ITC(HS)

Restricted import authorisation in India: ITC(HS) status and the ANF-2M application

Reading the ITC(HS) Schedule 1 policy column, what still blocks a Free line, and filing ANF-2M for a restricted import authorisation. Fees, 18-month validity, and the revalidation window.

By Aaryan Kakani · · 12 min read

Is your import Free, Restricted, Prohibited or STE-canalised?

The Foreign Trade Policy starts from permission, not prohibition. Under FTP Para 2.01(a) , imports into India are Free unless they are specifically regulated as Prohibited, Restricted, or canalised through a State Trading Enterprise in the ITC(HS) classification. Everything else in this guide follows from working out which of those four buckets your 8-digit line sits in.

Where a line is Restricted, FTP Para 2.08 allows import only against an Authorisation or Permission, or in accordance with a procedure notified for that purpose. That is what ANF-2M exists to obtain.

Policy statusWhat it meansRoute to import
FreeNot regulated in the ITC(HS). The default under FTP 2.01(a)No authorisation, but standards and entry-point conditions can still bite (section 3)
RestrictedImport permitted only against an Authorisation or Permission (FTP 2.08)ANF-2M to DGFT Headquarters, decided by the EXIM Facilitation Committee
ProhibitedNo import route at all. For example beef in any form and beef-containing productsNone. Do not plan a shipment against a Prohibited line
STE-canalisedImport routed exclusively through a designated State Trading EnterpriseBuy through the STE, or seek DGFT authorisation for a non-STE entity under FTP 2.21

Four FTP paragraphs that decide whether a deal is viable

  • FTP 2.09. Actual User condition. Where an import requires an authorisation, only the Actual User may import, and the authorisation is non-transferable . A pure trading model (import on an authorisation, resell to whoever wants it) does not survive this paragraph.
  • FTP 2.13. No right to an authorisation. There is no entitlement. DGFT or the Regional Authority may refuse. Treat the authorisation as a contingency in your commercial contract, not an assumption.
  • FTP 2.21. The STE door. The list of State Trading Enterprises sits in Appendix-2J, and DGFT may authorise an entity other than the notified STE to import. That authorisation is the only lawful way around canalisation.
  • FTP 2.06(b). Mandatory documents. Whatever the policy status, every import needs a bill of lading, air waybill, lorry receipt, railway receipt or postal receipt (CN-22 or CN-23), a commercial invoice cum packing list, and a bill of entry.

How do you check the ITC(HS) policy status of a product?

The lookup is free and needs no login. It is a two-tool process, and most people stop after the first tool, which is where the mistakes start.

The ITC(HS) determination route

  1. 1 Find the code on the ITC(HS) tool Open dgft.gov.in/CP/?opt=itchs . Search by code (6 to 8 characters) or by description (the description field accepts a maximum of 10 characters, so use the shortest distinctive keyword). Drill from the chapter and heading down to the specific 8-digit line.
  2. 2 Run the Schedule 1 import policy lookup Take the 8-digit code to dgft.gov.in/CP/?opt=itchs-import-export and read Schedule 1 (Import Policy). This is the screen that carries the actual policy status.
  3. 3 Read four things, not one The policy column, the policy condition text against that line, the General Notes to Schedule 1, and Appendices 1 to 5. A line can read Free in the policy column and still carry a condition that makes it unusable for your shipment.
  4. 4 Record the evidence Save the code, the policy status, the condition text and the date you checked. The ITC(HS) is amended by notification, so a determination is only good as of the date it was made.

There is a practical validation trick worth knowing. The DGFT portal validates classification on its own restricted-import forms. When you attempt a bulk upload of item lines and the portal returns an error along the lines of with ITC(HS) Code as <code> is not valid , that is the system telling you the code is not a Restricted line. Which is a useful negative confirmation of a Free determination you reached by reading.

What can still block an import that the ITC(HS) calls Free?

FTP Para 2.01(b) , read with 2.02 and 2.03(a) , is the paragraph that catches importers who stopped at the policy column. A "Free" line is still subject to standards, registration orders and entry-point conditions imposed by other laws.

OverlayWhat it does to a Free lineWhere it sits
Mandatory BIS standardsGoods must conform to the notified Indian Standard; newly notified standards apply automatically from their implementation dateAppendix-III of ITC(HS) Schedule 1
CRO 2012 (electronics and IT goods)Registration under the Electronics and IT Goods (Requirement for Compulsory Registration) Order 2012 is a precondition to clearanceCRO 2012, referenced in the General Notes
NDPS ActNarcotic drugs and psychotropic substances controls override a Free tariff lineNarcotic Drugs and Psychotropic Substances Act
Montreal ProtocolOzone-depleting substance obligations apply irrespective of the policy column; ODS products in Column (2) of Schedule VII are RestrictedMontreal Protocol and ODS Rules
Food entry-point restrictionsFood consignments may only enter through notified ports and points of entryAppendix-5
Beef and beef productsProhibited in any form, including products containing beefITC(HS) Schedule 1 General Notes
Hazardous wasteWaste in Schedule VI of the Hazardous and Other Wastes Rules 2016 is Prohibited notwithstanding the ITC(HS) entryHazardous and Other Wastes Rules 2016
Multichannel GSM/CDMA transceiversRestricted where the equipment operates on two or more simultaneous frequenciesGeneral Notes, Note 16

How do you file ANF-2M and where does it actually go?

