEP declaration included; (2) Let Export Order granted by Customs — typically 0–2 days after Shipping Bill filing; (3) Export General Manifest (EGM) filed by carrier — typically 3–7 days after vessel departure (airlines file faster, typically 1–2 days); (4) Scroll generated by ICEGATE — typically within 1–7 days of EGM filing appearing in the ICEGATE system; (5) E-scrip generated by exporter — this requires manual action on ICEGATE — PNPC initiates this within days of scroll availability; (6) E-scrip credited to ICEGATE ledger — same day as generation action. Total typical timeline: 2–4 weeks from shipment date to e-scrip in ledger. Delays in EGM filing by carriers can extend this.

Practitioner noteAir freight shipments generate scrolls faster than sea freight due to quicker EGM filing by airlines. For clients who export via air and need the scrip value for near-term import duty payment, the faster cycle time is a meaningful cash flow advantage. We track EGM filing dates and alert clients when carrier delays are pushing scroll generation beyond the normal window.
Why PNPC Global

Why PNPC Global for RoDTEP management

CapabilityCHA / Freight ForwarderGeneral Export ConsultantPNPC Global — Practising CAs
ITC-HS rate schedule verificationFiles what the client instructs — no independent rate verificationMay have basic schedule knowledge, cannot provide statutory opinionPrepares client master rate table from Schedule; provides written classification opinion; updated on each revision
AA/Drawback/RoDTEP overlap analysisOutside scopePartial knowledge — may not know all restrictionsStatutory analysis per applicable notifications; cross-scheme reconciliation register maintained
ICEGATE scrip ledger managementCHA has delegate access for Shipping Bill filing only — scrip ledger is exporter's responsibilityMay assist with ICEGATE navigationDirect ICEGATE ledger monitoring; scroll-to-scrip conversion within days; monthly scrip status report
FEMA export proceeds integrationOutside scopeOutside scopeRoDTEP tracking integrated with FEMA BRC/FIRC monitoring — consistent compliance across both
Income tax treatment and accountingOutside scopeOutside scopeAnnual entitlement statement; accounting under AS-12; income recognition guidance; ITR integration
Audit defenceCan provide port documents onlyLimited — no statutory representationComplete claim file maintenance; factual and legal response to CBIC/DGFT audit within 15 days
Retrospective review of unclaimed entitlementsCannot do — no access to rate historyCan estimate — cannot provide formal computationFull historical SB review; unclaimed entitlement computation; correction window assessment
EOU/SEZ specific eligibilityNo specific expertiseGeneral knowledgeWritten eligibility opinion per current notification; updated on each CBIC circular on EOU/SEZ RoDTEP

What the PNPC package includes

  1. 01

    Initial product eligibility review — ITC-HS code mapping to current RoDTEP Schedule Appendix 4R; written rate confirmation for each export product

  2. 02

    ICEGATE account setup and scrip ledger access configuration — ensuring direct access to scroll and scrip management functions

  3. 03

    CHA pre-filing instruction template — per-product RoDTEP rate table with filing instructions for CHA; updated on each product or rate change

  4. 04

    Monthly Shipping Bill tracking and scroll monitoring — identifying generated scrolls and triggering e-scrip generation within days

  5. 05

    Drawback/RoDTEP reconciliation register — quarterly cross-check ensuring no double-claiming; available for audit at any time

  6. 06

    FEMA export proceeds integration — RoDTEP Shipping Bills linked to BRC/FIRC monitoring register; unrealised proceeds flagged before FEMA deadline

  7. 07

    Annual RoDTEP entitlement statement for tax and audit — organised by quarter, product, and Shipping Bill; accounting treatment guidance

  8. 08

    E-scrip utilisation advisory — input on use-vs-transfer decision based on client's import pipeline and secondary market pricing

  9. 09

    FTP and CBIC notification monitoring — rate schedule updates, EOU/SEZ eligibility changes, and policy developments communicated within one week of notification

  10. 10

    Historical Shipping Bill review on onboarding — unclaimed entitlement quantification and correction window assessment for existing exporters

  11. 11

    CBIC audit support — complete claim file maintenance and factual response preparation on receipt of any audit or show-cause notice

  12. 12

    Integration with broader export compliance practice — AA, EPCG, Drawback, IEC, RCMC, GST refund, FEMA — unified management eliminating inter-scheme conflicts

Speak with a PNPC Chartered Accountant who manages export incentive compliance as a core practice — not as a side service. We will review your current Shipping Bills, identify whether your RoDTEP declarations are correctly filed, quantify any unclaimed entitlement, and put in place a systematic compliance process that captures every rupee the scheme authorises on every shipment going forward.

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