Deferred duty payment for manufacturers: EMI Scheme application cut from ten documents to three, enrolment opens 15 September 2026 — CBIC Circular 39/2026-Customs

The scheme and the change

Circular No. 08/2026-Customs dated 28 February 2026 was issued in pursuance of Notification No. 12/2026-Customs (N.T.) dated 1 February 2026, which extended the facility of deferred payment of customs import duty — under the proviso to section 47(1) of the Customs Act, 1962 — to “Eligible Manufacturer Importers” (EMI).

The trade represented that the data and documents asked for in the application were too many. By Circular No. 39/2026-Customs dated 3 September 2026, CBIC has revised the three appendices to the earlier circular. The verification of the relevant particulars is to be done through backend IT systems.

Appendix-I: fewer data fields

The applicant no longer has to give details of:

• EXIM documents filed during the previous financial year;
• GSTIN status, the declaration of manufacturing activity in FORM GST REG-01, GSTR-3B filing status, aggregate turnover and GST payment;
• date of commencement of business / GST registration, and ITC-04 filing particulars;
• factory or manufacturing premises, property holding rights, and book value of plant and machinery;
• major raw materials and finished goods with HSN details, and particulars of job workers.

Appendix-II: what to upload now

Appendix-III: the CA certificate

The certificate, on the letterhead of the Chartered Accountant or CA firm, gives a financial summary for the last two financial years — total assets, fixed assets (land and building, plant and machinery, others), total and contingent liabilities, net worth, current assets and liabilities, turnover, current ratio and debt-equity ratio — and an opinion on solvency. The revised format requires the CA to furnish reasons where the applicant has negative net worth or negative net current assets. The application form has matching fields (reasons in 100 words).

What the revised form still asks

• IEC, PAN, MSME and AEO status.
• GSTIN-wise, whether there is any liability on account of GST collected from customers but not deposited.
• Whether the applicant is a manufacturer under section 2(72) of the CGST Act, 2017, with the GSTINs involved in manufacturing; or, if not, the GSTINs from which inputs or capital goods are sent to a job worker under section 143. At least one active GSTIN must have declared the nature of activity as factory / manufacture in REG-01.
• Solvency for the two preceding financial years, insolvency or liquidation status, arrests, convictions and pending prosecutions under the Customs, Central Excise, service tax and GST laws.
• Earlier EMI applications and their status; contact details of the authorised person.

What manufacturers should do

Enrolment under the scheme with the reduced requirements is open from 15 September 2026. Get the Chartered Accountant’s certificate in the revised Appendix-III format with UDIN, and the authorisation letter, before applying. After approval, any change in the particulars relating to eligibility has to be notified to the Directorate of International Customs, CBIC, as undertaken in the application.