An Indian manufacturer may have the overseas buyer, purchase order, freight plan and customs documents ready – and still discover that the product cannot legally be shipped without strategic export-control clearance.
That is where SCOMET compliance becomes important.
SCOMET stands for Special Chemicals, Organisms, Materials, Equipment and Technologies. It is India’s national export-control framework for specified dual-use, nuclear-related, defence-related and strategic items, including certain software and technology. Controlled items are listed in Appendix 3 to Schedule 2 of ITC (HS). Depending on the category, exports may require authorisation from DGFT, the Department of Atomic Energy or the Department of Defence Production.
If you are uncertain whether an overseas shipment is controlled, the first step should be a technical SCOMET classification assessment – before dispatching the goods.
A SCOMET licence or authorisation permits export of specified controlled goods, software or technology where prior authorisation is required under India’s export-control framework.
The SCOMET list covers items that may have legitimate civilian or industrial uses but may also present military, proliferation, nuclear, chemical, biological or strategic-security concerns. FTP 2023 therefore provides that covered exports are prohibited or permitted under authorisation unless specifically exempted.
The important point for exporters is that SCOMET classification is different from an ordinary restricted export licence.
A product may look like ordinary commercial equipment and still contain technical characteristics that bring it within a SCOMET entry.
Depending on exact specifications, SCOMET controls can extend across chemicals, microorganisms, specialised materials, materials-processing equipment, aerospace systems, electronics, computers, telecommunications, information security, sensors, lasers, navigation systems, marine equipment and related technology.
This does not mean every product in these sectors requires a licence. Applicability depends on the actual SCOMET entry, technical parameters, intended use, destination, end user and relevant exemptions.
Before filing an application, answer five questions.
Prepare the complete technical description, model, part number, performance parameters, material composition and function.
DGFT’s regulatory page presently lists the Updated SCOMET List 2025, dated 23 September 2025, as its latest list. The classification exercise should therefore use the current list rather than an old PDF saved by the organisation several years ago.
SCOMET is not limited to physical cargo. FTP Chapter 10 expressly includes relevant software and technology within the strategic export-control framework.
DGFT’s current procedure examines the credibility of the end user, declared end use, supply chain and possible diversion or proliferation concerns.
Yes.
The current HBP provides a catch-all control where an exporter has been notified, knows, or has reason to believe that a non-SCOMET item risks use or diversion in weapons of mass destruction, missile systems or military use, including by terrorists or non-state actors. In such circumstances, a SCOMET authorisation may still be required.
That is why simply searching the HS code and concluding “not SCOMET” can be risky.
The current policy divides the list into Categories 0 to 8, with Category 7 reserved.
| Category | Broad coverage | Main licensing authority |
|---|---|---|
| 0 | Nuclear materials, related equipment and technology | Department of Atomic Energy |
| 1 | Toxic chemical agents and other chemicals | DGFT |
| 2 | Micro-organisms and toxins | DGFT |
| 3 | Materials, processing equipment and related technology | DGFT |
| 4 | Other nuclear-related equipment and technology | DGFT |
| 5 | Aerospace systems and related equipment/technology | DGFT |
| 6 | Munitions List | Department of Defence Production, subject to specified exceptions |
| 7 | Reserved | – |
| 8 | Advanced materials, electronics, computers, telecom, information security, sensors, navigation, marine, aerospace and related areas | DGFT |
Certain exceptions within Category 6 and the Commodity Identification Note have different jurisdiction, so exporters should confirm the exact sub-category instead of relying only on the broad category number.
For DGFT-administered cases, a practical filing sequence is:
Match the product or technology against the latest SCOMET control entry and record why it is controlled or not controlled.
A good classification file should contain the product datasheet, technical parameters, model/part number, intended function and the exact SCOMET entry reviewed.
Not every transaction follows the same route.