ANF-2M is electronic only . Paper submissions and scanned copies of a filled form are not accepted. The path on the portal is dgft.gov.in &rarr; Services &rarr; Import Management System &rarr; Import Authorization for restricted imports &rarr; Apply for new authorization.

Two prerequisites hold up more first-time filings than anything else: the portal profile must be linked to the IEC, and a registered digital signature certificate must be attached to the logged-in user. Saving a draft produces an Application Number ; only successful submission produces a File Number . If someone in your team says the application is "filed" but can only quote an Application Number, it has not been submitted.

ANF-2M blockWhat you must supply
Part A. Applicant identityIEC, branch details, PAN, CIN, Udyam or IEM registration, and the nodal person for the application
Part A. ManagementAll directors or partners, with DIN where applicable
Part A. Item linesCountry of origin, ITC(HS) code, technical specification, quantity, unit of measurement, and CIF value in both rupees and the foreign currency
Part B. Licensing historyThree preceding licensing years of licences: number, date, port of registration, and quantity approved, consumed and balance
Part B. TurnoverThree years of sales turnover, split between indigenous and imported goods
Logistics declarationsThe State Trading Enterprise flag, Port of Import, and Port of Registration
Case for the authorisationPurpose of import and a detailed justification, plus supporting attachments
ExecutionDeclaration and undertaking signed with DSC or e-Sign by a signatory competent under FTP Para 11.06, and payment of the fee

If you are applying for many item lines, do not type them in one at a time. Use Download Sample Excel on the item screen, populate it offline, and then use Bulk upload . This is also where the portal will reject codes that are not Restricted lines, which doubles as the classification cross-check described in section 2.

What are the fees, validity and revalidation rules?

The fee is proportional to CIF value and capped at both ends. The validity rule is the harsher constraint, because unlike most DGFT instruments an import restricted authorisation has no extension provision at all .

ItemAmount or periodSource
Issuance feeINR 1 per 1,000 of CIF value, minimum INR 500, maximum INR 1,00,000Appendix 2K
Amendment feeINR 200, plus the differential fee if CIF value has increasedAppendix 2K
First revalidation feeINR 500Appendix 2K
Import authorisation validity18 months from issuance. No extension provisionHBP 2.16(iii)
Revalidation6 months from the date of expiry, by DGFT HQ on meritsHBP 2.20(a)
Deficiency rectification90 days, failing which the application is deemed withdrawnHBP 2.05(b)
Export authorisation validity (for contrast)24 months, revalidated 6 months at a time up to 12 monthsHBP Chapter 2

Two practical notes on payment. If a deficiency reply raises the CIF value, expect a proportional top-up demand alongside the amendment fee. And a payment status that reads Confirmed or Submitted for up to an hour is normal reconciliation lag, not a failed transaction. Do not pay twice. Refunds, where due, are governed by Appendix 2K read with FTP Para 2.11.

Revalidation beyond the ordinary case is tightly bounded. Under HBP 2.21 it is granted only under specific orders of the Head of Office and is capped at the custody period.

Worked example. Fee-free revalidation, from the HBP

  1. 1 Authorisation issued on 01.04.2017 . Ordinary validity therefore runs 18 months.
  2. 2 It is finally accepted on the Customs server only on 31.10.2017 .
  3. 3 The period lost to transmission failure is 7 months . The relief is the delay or 6 months, whichever is less.
  4. 4 6 months of revalidation is granted, with no fee. Provided the request is filed by end November 2017, i.e. Within one month of 31.10.2017 , with screenshots of both servers attached.
  5. 5 Had 6 clear months still remained on the authorisation at final acceptance, the relief would not be available at all.

How do you track, amend and avoid the port-of-registration trap?

Tracking sits under My Dashboard &rarr; Submitted Applications. Filter on Scheme Restricted Imports and Sub Scheme Issuance of Restricted Imports Authorisation , then open File Status. The Action menu on each row gives you View Life Cycle, Payment Details, Make a Copy, Withdraw, and View Approved Licenses &rarr; View Letter once the authorisation is granted.

Post-issuance changes run through two separate flows: Apply for Amendment, and Apply for Revalidation. On the revalidation flow only the revalidation details are editable, so do not expect to correct data there.

What you can and cannot change after issuance

  • Amendment is time-boxed. It is only possible while the import validity is still alive. Once the 18 months lapse there is nothing to amend.
  • Permitted amendments are narrow. Adding items, decreasing quantity, decreasing CIF value, and modifying the unit of measurement. Note the direction: quantity and value can come down, not up.
  • Port of registration is final. Under HBP 2.48(b) it cannot be changed after issuance and all imports under the authorisation must move through it unless Customs permits otherwise.
  • Date of import means date of shipment from the supplying country (HBP 2.17(a) read with Para 11.11), and the authorisation must be valid on that date (HBP 2.18(a)). Not on the date the vessel berths in India.
  • A duplicate is co-terminus with the original and none is issued after expiry (HBP 2.27). Losing the authorisation late in its life does not buy you time.

