Paragraphs 9 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.
Part D of Chapter 9 of the Foreign Trade Policy, 2023 sets up an "Inventory-based Cross-border E-Commerce Facilitation Framework". Paragraphs 9.13 to 9.15 define the key terms, state the objective and set the first conditions: who may hold inventory for export, what goods are eligible and when title to goods may pass.
An Exporter-on-Record holds a valid IEC and GSTIN, is registered with DGFT, and sells goods procured from one or more Sellers-on-Record to buyers outside India (paragraph 9.13). An e-commerce entity other than a marketplace e-commerce entity may undertake export-only inventory operations through an Exporter-on-Record (paragraph 9.15(i)). Only goods of Indian origin qualify, and title passes to the Exporter-on-Record only against a confirmed export order from a buyer outside India; speculative transfer or inventory build-up is not permitted (paragraph 9.15(iv)).
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. This Part was brought in by Notification 27/2026-27 of 5 August 2026, and the text of paragraphs 9.13 to 9.15 below is the text of the chapter file. Later Notifications and Public Notices should be checked before acting. The Policy is made under section 5 of the Foreign Trade (Development and Regulation) Act, 1992; see our article on section 5 of the FTDR Act. Whether an exporter or a seller joins the framework, tax registration comes first; see our GST registration for exporters page.
Paragraph 9.13: five definitions
Paragraph 9.13 gives the meanings "for the purposes of" the Framework "unless the context otherwise requires".
| Term | Operative words |
|---|---|
| Exporter-on-Record (EOR) | An entity holding a valid IEC and GSTIN, registered with DGFT under the Framework, exporting and selling goods procured from one or more Sellers-on-Record to buyers located outside India |
| Seller-on-Record (SOR) | An entity registered in India under the applicable Goods and Services Tax law, supplying goods produced in India to the Exporter-on-Record against the Exporter-on-Record's confirmed export orders, for the purpose of export to buyers located outside India |
| Export Inventory | Goods procured by the Exporter-on-Record from a Seller-on-Record against a confirmed export order and held exclusively for export, which are designated, recorded and traceable in the Exporter-on-Record's records as export-designated stock |
| Domestic Inventory | Goods held by the Seller-on-Record for supply in the Domestic Tariff Area (DTA) |
| Export Rebates and Refunds (ERR) | Cash or cash-equivalent export incentives, rebates, refunds or remissions received by the Exporter-on-Record upon export of goods, including Duty Drawback, RoDTEP, RoSCTL or any other notified scheme involving direct monetary or transferable financial benefit |
Four details need care.
The e-commerce entity limb. Under the first definition, where an e-commerce entity proposes to undertake export operations under a paragraph of the Consolidated FDI Policy "as amended vide Press Note No. 3 (2026 Series) dated 23.07.2026", the operations "shall be carried out through a separate legal entity incorporated for this purpose". At registration or amendment, that entity discloses its shareholding pattern and the nature of its ownership or control relationship with the e-commerce entity. The Press Note is named here as printed; its content is not in the Policy text and is not explained in this article.
The ERR exclusions. The fifth definition says ERR "shall not include" non-transferrable duty remission instruments such as Advance Authorisation or EPCG Authorisation. It also says that refund of taxes to the Exporter-on-Record under the Central Goods and Services Tax Act is an Exporter-on-Record entitlement and is "not part of Seller-attributable Export Rebates and Refunds". The split matters later, when paragraph 9.17 shares the rebates with the sellers. No rate of any scheme is stated here.
Two kinds of stock. Export Inventory belongs to the Exporter-on-Record and is held "exclusively for export". Domestic Inventory belongs to the Seller-on-Record and is for supply in the DTA. The same product can be in either category, depending on whose hands it is in and why it is held.
The Seller-on-Record must supply goods "produced in India". This is also the origin condition that paragraph 9.15(ii) repeats.
Paragraph 9.14: objective
The Framework aims to enable e-commerce exports through an inventory model "under which the Exporter-on-Record holds inventory for export, undertakes export-related processes, exports goods, and assists and enables Sellers-on-Record to access global markets".
Paragraph 9.15: eligibility and conditions for holding export inventory
| Sub-paragraph | Condition |
|---|---|
| (i) | An e-commerce entity, other than a marketplace e-commerce entity as defined under the Consolidated FDI Policy, may undertake export-only inventory operations through an Exporter-on-Record registered under the Framework. The Exporter-on-Record may hold inventory of goods exclusively for export through e-commerce and undertake all export-related activities, subject to the Framework and the Consolidated FDI Policy as in force from time to time |
| (ii) | Only goods of Indian origin are eligible. The Seller-on-Record is responsible for ensuring and declaring the correct origin in accordance with applicable laws and the relevant origin criteria |
| (iii) | A list of ineligible goods may be notified by DGFT from time to time |
| (iv) | Title passes from the Seller-on-Record to the Exporter-on-Record only against a confirmed export order received by the Exporter-on-Record from a buyer located outside India. Speculative transfer of title or inventory build-up without a confirmed export order is not permitted |
Three consequences follow from the text. First, the model is closed at both ends: the buyer's order comes first, and the goods follow. An Exporter-on-Record cannot stock goods in advance in the hope of orders. Second, the origin burden is on the seller, who must "ensure and declare" the correct origin; the Exporter-on-Record is not named as the declarant. Third, the list in sub-paragraph (iii) is not in the chapter file, so a seller must check DGFT's notifications for any list.
Our article on paragraphs 9.16 and 9.17 explains how Export Inventory is segregated and how the rebates are shared. The Framework has no Handbook counterpart for paragraphs 9.13 to 9.15; the Handbook paragraphs for Part D begin at paragraph 9.03.
An example
Lotus Export Platforms Private Limited, an invented company with an IEC and GSTIN, registers with DGFT as an Exporter-on-Record. A buyer abroad confirms an order for printed tablecloths. Trishul Weaves, a GST-registered manufacturer in India, supplies the tablecloths against that order. Title passes to Lotus only after the order is confirmed, as paragraph 9.15(iv) requires. Trishul declares that the goods are of Indian origin under paragraph 9.15(ii). If Lotus had instead bought a large lot from Trishul with no order in hand, that would be the speculative inventory build-up that paragraph 9.15(iv) says is not permitted.
Need help with registering as a seller or an exporter?
Both the Exporter-on-Record and the Seller-on-Record depend on correct tax registration. We can help with your GST registration for exporters and advise on how your sales model sits with the Framework.
Key takeaways
- Paragraph 9.13: five definitions, including Exporter-on-Record (valid IEC and GSTIN, registered with DGFT) and Seller-on-Record (GST-registered supplier of Indian-made goods).
- A separate legal entity is needed where an e-commerce entity operates under the FDI paragraph the definition names.
- Paragraph 9.15(i): an e-commerce entity other than a marketplace e-commerce entity may do export-only inventory operations through an Exporter-on-Record.
- Paragraph 9.15(ii) and (iv): goods of Indian origin only; title passes only against a confirmed export order.
Read next
- Paragraphs 9.16 and 9.17 of the Foreign Trade Policy, 2023: export inventory and payment to the Seller-on-Record
- Paragraphs 9.18 and 9.19 of the Foreign Trade Policy, 2023: returned consignments, compliance certificate and disputes
- Paragraphs 9.07 to 9.12 of the Foreign Trade Policy, 2023: e-commerce export hubs and Dak Niryat Kendras
- GST refund on courier and postal exports
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.