DGFT & RCMC Registration

A Registration-cum-Membership Certificate (RCMC) is issued by the relevant Export Promotion Council (EPC) or commodity board and is required under Paragraph 2.91 of the Foreign Trade Policy 2023 for any exporter seeking to avail benefits, concessions, or authorisations under the FTP. Without a valid RCMC, exporters cannot claim advance authorisations, Export Promotion Capital Goods (EPCG) licences, or duty drawback benefits linked to export performance obligations. The RCMC is granted by the EPC whose product range covers the exporter's main line of business — for example, FIEO issues RCMC for service exporters and EEPC India for engineering goods exporters. The certificate is valid from April 1 of the year of registration to March 31 of the fifth year, and must be renewed thereafter; a lapsed RCMC prevents the exporter from availing FTP benefits during the lapsed period.

An exporter applies for RCMC online through the DGFT portal at dgft.gov.in by filing the application form specific to the relevant EPC, accompanied by a copy of the IEC issued by DGFT, PAN card, bank certificate or Authorised Dealer certificate confirming the export account, and a memorandum or list of products to be exported. For service exporters, FIEO requires a copy of GST registration and a declaration of the service category in accordance with Paragraph 2.92 of the FTP 2023. Membership and registration fees vary by EPC — FIEO's annual membership fee depends on the category of membership (associate, regular, etc.) — and must be paid online at the time of application. Once the EPC verifies the documents and payment, the RCMC is issued digitally and is also reflected on the DGFT portal against the exporter's IEC, enabling verification by customs and banks for benefit claims.

Yes, a valid RCMC is required to claim RoDTEP benefits as these are export promotion benefits under the Foreign Trade Policy 2023. RoDTEP was notified by the Ministry of Commerce vide Notification No. 19/2015-2020 (RE 2021) and is implemented through the ICEGATE portal — exporters must declare their RoDTEP eligibility in the Shipping Bill filed under Section 50 of the Customs Act 1962, and the credit scrips are issued electronically based on approved rates notified product-wise. The exporter must hold a valid IEC, active RCMC, and GST registration to be eligible. RoDTEP rates are product-specific and are notified by DGFT in Appendix 4R of the FTP; exporters should verify the applicable rate for their ITC (HS) code before shipping. RoDTEP scrips can be used for payment of BCD on imports or transferred to other importers, making their proper claim commercially significant.

Exporting without a required RCMC does not by itself make the export illegal, as exports are governed primarily by the Customs Act 1962 and the Foreign Trade (Development and Regulation) Act 1992 which do not require RCMC for the physical act of export. However, any benefit or authorisation claimed under the FTP — such as advance authorisation under Chapter 4 of the FTP 2023, EPCG under Chapter 5, or scrip-based benefits — will be denied or subject to recovery with interest and penalty if the exporter cannot produce a valid RCMC at the time of availing the benefit. Claims already availed without a valid RCMC are treated as irregular and the DGFT can issue a demand and recovery notice under Rule 7 of the Foreign Trade (Regulation) Rules 1993. The exporter is advised to obtain RCMC before filing any application for an advance authorisation or EPCG licence to avoid complications during the export obligation discharge period.

Under the Advance Authorisation scheme governed by Chapter 4 of the Foreign Trade Policy 2023, an exporter is permitted to import specified inputs duty-free against a commitment to export a defined quantity of the resultant product within 18 months from the date of authorisation (extendable under Paragraph 4.51 of the Hand Book of Procedures 2023). The exporter must maintain a valid RCMC throughout the export obligation period, as annual confirmation of RCMC is required for certain product categories at the time of applying for extension or redemption. Export Obligation Discharge Certificates (EODC) are issued by the regional DGFT authority after verifying Shipping Bills and Bank Realisation Certificates or FIRC confirming receipt of foreign exchange under Rule 3 of the Foreign Trade (Regulation) Rules 1993. Failure to fulfil export obligation results in recovery of customs duty foregone along with interest at 15% per annum under Section 28AA of the Customs Act 1962 and penalty under the FT(D&R) Act 1992.