MOOWR 2019 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.
Regulations 17 to 20 of the Manufacture and Other Operations in Warehouse (no. 2) Regulations, 2019 (the MOOWR Regulations) close the set. They set out the records a section 65 unit must keep and for how long, the monthly return, audit by the proper officer, penalty in accordance with the Act, and the Board's power to exempt a class of goods.
A licensee keeps detailed records of receipt, handling, storing and removal, a record of each operation, a record of samples drawn and copies of the documents and bonds, preserves them for at least five years from removal of goods, keeps off-site digital copies and files a monthly return within ten days after month end. The proper officer may audit a unit operating under section 65, and contraventions attract a penalty under the Act.
Position of the text: as amended up to the CBIC text updated 1 October 2019 (Notification No. 69/2019-Customs (N.T.) dated 1 October 2019); no amendment found up to 3 October 2026. Later notifications should be checked. This article describes the text as published.
The permission rules are in our article on regulations 1 to 6, and removals are covered in regulations 13 to 16. The audit power ties in with the Customs Audit Regulations, 2018; see our article on Customs Audit Regulations, 2018 for the general audit procedure. A unit that needs a records and audit-readiness review can use our compliance documentation service.
Regulation 17: maintenance of records
Regulation 17(1): what to keep. The licensee:
- (i) maintains detailed records of the receipt, handling, storing and removal of goods into or from the warehouse and produces them to the bond officer when required;
- (ii) keeps a record of each activity, operation or action taken in relation to the warehoused goods;
- (iii) keeps a record of the drawal of samples from the warehoused goods under the Act or any other law; and
- (iv) keeps copies of bills of entry, transport documents, Forms for transfer of goods from a warehouse, shipping bills or bills of export or any other documents evidencing receipt or removal, and copies of the bonds executed under section 59.
Regulation 17(2): how long. Records and accounts are kept updated and accurate, preserved for a minimum of five years from the date of removal of goods from the warehouse, and made available for inspection by the bond officer or any other officer authorised under the Act.
Regulation 17(3): off-site digital copies. The licensee also preserves updated digital copies at a place other than the warehouse, to prevent loss from natural calamities, fire, theft, skilful pilferage or computer malfunction.
Regulation 17(4): monthly return. The licensee files with the bond officer a monthly return of receipt, storage, operations and removal of goods in the warehouse within ten days after the close of the month to which it relates.
| Item | Rule |
|---|---|
| Retention | At least five years from the date of removal of goods |
| Accuracy | Kept updated and accurate |
| Digital copy | Updated copy at a place other than the warehouse |
| Return | Monthly, within ten days after month end |
| Inspection | By the bond officer or any other authorised officer |
What is different from the ordinary warehouse
The ordinary Warehouse (Custody and Handling of Goods) Regulations, 2016 add a duty to give the bond officer section 61 expiry information by the 10th of the preceding month. The MOOWR records regulation has no such sub-regulation; its sub-regulations stop at the monthly return. At the application stage, regulation 4(2) also required an undertaking to furnish accounts digitally to the bond officer on a monthly basis, in a format that may be specified. Those digital accounts and this monthly return sit together in practice, although the text of regulation 17(4) speaks only of a "return".
Regulation 18: audit
The proper officer may conduct audit of a unit operating under section 65 in accordance with the provisions of the Act and the rules made under it. The regulation says "may", and names no frequency, trigger or notice period; the manner of audit comes from the Act and the rules. The Customs Audit Regulations, 2018 deal with the audit of importers and exporters generally, and this regulation is the specific hook for a MOOWR unit.
Regulation 19: penalty
A person who contravenes any provision of the regulations, abets such contravention or fails to comply with any provision is liable to a penalty in accordance with the provisions of the Act. The regulation applies to "a person", not only to the licensee, and prints no amount.
Regulation 20: power to exempt
The Board, having regard to the nature of the goods, their manner of transport or storage, may exempt a class of goods from any of the provisions of the regulations. The power is exercised for classes of goods, not for individual units.
A worked example
Prism Electronics Pvt Ltd's MOOWR unit has its stock ledgers, sample register and copies of bills of entry, shipping bills, transfer Forms and bonds in the plant office, with an updated digital copy on a server at another location. By the tenth of each month the keeper files the monthly return for the previous month. An audit notice from the proper officer arrives; Prism produces the five-year records. A removal made four years ago is still within the retention period because it counts from the date of removal. When Prism is found to have missed a return in one month, the Act's penalty provisions apply under regulation 19.
Checklist
- Hold five years of records from the date of removal of each lot, not from the date of the entry.
- Keep an off-site, updated digital copy.
- File the return by the tenth.
- Be ready for audit by the proper officer under the Act and rules.
Need help getting ready for a MOOWR audit?
If your unit wants a mock audit of its records, samples register and monthly returns against regulation 17, our compliance documentation team can help.
Key takeaways
- Records cover receipt, handling, storing, removal, each operation, samples and supporting documents, including bonds under section 59.
- Retention is at least five years from removal of goods, with an off-site digital copy.
- The monthly return is due within ten days after month end.
- The proper officer may audit a unit operating under section 65.
- Penalty follows the Act, and the Board may exempt a class of goods.
Read next
- Regulations 13-16 of the MOOWR (No. 2) Regulations, 2019: transfer and removal of resultant goods
- Regulations 1-6 of the MOOWR (No. 2) Regulations, 2019: eligibility and permission
- Regulations 1-7 of the Customs Audit Regulations, 2018: auditee records, selection and conduct of audit
Disclaimer: Based on the customs regulations named above as published on the CBIC Tax Information Portal or in the Gazette and, for sets amended since 2023, the amending notifications (read through a TaxClue consolidated reading text; no official consolidated text exists), as consulted on 3 October 2026. Later notifications, fees and the Customs Act, 1962 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.