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 2.56 of the Policy recognises Export Promotion Councils as Registering Authorities that issue a Registration-cum-Membership Certificate (RCMC). Paragraph 2.57 says who must hold one and who need not. Notification 36/2026-27 dated 15 September 2026 inserts a sub-paragraph (c) on low-value consignments, and the chapter file already prints a sub-paragraph (c) with a different amount.
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. It also takes in Notification No. 36/2026-27 dated 15 September 2026. 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 and Public Notices should be checked.
A person applying for an authorisation (other than for items listed as restricted in ITC(HS)), or for any other benefit or concession under the Policy, must provide an RCMC unless specifically exempted (paragraph 2.57(a)). Two certificates of commodity boards are treated as RCMC (paragraph 2.57(b)). A later sub-paragraph (c) exempts low-value consignments: Notification 36/2026-27 says Rs. 3,00,000 FOB value, while the chapter file prints Rs.10,000.
Paragraph 2.56: Export Promotion Councils as Registering Authorities
Under paragraph 2.56(a), Export Promotion Councils (EPCs) are organisations of exporters set up to promote and develop Indian exports. Each Council is responsible for a particular group of products, projects or services as given in Appendix 2T, which is named only here. Paragraph 2.56(b) says EPCs are also eligible to function as Registering Authorities to issue the RCMC to their members, and that the criteria for recognition are in paragraph 2.78 of the Handbook. For a list of councils, see our article on the list of export promotion councils in India.
Paragraph 2.57: the RCMC requirement
Paragraph 2.57(a): when an RCMC is needed
Any person applying for an authorisation to import or export under the Policy, except for items listed as restricted in ITC(HS), or applying for any other benefit or concession under the Policy, is required to provide the RCMC granted by the competent authority in accordance with the procedure in the Handbook, unless specifically exempted under the Policy. A firm that sells nothing abroad and needs no benefit has no RCMC duty under this paragraph; the duty arises when it applies for an authorisation or a benefit. The first step for most firms is an RCMC registration.
Paragraph 2.57(b): Spices Board and Coir Board
The Certificate of Registration as Exporter of Spices (CRES) issued by the Spices Board, and the Certificate of Registration as Exporter of Coir and Coir products issued by the Coir Board, are treated as an RCMC for the purposes of the Policy.
Paragraph 2.57(c): low-value consignments, two texts
As notified on 15 September 2026 (Notification No. 36/2026-27). The Notification, issued under section 5 of the Foreign Trade (Development and Regulation) Act, 1992 read with paragraph 1.02 of the Policy, says that in paragraph 2.57, after sub-paragraph (b), a sub-paragraph (c) is inserted. As notified, sub-paragraph (c) reads in substance: notwithstanding sub-paragraphs (a) and (b), the requirement of an RCMC or a Certificate of Registration does not apply to an export consignment where the FOB value of the consignment does not exceed Rs. 3,00,000. The Notification's note on effect says the aim is to promote small value exports, especially exports through postal, courier and other emerging channels, and that consignments with an FOB value above Rs. 3,00,000 continue to need a valid RCMC or Certificate of Registration wherever the requirement otherwise applies.
What the chapter file still prints. The chapter text on the DGFT website consulted on 2 October 2026 already printed a sub-paragraph (c) in paragraph 2.57. It says that, notwithstanding sub-paragraphs (a) and (b), an RCMC or Certificate of Registration is not required for applying for an authorisation to import or export under the Policy (except items listed as restricted in ITC(HS)) or for any other benefit or concession, for export consignments where the FOB value is less than or equal to Rs.10,000.
| Source | Amount | Wording in brief |
|---|---|---|
| Notification 36/2026-27, 15 September 2026 | Rs. 3,00,000 FOB value, "does not exceed" | The RCMC or Certificate of Registration requirement does not apply to the consignment |
| Chapter file, consulted 2 October 2026 | Rs.10,000 FOB value, "less than or equal to" | No RCMC or Certificate of Registration for applying for an authorisation (not restricted items) or any other benefit or concession |
The two texts print different amounts and different words, and this article does not say how they fit together or which is numbered where. It also does not guess whether the Notification replaces the earlier sub-paragraph or sits beside it. Anyone who relies on a low-value exemption should read the current paragraph 2.57 on the DGFT website and the Notification together before shipping.
The exemption is for a consignment, not for the exporter, and it is measured by the FOB value of that consignment as printed. Our article on GST refund on courier and postal exports covers the GST side of small exports; it takes no figure from this Policy paragraph.
What the Handbook requires
Paragraph 2.77: Registering Authorities
A Registering Authority is a body notified by DGFT to register importers and exporters as its members by issuing the RCMC. The list of notified Registering Authorities is in Appendix 2T.
Paragraph 2.78: criteria for EPCs
For EPCs to function as Registering Authorities, the Handbook lays down three criteria.
- (a) e-Voting. Electronic voting is mandatory for election to the posts of Vice Chairman or Vice President and Executive Committee members.
- (b) Tenure of elected heads. The tenure of an elected head is not for more than two years. The election of Chairman or President is via the Vice Chairman or Vice President route. A member who has held the post of Chairman or President, or Vice Chairman or Vice President, may come back as Vice Chairman or Vice President in the same council after a gap of not less than 4 years.
- (c) Directions of the Central Government. EPCs acting as Registering Authorities must abide by all directions of the Central Government in respect of promotion and development of international trade.
These criteria bind the council, not the exporter. The exporter's own application steps are in paragraphs 2.79 to 2.85 of the Handbook, covered in our article on RCMC application, validity and de-registration.
The Act behind the paragraphs
The Policy is made under section 5 of the Act; see our article on section 5 of the FTDR Act. The Handbook is issued under the Director General's power in section 6 of the FTDR Act. These paragraphs name no other section.
A worked example
Kiran Handlooms, an invented seller of handloom products, wants an authorisation for an import. Under paragraph 2.57(a) it must provide an RCMC. A sister firm sends a courier consignment whose FOB value is Rs. 2,00,000. Under the Notification of 15 September 2026 that is within the ceiling of Rs. 3,00,000, but under the chapter file's sub-paragraph (c) it is above Rs.10,000. The two texts give different answers, so the firm should confirm the current paragraph 2.57 on the DGFT website before relying on either.
Need help with an RCMC?
Choosing the right council, filling the application and keeping the certificate current are routine but easy to get wrong. Our team can handle them through our RCMC registration service.
Key takeaways
- An RCMC is needed for an authorisation (other than restricted items) or any other benefit or concession, unless exempted (paragraph 2.57(a)).
- CRES of the Spices Board and the Coir Board certificate are treated as RCMC (paragraph 2.57(b)).
- Notification 36/2026-27 sets Rs. 3,00,000 FOB; the chapter file prints Rs.10,000. Both are given; neither is reconciled.
- EPCs as Registering Authorities must follow e-voting, two-year tenure and a gap of 4 years (Handbook paragraph 2.78).
Read next
- Handbook of Procedures, 2023, paragraphs 2.79 to 2.85: RCMC application, validity and de-registration
- Paragraphs 2.54 and 2.55 of the Foreign Trade Policy, 2023: non-realisation of export proceeds and export credit agencies
- RCMC: what it is and how to get it
- FIEO registration for exporters
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.