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.
Under the inventory-based framework in Chapter 9, the Exporter-on-Record keeps the stock, files the export and receives the export incentives. Paragraphs 9.16 and 9.17 of the Foreign Trade Policy, 2023 make it keep export stock apart and traceable, pay the Seller-on-Record on time, and share the export rebates and refunds with the seller. Paragraphs 9.03 and 9.04 of the Handbook of Procedures set the registration, the charge limit and the seller's access.
The Exporter-on-Record must identify, segregate and keep a digital repository of Export Inventory (paragraph 9.16). It pays the Seller-on-Record no later than 7 days from acceptance or deemed acceptance (paragraph 9.17(i)), and shares Export Rebates and Refunds in proportion to the FOB value of each seller's goods as declared in the Shipping Bill (paragraph 9.17(iii)). It may keep an administrative charge, which the Handbook caps at 10% of the gross amount (Handbook 9.03(vi)); the seller's balance is disbursed within 30 days of receipt (Handbook 9.03(vii)).
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 9 of the Handbook of Procedures, 2023 as published on the DGFT website (file of August 2026), consulted on 2 October 2026. Later Notifications and Public Notices should be checked before acting. The Policy rests on section 5 of the Foreign Trade (Development and Regulation) Act, 1992 (section 5 of the FTDR Act); the Handbook is issued under section 6. For the refund of tax on exports, see our GST refund on exports page; the definitions used below are explained in our article on paragraphs 9.13 to 9.15.
Paragraph 9.16: export inventory management and segregation
The Exporter-on-Record is "responsible for distinctly identifying, segregating and maintaining Export Inventory". It must also maintain a digital repository "enabling identification, tracking and traceability of all Export Inventory", including records of procurement from the Seller-on-Record, inventory status and linkage with export documentation. The manner, form and standards for identification, segregation and maintenance, and for the repository, "shall be as prescribed under the Handbook of Procedures".
Paragraph 9.03(iii) of the Handbook gives two requirements for the repository. It must be accessible to DGFT and other authorities authorised under applicable law, and remain operational regardless of the number of locations where Export Inventory is held. It must also link the procurement records, GST invoices and export documents of the Exporter-on-Record to the records of each Seller-on-Record.
Paragraph 9.17: payment and the sharing of rebates
| Sub-paragraph | What it says |
|---|---|
| (i) | Payment to the Seller-on-Record "promptly" on acceptance or deemed acceptance of the goods, and no later than 7 days from that date. Payment is not contingent on, or delayed by, receipt of payment from the buyer outside India, return of goods by that buyer or any other event outside the seller's control |
| (ii) | The Exporter-on-Record may claim Export Rebates and Refunds in accordance with the Policy and relevant notifications |
| (iii) | The Exporter-on-Record apportions and disburses the rebates among the Sellers-on-Record whose goods are part of the Export Consignment, in proportion to the FOB value attributable to each seller's goods as declared in the Shipping Bill |
| (iv) | The Exporter-on-Record may retain an administrative charge from the rebates; the balance is the Seller-attributable Export Benefits and goes to the Seller-on-Record |
| (v) | The pass-through under (iii) becomes operative for a consignment only when the Exporter-on-Record has claimed rebates and refunds for it |
The first sub-paragraph protects the seller from a buyer's non-payment or return. The seven days run from acceptance or deemed acceptance by the Exporter-on-Record, not from the shipment or from the buyer's payment. The paragraph does not define deemed acceptance. The fifth sub-paragraph links the seller's share to the Exporter-on-Record's own claim: the pass-through arises only once the claim has been made.
Paragraph 9.17(iv) does not fix the charge. Paragraph 9.03(vi) of the Handbook does: the charge "shall not exceed 10% of the gross amount of Export Rebates and Refunds". Paragraph 9.03(vii) adds that Seller-attributable Export Benefits are to be disbursed within 30 days of receipt of the rebates and refunds by the Exporter-on-Record. Under paragraph 9.13 of the Policy, refund of CGST-law taxes is an Exporter-on-Record entitlement and not part of the Seller-attributable amount.
