HS Code 73181500 Amended under RoDTEP โ€“ Expanded Scope for Exporters

Dated: 10.04.2026

In a significant yet technical amendment, the Directorate General of Foreign Trade (DGFT) has issued Notification No. 06/2026-27 dated 09 April 2026, bringing clarity to the description of HS Code 73181500 under the RoDTEP Scheme.

This move reflects the Governmentโ€™s continuing effort to ensure harmonisation between export incentive schemes and Customs Tariff classification, thereby reducing ambiguity for exporters and compliance professionals.

Legal Framework Behind the Notification

The notification has been issued under:

  • Section 5 of the Foreign Trade (Development and Regulation) Act, 1992
  • Read with Para 1.02 of FTP 2023

It amends:

  • Appendix 4R and Appendix 4RE of the Handbook of Procedures (HBP) relating to the Remission of Duties and Taxes on Exported Products (RoDTEP) Scheme.

What Has Changed? (Core Amendment)

As per the official notification :

HS CodeExisting DescriptionRevised Description
73181500Screw for use in manufacture of cellular mobile phoneOther screws and bolts, whether or not with their nuts or washers

Understanding the Amendment

1. Removal of Sector-Specific Restriction

Earlier, the description restricted the applicability to:

โ€œScrews used in manufacture of cellular mobile phonesโ€

Now, the revised description:

โ€œOther screws and bolts, whether or not with their nuts or washersโ€

This expands the scope significantly by:

  • Removing end-use restriction
  • Aligning with generic tariff description under Customs Tariff Act, 1975

2. Alignment with Customs Tariff

The notification explicitly states that the amendment is:

โ€œto align the description with the corresponding HS classification as per the First Schedule to the Customs Tariff Act, 1975โ€

This is a crucial correction because:

  • Export incentive schedules must mirror tariff classification
  • Any mismatch leads to denial or disputes in RoDTEP claims

3. Retrospective Effect

A key highlight is:

  • Effective Date: 15 December 2022

This means:

  • Past exports under this HS Code may be impacted
  • Exporters may need to revisit claims or eligibility

Impact on Exporters

1. Wider Coverage under RoDTEP

  • Exporters dealing in general screws and bolts can now claim benefits
  • No longer limited to mobile manufacturing supply chain

2. Reduction in Litigation Risk

  • Eliminates classification-based disputes
  • Reduces rejection of RoDTEP claims due to description mismatch

3. Opportunity for Reassessment of Past Claims

  • Exporters who were earlier denied benefits may:
    • Seek reprocessing
    • File representations

Compliance & Advisory Points

Exporters should take the following steps:

  • Review HS Code 73181500 exports since Dec 2022
  • Reconcile shipping bills with RoDTEP claims
  • Maintain documentation showing product classification
  • Evaluate possibility of:
    • Amendment requests
    • Refund/re-credit claims

Conclusion

Notification No. 06/2026-27 is a welcome corrective step, albeit delayed. By aligning the RoDTEP schedule with the Customs Tariff, the Government has removed an artificial restriction that could have led to unnecessary denial of export incentives.

However, the retrospective effect introduces both opportunity and complexityโ€”exporters must act swiftly to safeguard their claims and optimise benefits.

In case you face any issues related to Indirect Tax-Customs, GST, Foreign Trade Policy (FTP), Arbitration matters and Central Licensing and related advisory matters in India then please feel free to get in touch with SJ EXIM Services.

We offer Legal advice and litigation support in matters related to Indirect Tax-Customs, FTP, other Indirect Tax matters & Arbitration law, all sorts of Central licensing and related matters. Come and explore the new way of doing business with us!


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