A business story to begin with
When a Noida-based electronics refurbisher began exporting reconditioned laptops to Africa, customs flagged the shipment under “restricted goods.”
The exporter held valid CPCB EPR authorization but didn’t realize that DGFT’s “export after repair” approval was also required. The missing license delayed the shipment for 45 days and added ₹3.2 lakh in warehousing costs.
Such incidents are not rare. As India accelerates toward a circular economy, businesses that bridge the gap between environmental compliance (CPCB, MoEFCC) and trade governance (DGFT) are gaining a competitive edge. DGFT’s latest reforms under the Foreign Trade Policy 2023 (FTP 2023) mark a crucial shift — transforming trade rules to align with sustainability and global green trade standards.
India’s Circular Economy Vision under FTP 2023
The FTP 2023 goes beyond export promotion — it positions India as a global supplier of sustainable goods and services.
What the policy emphasizes:
- Making India a global hub for green manufacturing and recycling.
- Encouraging remanufacturing, repair, and refurbish exports to reduce carbon waste.
- Linking export incentives with sustainability targets and digital traceability.
- Aligning trade norms with the Basel Convention and UN SDGs.
Business relevance:
These reforms mean exporters dealing in refurbished, recyclable, or green-certified goods can now access clear legal pathways for movement — something that was earlier fragmented across multiple agencies.
How DGFT’s Reforms Drive Sustainable Trade
DGFT now acts as the convergence point between trade growth and environmental responsibility.
Key policy shifts that matter:
- Export after repair (GAER – Para 10.12 of HBP):
Simplifies movement of defective goods for repair and re-export, reducing waste and saving costs. - Authorization-free exports for certain refurbished categories:
DGFT has exempted specific low-risk refurbished goods (non-SCOMET) from licensing barriers. - Simplified import norms for recyclable inputs:
Registered recyclers can import waste or scrap (batteries, metals, plastics) under MoEFCC consent. - Online issuance of authorizations:
DGFT’s eCom module integrates with ICEGATE, reducing manual touchpoints by 60%. - Faster disposal of “restricted item” applications:
A 30-day SLA introduced for most import/export license decisions.
Result:
Circular business models — from refurbished electronics to battery material recovery — can now operate at scale with predictable policy backing.
DGFT’s Interlink with EPR and CPCB Compliance
While DGFT ensures trade legitimacy, CPCB and MoEFCC ensure environmental responsibility. Together, they create India’s dual compliance backbone for circular economy trade.
| Activity | Governing Rule | Key Permission Needed | Responsible Authority |
|---|---|---|---|
| Import of used electronics for repair | E-Waste Rules 2022 | MoEFCC Consent + DGFT License | DGFT + MoEFCC |
| Export of refurbished goods | FTP 2023 (GAER) | Export Authorization | DGFT |
| Import of used batteries / battery scrap | Battery Waste Management Rules 2022 | EPR Registration + DGFT License | CPCB + DGFT |
| Recycling plant setup | Environment (Protection) Act + EPR Portal | Consent to Operate + EPR ID | SPCB + CPCB |
| Use of recycled content in export goods | FTP 2023 + BIS | Quality Certification | BIS + DGFT |
Interpretation:
DGFT handles the “entry-exit” gate of trade; CPCB manages “in-country compliance.” When both align, India builds a traceable loop of waste-to-resource trade — the essence of circular economy.
The Circular Economy Ecosystem — A Policy Web in Motion
1. DGFT (Trade Policy)
Manages import/export licensing and defines “restricted” goods through the ITC (HS) schedule.
2. CPCB & SPCB (Environmental Oversight)
Issue EPR authorizations, validate recyclers, and track waste return and recovery.
3. MoEFCC (Policy & Basel Control)
Approves transboundary movement of waste under the Basel Convention.
4. BIS (Quality & Standards)
Ensures recycled materials and refurbished goods meet export quality benchmarks.
5. NITI Aayog (Strategy)
Monitors progress toward national circular economy targets — battery, plastics, e-waste, and textiles.
Together, these five agencies shape India’s green trade architecture.