Procedure under the Handbook
Paragraph 9.03: registration, inventory and obligations
| Sub-paragraph | Requirement |
|---|---|
| (i) | Application for registration as Exporter-on-Record in the form and manner prescribed in ANF 9A, with the documents specified there. The form is named only; its fields are not described here |
| (ii) | Any change in the particulars furnished at registration is intimated to DGFT within 30 days from the date of change, in a revised ANF 9A. DGFT may examine continued eligibility and may confirm, modify, suspend or cancel the registration, as appropriate |
| (iii) | The digital repository: accessible to DGFT and linked to seller records, as above |
| (iv) | The Exporter-on-Record ensures that goods held in Export Inventory match the descriptions, specifications and quality parameters declared by the Seller-on-Record |
| (v) | The Exporter-on-Record is solely responsible for compliance of goods held in Export Inventory, prior to export, with the laws and requirements of the destination country, including testing, inspection, certification, registration and approvals, and labelling, packaging, marking and product information |
| (vi) | Administrative charge not above 10% of the gross amount |
| (vii) | Seller-attributable benefits disbursed within 30 days of receipt |
| (viii) | The process and modalities for claiming rebates and refunds may be reviewed by DGFT during the pilot phase |
Sub-paragraph (viii) matters for planning: the Handbook itself calls this a pilot phase, and DGFT may revise the claim process.
Paragraph 9.04: rights and visibility of the Seller-on-Record
The Exporter-on-Record gives each seller access to consolidated digital records of Export Inventory management and segregation for goods that seller supplied. The records include, as a minimum, the final sale price to the buyer outside India, order status, and shipment tracking details with destination country. The Exporter-on-Record must also ensure that the identity of the manufacturer or brand owner, and where the seller is different, the identity of the Seller-on-Record, is disclosed to the buyer through the product listing or other applicable means.
An example
Kesar Gifts Private Limited, an invented Exporter-on-Record, ships one consignment made up of goods from two sellers, Anant Brassware and Meera Textiles. The Shipping Bill declares the FOB value of each seller's goods. Kesar pays each seller within 7 days of accepting the goods, whether or not the buyer abroad has paid. Kesar then claims the rebates and refunds for the consignment. It shares them between the two sellers in proportion to the FOB value of each one's goods, after keeping an administrative charge not above 10% of the gross amount, and disburses each seller's share within 30 days of receiving the money. The seller whose goods carry the higher FOB value receives the larger share. Each seller can see its final sale price, order status and tracking through the records Kesar must make available.
Points to watch
- The 7-day payment clock and the 30-day disbursal clock are separate. The first runs from acceptance; the second from receipt of the rebates.
- The 10% ceiling is in the Handbook, not in the Policy paragraph.
- Compliance with destination-country requirements rests on the Exporter-on-Record under Handbook 9.03(v).
- The pilot-phase wording in Handbook 9.03(viii) means the modalities can change; check DGFT's current notices.
Need help with export refunds and the tax side?
Rebates and tax refunds follow different rules and different recipients under this Framework. We can help you with a GST refund on exports and with reading how the Exporter-on-Record and Seller-on-Record each fit.
Key takeaways
- Paragraph 9.16: identify, segregate and keep a digital repository of Export Inventory; manner and standards in the Handbook.
- Paragraph 9.17(i): pay the seller no later than 7 days from acceptance or deemed acceptance, regardless of the buyer's payment or return.
- Paragraph 9.17(iii): share rebates in proportion to FOB value declared in the Shipping Bill.
- Handbook 9.03: ANF 9A registration, change intimation within 30 days, charge not above 10% of gross, disbursal within 30 days.
- Handbook 9.04: seller access to records and disclosure of manufacturer or brand owner.
Read next
- Paragraphs 9.18 and 9.19 of the Foreign Trade Policy, 2023: returned consignments, compliance certificate and disputes
- Paragraphs 9.13 to 9.15 of the Foreign Trade Policy, 2023: the inventory-based cross-border e-commerce framework
- Rule 96 under GST: the shipping bill as a refund application
- 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.