Paragraph 4 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
This article is on the Handbook only: paragraph 4.36 of the Handbook of Procedures, 2023 has no paragraph of its own in the Foreign Trade Policy, 2023. It lets several Advance Authorisations be clubbed so that imports and exports made under them are matched together for redemption or regularisation. The paragraph has fifteen sub-paragraphs with time tests, a single value-addition calculation after clubbing, and a list of cases in which clubbing is not allowed.
The procedure is taken from Chapter 4 of the Handbook of Procedures, 2023 as published on the DGFT website (file of July 2026), consulted on 2 October 2026. This article is based on the chapter-wise text of the Foreign Trade Policy, 2023 published on the DGFT website, as consulted on 2 October 2026; the copy carries no "updated up to" date. Later Public Notices should be checked. A holder with a pile of old authorisations that cannot be discharged one by one can discuss the route in a legal consultation.
Clubbing is only for redemption or regularisation and no further import or export is allowed (paragraph 4.36(iii)). The request goes in ANF 4C to the Regional Authority that issued the authorisations (4.36(ii)). The authorisations must have been issued within 24 months of the earliest; imports within 30 months and exports within 48 months of that earliest date are counted (4.36(vi)). After clubbing the authorisations are one authorisation for all purposes (4.36(xii)). Clubbing is barred where fraud is noticed or where a discharge certificate, redemption letter or adjudication order exists (4.36(xiv)).
The sub-paragraphs
| Sub-paragraph | Rule |
|---|---|
| (i) | No clubbing of authorisations issued on or before 31st March, 2009. |
| (ii) | The request is made in ANF 4C to the Regional Authority that issued the authorisations. ANF 4C is named only. |
| (iii) | Clubbing is available only for redemption or regularisation; no further import or export is allowed. |
| (iv) | It is also available for Advance Authorisations for Annual Requirement issued during the Policy periods 2009-14, 2015-20 and 2023, wherever exports and imports have taken place as per the notified SION. |
| (v) | Only authorisations under which similar duty exemption has been availed may be clubbed. They may pertain to different financial years. |
| (vi) | Only authorisations issued within 24 months of the date of issue of the earliest one are clubbed, whether valid or not. On clubbing, only imports made within 30 months from the date of issue of the earliest authorisation are considered; imports beyond 30 months are regularised under paragraph 4.49 of the Handbook. Only exports within 48 months are considered; exports beyond 48 months of the earliest are not acceptable for clubbing. |
| (vii) | Exports made during the initial or extended export obligation period of individual authorisations (after payment of the composition fee under paragraph 4.40) are clubbed. |
| (viii) | If a shortfall in value or quantity is noticed on clubbing, it is regularised under paragraph 4.49. |
| (ix) | Authorisations with different export obligation periods may be clubbed. |
| (x) | Inputs common to all authorisations are clubbed and accounted for as per SION or ad hoc norms fixed by the Norms Committee. All inputs covered need not be the same. |
| (xi) | Minimum value addition prescribed in the Policy and Procedures for the export product must be maintained on clubbing. |
| (xii) | After clubbing, the authorisations are deemed to be one authorisation for all purposes. Value addition is calculated on total CIF and total FOB arrived at after clubbing. |
| (xiii) | All cases clubbed under earlier provisions are not reopened. |
| (xiv) | No clubbing where misrepresentation or fraud has come to the notice of the Regional Authority; and none where a discharge certificate or redemption letter has been issued, or adjudication orders passed by the Regional Authority or Customs authority. |
| (xv) | Additional provisions for authorisations covered under Appendix 30A (issued under the 2009-14 Policy) or Appendix 4J (issued under the 2015-20 and 2023 Policies), and authorisations with an export obligation period of less than 18 months: see below. |
Appendices 30A and 4J are named only.
Reading the time tests in (vi)
The three periods run from one date, the issue of the earliest authorisation proposed to be clubbed.
- 24 months limits which authorisations can be put together. Authorisations issued more than 24 months after the earliest are out, whether or not they are still valid.