Circular Economy by the Numbers — The Business Case
| Sector | FY 2021-22 Market Size | Expected CAGR (2023–2030) | Opportunity for Circular Trade |
|---|---|---|---|
| Battery Recycling | $1.2 Billion | 23% | Export of recovered metals (Li, Co, Ni) |
| E-Waste Processing | $3.1 Billion | 18% | Export of refurbished electronics |
| Plastic Recycling | $2.7 Billion | 12% | Import of scrap, export of recyclate |
| Metal Recovery | $4.5 Billion | 10% | Secondary raw material export |
| Renewable Component Refurbishment | $1.0 Billion | 20% | Solar modules, wind parts reuse |
Interpretation:
Circular trade is not a niche — it’s a multi-billion-dollar opportunity for Indian exporters leveraging DGFT and CPCB frameworks smartly.
DGFT Notifications Strengthening Circular Trade (2023–2025)
Recent policy actions you can reference:
- Notification 23/2023 (3 Aug 2023):
Import licensing for IT equipment (laptops/tablets) restructured — enables repair/refurb channels with authorization. - Trade Notice 22/2024:
8-digit HS code reclassification — helps recyclers identify permissible scrap categories. - Circular 07/2024:
Clarifies validity of import licenses — ensures ongoing authorization for long-term recycling projects. - FTP Para 2.05:
Introduced self-certification for certain low-impact recyclable goods.
Business implication:
The reforms reduce ambiguity, speed up customs clearance, and encourage formal recycling supply chains over informal scrap trade.
Risk & Penalty Landscape — Why Compliance Matters
Ignoring DGFT-EPR integration can lead to heavy costs, not just delays.
Potential penalties include:
- Import/export license suspension under FTP Section 8.
- Fines ranging from ₹5–₹10 lakh per instance.
- CPCB registration cancellation or blacklisting.
- Confiscation of shipments by customs for Basel non-compliance.
- International buyer contract termination due to missing traceability documents.
Hidden cost:
Every day of customs detention can cost ₹8,000–₹10,000 in demurrage — a common pain point for unaware exporters.
Humanized Example — The Solar Refurbisher’s Breakthrough
A Pune-based solar equipment company used to discard imported faulty modules due to unclear export norms. After FTP 2023, DGFT allowed “export after repair” with simplified documentation.
Within six months, the company exported 2,000 repaired modules to the Middle East — earning ₹1.4 crore in recovered value while avoiding waste disposal costs.
The change was possible through DGFT’s GAER provisions + CPCB’s EPR compliance, handled jointly via Green Permits.
India’s Trade Vision 2030 — Where We’re Headed
Policy direction shaping up:
- Integration of DGFT and CPCB online portals for real-time tracking.
- Introduction of a Green Export Promotion Scheme (GEPS) rewarding recycled content.
- Expansion of Basel-compliant trade approvals to cover EV, textile, and renewable waste.
- Creation of a National Circular Economy Dashboard under NITI Aayog for unified reporting.
- Inclusion of carbon footprint disclosure in export documentation.
These measures will make India’s export system more transparent, sustainable, and competitive globally.
Key Takeaways for Indian Businesses
- Map your trade activities: Identify if your imports/exports involve restricted or recyclable items.
- Register on CPCB’s EPR portal: Ensure recyclers and producers have valid authorization.
- Check DGFT’s ITC (HS) list: Verify if your goods fall under “restricted” or “free” category.
- Leverage Green Permits’ guidance: Align your DGFT, BIS, and CPCB filings seamlessly.
- Stay ahead of deadlines: Renewal delays can halt exports abruptly.
Conclusion — Green Trade Begins with Smart Compliance
Circular economy is more than an environmental goal — it’s the next competitive edge for Indian exporters.
DGFT’s export-import reforms have opened the door to a cleaner, faster, and more profitable trade future, where compliance fuels growth, not delays.
Green Permits simplifies this journey — from DGFT licensing to CPCB registration, so your business can focus on scaling sustainably.
📞 +91 78350 06182 | 📧 wecare@greenpermits.in
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FAQs
DGFT creates export-import policies that promote recycling, reuse, and refurbish-based trade while aligning with EPR obligations.
The 2023 FTP introduced export-after-repair (GAER), simplified recycling imports, and digital authorization systems.
Yes, but only with valid DGFT authorization and CPCB EPR registration under MoEFCC consent.
It ensures that waste trade (including recyclables) follows global consent and environmental safeguards before shipment.
Customs may detain goods, impose fines, or cancel your IEC — even if you have EPR registration.