On deficiencies: a deficiency that is not rectified within 90 days means the application is deemed withdrawn under HBP 2.05(b). The deficiency reply flow asks "Do you want to amend application?". Answer No if you are only adding attachments, and Yes if you need to change submitted data. Either way the file returns to the same officer, so the reply should answer the query directly rather than restating the original case.

Which imports escape the authorisation requirement altogether?

Several categories of restricted goods can be imported without an authorisation. These carve-outs are worth checking before you commit to a months-long ANF-2M cycle for what may be a sample shipment or a research consignment.

Carve-outs from the authorisation requirement

  • Samples. FTP 2.25. Bona fide technical and trade samples of restricted items may be imported without an authorisation, excluding defence and security items, seeds, bees and new drugs, which stay governed by HBP 2.62.
  • R&D units. HBP 2.50. Government-recognised research and development units may import all restricted items and all STE items for research purposes, except live animals.
  • No-forex-remittance categories. General Notes, Note 1. Personal effects of UN officials, equipment of returning professionals, mountaineering baggage, paintings for exhibition, FCRA-covered charity gifts, food parcels up to INR 1,00,000 a year, Red Cross and relief consignments, donations to the National Defence Fund, and foreign television crews' equipment brought in against re-export.
  • Human biological samples. General Notes, Note 17. Samples for laboratory analysis or research and development clear at the port of entry without a licence, on an undertaking.

Second-hand goods deserve their own table, because the split between Restricted and Free is counter-intuitive and is a frequent source of stranded consignments. The governing provisions are FTP 2.31, General Note 14 and HBP 2.58.

Second-hand categoryStatusCondition
Desktop computersRestrictedAuthorisation required
Refurbished or reconditioned spares of refurbished PC and laptop partsRestrictedAuthorisation required; dossier evidence on installed base applies
Air conditionersRestrictedAuthorisation required
Diesel generating setsRestrictedAuthorisation required
All other second-hand non-capital goodsRestrictedAuthorisation required
Refurbished or reconditioned spares of capital goodsFreeChartered engineer certificate of at least 80% residual life
All other second-hand capital goodsFreeSubject to the general conditions of the ITC(HS) line
Goods imported for repair, refurbishing or re-engineeringFreeSubject to waste-disposal rules and re-export of the processed goods

Finally, a set of value-capped entitlements sits outside the ordinary case-by-case route. Arms and ammunition dealers are entitled to 5% of the average annual ammunition sales turnover of the preceding three licensing years, subject to a minimum of INR 2,000. Hotels recognised by the Director General of Tourism are entitled to 25% of the foreign exchange earned from foreign tourists in the preceding licensing year; travel agents, tour operators, restaurants, tourist transport operators, and adventure and convention units are entitled to 10%. These tourism-sector applications route to DGFT Headquarters through the Director of Tourism, and unused entitlement can be carried forward for two years.

Restricted import checklist and the mistakes that sink a consignment

Before you ship anything

  • Confirm the policy status on the 8-digit national line, not the 6-digit heading
  • Read the policy condition, the General Notes and Appendices 1 to 5, not just the policy column
  • Check BIS Appendix-III, CRO 2012 and Appendix-5 entry points even where the line reads Free
  • Confirm you qualify as the Actual User, because the authorisation is non-transferable under FTP 2.09
  • File ANF-2M electronically to DGFT Headquarters with a registered DSC, not to your jurisdictional RA
  • Budget your timeline around the EXIM Facilitation Committee's roughly monthly cadence (HBP 2.48(c))
  • Choose the port of registration deliberately. It is final under HBP 2.48(b)
  • Treat the 18-month validity as absolute; HBP 2.16(iii) carries no extension provision
  • Verify transmission to the Customs server within 15 working days so the HBP 2.20(d) relief stays available
Item typeDossier the ANF-2M must carry
AircraftYear of manufacture, new or second-hand, number of seats, residual life, flying hours, private or passenger use, and model
MachineryYear of manufacture and residual life
Bulk drug or formulationDrug Manufacturing Licence, plus chartered accountant-certified production and consumption data for three years
Refurbished computer partsManufacturer or authorised agent status, and the installed base for two years
Government, Police or Defence supplyCopy of the recommendation, and the End User Certificate

Three further traps are worth naming explicitly. First, FTP Para 2.14 : breach of a condition of the authorisation, or an unpaid demand, triggers action under the Foreign Trade (Development and Regulation) Act, false self-certification draws additional penal action, and DEL listing follows under Rule 7 of the Foreign Trade (Regulation) Rules 1993. A DEL-listed IEC can still submit an application, but the file will not be actioned until the listing is cleared; a cancelled or suspended IEC cannot submit at all.

Second, language. Under HBP 2.03(a) documents must be in English or Hindi. Any regional-language original must be accompanied by a self-certified translation. A routine deficiency on dossiers assembled from state-level licences.

Update history

  • First published.