Paragraphs 2 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.
Paragraph 2.20A prohibits direct or indirect import or transit of all goods originating in or exported from Pakistan, until further orders. Paragraph 2.20B prohibits import of goods produced or manufactured, wholly or in part, through the use of forced labour, once the Central Government specifies the goods by notification after an enquiry. Paragraph 2.50A of the Handbook sets out the five steps of the DGFT's enquiry.
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. The procedure is taken from Chapter 2 of the Handbook of Procedures, 2023 as published on the DGFT website (file of July 2026), consulted on 2 October 2026. Later Notifications, Public Notices and Trade Notices should be checked before you act. No goods are named as notified under paragraph 2.20B in this article. If your supply chain may be affected, a legal consultation can help you assess it.
Paragraph 2.20A prohibits direct or indirect import or transit of all goods originating in or exported from Pakistan, whether or not the goods are otherwise importable without an authorisation, until further orders, with any exception needing prior approval of the Government of India. Paragraph 2.20B prohibits import of goods made wholly or in part with forced labour, but only for the goods the Central Government specifies by notification after an enquiry. The Handbook gives the DGFT a five-step enquiry (paragraph 2.50A).
What the Policy says
Paragraph 2.20A: imports from Pakistan
Direct or indirect import or transit of all goods originating in or exported from Pakistan, whether or not they are importable without an authorisation or otherwise permitted, is prohibited with immediate effect, until further orders. The paragraph says the restriction is imposed in the interest of national security and public policy. Any exception to the prohibition requires the prior approval of the Government of India.
Three points are worth noting from the words:
- It covers goods "originating in or exported from" Pakistan, so goods of third-country origin shipped from Pakistan are covered as well as goods made there.
- It covers "direct or indirect" import and also "transit".
- It has no end date: "until further orders".
The paragraph names no section of the Act. For the Act's power to prohibit imports, see our article on sections 3 and 4 of the Foreign Trade (Development and Regulation) Act, 1992; the Policy is made under section 5 of the Act. Customs has its own power over prohibited goods in section 11 of the Customs Act, 1962.
Paragraph 2.20B: goods produced with forced labour
The import of goods produced or manufactured, wholly or in part, through the use of forced labour is prohibited. The Central Government may from time to time specify, by notification, the goods whose import is prohibited under the paragraph, having regard to the findings of an enquiry or other material it considers appropriate. The procedure for conducting the enquiry by the Director General of Foreign Trade into the use of forced labour in the production of such goods is as prescribed in the Handbook of Procedures, 2023.
Two features matter. First, the prohibition operates on goods that are specified by notification. The paragraph prints none, and none is stated here; check the current notifications. Second, "forced labour" is defined in paragraph 11.64 of the Policy as all work or service exacted from any person under the menace of any penalty and for which the person has not offered himself voluntarily, as defined under the ILO Forced Labour Convention, 1930 (Convention 29). That definition is explained in a separate article on the Policy's definitions.
What the Handbook requires
Paragraph 2.50A, headed "Procedure for determination of use of forced labour in the production of imported goods", gives five steps:
| Step | What the DGFT may do |
|---|---|
| 1 | Undertake an enquiry, on its own motion or on receipt of information or a complaint supported by credible material, to ascertain whether goods imported into India have been produced, wholly or in part, using forced labour |
| 2 | Seek information, documents or clarifications from the importers, exporters, manufacturers or any other person or authority considered necessary |
| 3 | Consult the relevant Ministries, Departments or agencies, or other stakeholders, as necessary |
| 4 | Obtain information or technical inputs from any domestic or international organisation, governmental authority or expert body, wherever considered necessary |
| 5 | On completion, prepare a report with its findings on the use of forced labour in the production of the goods, and make appropriate recommendations to the Central Government, including for prohibition of import of the goods |
Step 5 says that recommendation for prohibition may be made under the Foreign Trade (Development and Regulation) Act, 1992 and the Policy. The Handbook paragraph prints no time limits, no form of complaint and no right of hearing for an importer; the DGFT "may" seek information from importers, exporters and manufacturers. The Handbook itself is notified under section 6 of the Act. For compliance practice in the supply chain, see our guide on child and forced labour compliance for exporters.
A practical example
Granite Bay Apparel, an invented importer, buys fabric from a trader abroad. The trader's goods were shipped from Pakistan after being sourced elsewhere. Under paragraph 2.20A, goods "exported from" Pakistan are within the prohibition even if they did not originate there, and the prohibition covers indirect import and transit, so the importer cannot route around it, and any exception needs prior approval of the Government of India. On a separate shipment, a complaint supported by credible material says an overseas supplier uses forced labour. The DGFT may open an enquiry under paragraph 2.50A, ask Granite Bay and the supplier for documents, and recommend to the Central Government that import of the goods be prohibited. The prohibition under paragraph 2.20B would then apply once the goods are specified by notification.
Need help with an import-prohibition question?
Whether a shipment falls under a prohibition depends on its route, its origin and the current notifications. Our team can help you assess a supply chain through a legal consultation.
Key takeaways
- Direct or indirect import or transit of goods originating in or exported from Pakistan is prohibited until further orders, and exceptions need prior approval of the Government of India (paragraph 2.20A).
- Goods made wholly or in part with forced labour are prohibited, in the case of goods the Central Government specifies by notification (paragraph 2.20B).
- The DGFT may open an enquiry on its own motion or on a credible complaint (Handbook paragraph 2.50A).
- The enquiry ends with a report and recommendations to the Central Government.
- Check the current notifications; none is named here.
Read next
- Paragraphs 2.16 to 2.20: United Nations linked prohibitions
- Paragraphs 2.21 to 2.24: State Trading Enterprises and trade with specific countries
- Child and forced labour compliance for exporters
- Section 11 of the Customs Act, 1962: power to prohibit import or export of goods
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.