- 30 months limits imports. Imports beyond that date are not counted as clubbed imports but are regularised under paragraph 4.49, with whatever payment that paragraph asks for; see our article on paragraphs 4.49 and 4.50 of the Handbook.
- 48 months limits exports. Exports beyond that date are not acceptable.
Paragraph 4.36(vii) adds that exports during an extended period count if the composition fee under paragraph 4.40 has been paid; see our article on paragraph 4.22 of the Policy and paragraphs 4.40 and 4.41 of the Handbook.
Authorisations under Appendix 4J or with a shorter period: (xv)
For authorisations covered under Appendix 30A or Appendix 4J, and authorisations issued with an export obligation period of less than 18 months:
- (a) the export obligation period of the clubbed authorisations is reckoned from the date of the earliest import in any of the authorisations proposed to be clubbed; and
- (b) clubbing is allowed provided all exports are completed within the initial or extended export obligation period reckoned from that earliest import.
Policy link: paragraph 2.03(A)(i)(f)
Paragraph 2.03(A) of the Policy lets an Advance Authorisation holder use an exemption from mandatory quality control orders on imports, on conditions. One of them, in sub-paragraph (f), says the facility of clubbing under paragraph 4.36 of the Handbook is not available for authorisations that used that exemption. See our article on paragraphs 2.03 and 2.03A of the Policy. The sub-paragraph letter is given as the Policy prints it; the numbering of 2.03A in the copy is uneven.
The Handbook is issued by the Director General under section 6 of the Foreign Trade (Development and Regulation) Act, 1992 (section 6 of the FTDR Act), supporting a Policy made under section 5 (section 5 of the FTDR Act). The Policy is not a statute: it binds through the Act and the conditions of each authorisation.
A worked example
Kapoor Textiles Private Limited, an invented manufacturer, has three Advance Authorisations, the first issued in month 0 and the others within 24 months of it. None has an EODC and no adjudication order exists. Exports and imports under each are short individually but, together, match. It applies in ANF 4C (paragraph 4.36(ii)). Imports within 30 months of the first authorisation and exports within 48 months are counted (paragraph 4.36(vi)). A late import in month 33 is regularised under paragraph 4.49. After clubbing the three are one authorisation (paragraph 4.36(xii)), and value addition is tested on the total CIF and total FOB. If one of the three already had a discharge certificate, that one could not be clubbed (paragraph 4.36(xiv)).
Need help with clubbing?
Clubbing can rescue a set of authorisations, but only if the dates fit and the exports and imports have been reconciled before the request is filed. Our team can test the 24, 30 and 48 month tests against your papers in a legal consultation.
Key takeaways
- Clubbing is for redemption or regularisation only (paragraph 4.36(iii)); no further import or export.
- Request in ANF 4C to the issuing Regional Authority (paragraph 4.36(ii)).
- 24 months for the authorisations, 30 months for imports, 48 months for exports, all from the earliest authorisation (paragraph 4.36(vi)).
- After clubbing, one authorisation; value addition on total CIF and total FOB (paragraph 4.36(xii)).
- Not allowed after fraud, an EODC or redemption letter, or an adjudication order (paragraph 4.36(xiv)), nor for authorisations that used the QCO exemption (Policy paragraph 2.03A).
Read next
- Paragraphs 4.49 and 4.50 of the Handbook of Procedures, 2023: regularisation of bona fide default
- Paragraph 4.22 of the Foreign Trade Policy, 2023: export obligation period and extension
- Paragraphs 4.27, 4.28, 4.43 and 4.46 to 4.48 of the Handbook of Procedures, 2023: monitoring and redemption of export obligation
- Advance Authorisation: export obligation, clubbing and the EODC
Disclaimer: Based on the chapter-wise text of the Foreign Trade Policy, 2023 and the Handbook of Procedures, 2023 published on the DGFT website, and on the later Notifications named in this article, as consulted on 2 October 2026. The copies carry no "updated up to" date. Notifications, Public Notices, Trade Notices, the ITC(HS) schedules, Appendices and forms change often; the current text on the DGFT website should be checked before acting. This article is general information, not legal advice; check the official text before acting.