The HBP separately addresses regular exports, repeat orders, stock-and-sale transactions, repair or replacement, temporary exports for demonstrations or exhibitions, intra-company transfers and specified general-authorisation mechanisms.
Identify:
Current DGFT requirements place significant emphasis on the integrity of the chain between exporter and ultimate end user.
DGFT’s current Aayat Niryat Forms page identifies ANF-10A as the application form for export of SCOMET items listed in Appendix 3 to Schedule 2.
The current HBP requires applications to be filed through:
Services → Export Management System → SCOMET
Supporting documents are uploaded electronically. Manual filing of the complete application has been discontinued, although original EUCs or the relevant legal undertaking still have to be provided in hard copy where prescribed.
DGFT’s FAQ also identifies an IEC-linked user profile and registered DSC among the prerequisites for SCOMET filing.
SCOMET cases considered by the Inter-Ministerial Working Group are assessed against matters such as end-user credentials, end use, supply-chain integrity, diversion risk, national-security considerations and India’s international non-proliferation commitments.
DGFT’s online system permits applicants to view a deficiency and submit a response, including amendments or additional attachments where required.
The quality of the response matters. A generic reply may not resolve a technical classification or end-user question.
The exact documentation depends on the export route and SCOMET category. Current DGFT Appendix 10 identifies key documents for a standard application including the relevant End User Certificate/End Use documentation, purchase order or invoice, and technical specifications or technical drawings.
| Document/information | Main responsibility |
|---|---|
| IEC and exporter details | Indian exporter |
| Technical specification/drawing | Exporter/manufacturer |
| Correct SCOMET classification | Exporter, supported by technical review |
| Purchase order/contract | Foreign buyer/exporter |
| End Use-cum-End User Certificate | Relevant foreign entities in supply chain |
| Buyer/consignee/end-user details | Foreign parties + exporter verification |
| Specific end-use explanation | Ultimate end user |
| Previous SCOMET export details, where relevant | Exporter |
| Additional assurances sought by authority | Applicant/foreign party as applicable |
One of the most important consistency checks is that the product description, technical parameters, purchase order and EUC tell the same story. Current ANF-10A guidance specifically emphasises matching details across the application, EUC and purchase order.
Before submitting the file, an exporter should be able to answer “yes” to the following:
If several answers are “no”, filing immediately may create more work than completing the compliance review first.
DGFT’s current Appendix 2K prescribes an application fee of ₹1,000 for an export licence/SCOMET item application. Professional consulting or technical-classification charges are separate commercial costs and are not government fees.
There is no responsible basis for promising a fixed approval period for every SCOMET application.
Under the current HBP, IMWG members are expected to endeavour to provide comments, views or NOC to DGFT within 30 days after DGFT forwards the application, and the IMWG normally meets once every month. That does not mean every complete SCOMET authorisation will automatically be granted within 30 days. Technical queries, inter-agency examination, end-user verification or proliferation concerns may affect the case.
For a standard SCOMET authorisation, the current July 2026 HBP specifies a validity period of 24 months from the date of issue unless otherwise specified.
A normal authorisation may be revalidated on merit for six months at a time, up to a maximum additional period of 12 months. The application is prescribed to be made in ANF-10F 30 days before expiry. Revalidation is not available for technology/software transfers and certain general-authorisation categories.
General-authorisation routes can have different validity periods. For example, the HBP provides specific validity conditions for GAICT, GAEC, GAER, GAED, GAET and GAEIS rather than applying the standard 24-month period automatically.
Depending on the commercial transaction, the correct solution may not be a simple one-shipment authorisation.
The current HBP contains procedures for situations including:
Repeat orders: Certain exports of the same controlled item to the same country/entities can qualify for a repeat-order route, subject to prescribed conditions.
Stock and sale: Allows specified bulk exports to an overseas stockist followed by transfer to approved ultimate end users, subject to detailed conditions and reporting.
Repair or replacement: Separate procedures exist for export/re-export of defective controlled items and for eligible re-export following repair.
Temporary exports: Specific procedures apply to demonstrations, displays, exhibitions, tenders and similar temporary movements.
General authorisations: The current HBP includes mechanisms such as GAICT for qualifying intra-company transfers, GAET for specified telecommunications items, GAEIS for qualifying information-security items, and GAEC for specified chemical-related exports. Each has separate eligibility and reporting requirements.
Choosing the wrong pathway can result in unnecessary documentation or a file that does not reflect the actual commercial transaction.
Licence holders also need an internal export-control record.
The current HBP requires every SCOMET export-authorisation holder to maintain relevant records, including application documentation, for five years or the validity of the export authorisation, whichever is higher, calculated from the applicable export or import date.
Some general-authorisation and stock-and-sale routes also carry specific post-shipment or periodic reporting obligations.
For businesses regularly exporting controlled technology, an internal compliance process should therefore cover classification, buyer screening, EUCs, approval status, shipment records, licence balances and post-reporting obligations.
A technically controlled product should not be treated like a normal paperwork licence.
Typical risk areas include inconsistent technical descriptions, wrong SCOMET sub-category, vague end use, incomplete supply-chain information, mismatches between the EUC and purchase order, selecting a regular licence when a specialist route is more appropriate, or assuming that an old classification remains valid after the control list changes.
Another serious mistake is treating an HS code as the final classification answer. DGFT’s current forms and control list are highly specification-driven; a defensible decision should therefore document the technical basis for the classification.
Consider an Indian advanced-electronics manufacturer preparing a shipment to an overseas industrial buyer.
The commercial invoice simply describes the product as an electronic control module. However, the equipment contains specialised technical functionality requiring comparison with Category 8 control parameters.
The immediate question is not:
“What is the HS code?”
It is:
“Do the exact specifications cross a SCOMET control threshold, and if they do, who will ultimately use the equipment and for what purpose?”
The company should first document the classification, map the buyer-consignee-end-user chain, obtain the appropriate EUCs and then select the relevant authorisation route.
This example is illustrative and does not classify any particular product.
DGFT states that export of SCOMET items without appropriate authorisation attracts penal provisions under the FTDR Act.
Section 11 of the FTDR Act provides that a person making, abetting or attempting an export or import in contravention of the Act, rules, orders or Foreign Trade Policy may be liable to a penalty of not less than ₹10,000 and up to five times the value of the goods, services or technology involved, whichever is more. Application of the provision depends on the facts and adjudication of the specific case.
If an organisation discovers a possible export-control violation, the current HBP also provides a mechanism for voluntary self-disclosure to the SCOMET Division of DGFT.
No. SCOMET is a specific strategic export-control list. DGFT separately maintains procedures and forms for other restricted exports. Its current forms page, for example, lists ANF-10A for SCOMET and ANF-2N for restricted export licences.
No. The list includes many dual-use products with legitimate civilian or industrial applications, as well as controlled software and technology.
Potentially yes, where the catch-all provisions apply because the exporter knows, has reason to believe, or has been informed of specified WMD, missile or military-use risks.
The current HBP states that SCOMET authorisation is not required merely for supply from DTA to an SEZ/EOU, subject to the prescribed reporting. However, authorisation is required when the item is physically exported outside India from the SEZ/EOU.
A standard SCOMET authorisation is presently valid for 24 months unless otherwise specified. Special general-authorisation schemes may have different validity periods.
The current DGFT Appendix 2K specifies ₹1,000 for an export licence/SCOMET item application.
A competent DGFT SCOMET licence consultant should do more than upload documents.
The advisory work should begin with classification and transaction review:
Green Permits provides regulatory and import-export compliance support to businesses operating in India. Its broader DGFT compliance service is available through the DGFT License in India page, and company information is available on the About Green Permits page.
If your company is planning to export a product that may fall within the SCOMET framework, consider completing the technical classification and end-user documentation review before committing the shipment date.
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