An Indian importer finalises an overseas purchase order, pays the supplier and books the shipment. The business has an active IEC and assumes that Customs clearance should be routine.
Then the product classification is reviewed more closely.
The applicable 8-digit ITC HS entry says “Restricted.”
At this stage, having an IEC is not enough. The importer may require a specific DGFT import authorisation, and depending on the product, another regulatory approval may also have to be obtained before the consignment can move smoothly through Customs.
This is where a DGFT Restricted Item Import Licence Consultant in India becomes useful. The work should begin with classification and regulatory mapping rather than simply filling an online form.
Under the Foreign Trade Policy 2023, imports and exports are generally Free unless regulated through prohibition, restriction, State Trading Enterprises or another applicable condition. Product-specific importability is determined through the ITC HS import policy.
A restricted import licence, more formally referred to as a Restricted Import Authorisation, permits the import of goods whose applicable ITC HS entry does not allow unrestricted import.
DGFT describes restricted goods as goods whose import is permitted only with an authorisation, permission or licence, or according to a prescribed procedure.
The important point is that Restricted does not mean Prohibited.
A restricted product may be imported if the applicant satisfies the applicable policy conditions and receives the necessary authorisation. A prohibited product, on the other hand, cannot automatically be made importable merely by filing ANF-2M.
This distinction should be established before the overseas supplier dispatches the shipment.
No.
An Importer Exporter Code identifies the importer for foreign-trade purposes, but it does not override an ITC HS restriction.
The first compliance question should therefore be:
What is the exact 8-digit ITC HS code and what is its current import-policy status?
The DGFT website provides an ITC HS-based import-policy search facility through which businesses can check the policy attached to individual codes.
This check matters because a product may be:
| Import status | Practical meaning |
|---|---|
| Free | Usually no DGFT restricted import authorisation, although other regulatory conditions may still apply |
| Restricted | Import requires applicable DGFT authorisation or prescribed permission |
| Prohibited | Import is generally not permitted except where a specific legal exception exists |
| STE | Import is subject to the applicable State Trading Enterprise mechanism |
| Free subject to condition | No restricted licence may be necessary, but another policy condition can still control import |
A consultant should therefore not conclude that a licence is necessary merely from the product’s commercial name.
The classification and exact policy condition come first.
The requirement is product-specific rather than business-size-specific.
It may affect manufacturers, merchant importers, traders, MSMEs, project companies or other entities when the ITC HS classification or applicable notification places the proposed goods under a restricted import regime.
Second-hand goods provide one example of why the policy needs to be checked carefully. Current FTP provisions treat certain second-hand goods differently according to their nature, and some categories require restricted import authorisation while others are subject to separate conditions.
The safest approach is therefore not to rely on broad categories such as “machinery”, “electronics”, “scrap” or “chemicals”.
Check the actual product.
Before filing, answer these five questions.
A commercial description is not enough.
Technical specifications, composition, intended use and product characteristics may change the classification.
Check the live DGFT ITC HS policy rather than relying on a historic notification or an old licence obtained for a similar product.
FTP 2023 specifically states that importability is governed by the policy applicable on the relevant date of import.
Not necessarily.
The ITC HS condition or underlying product law may connect the import to another technical or administrative authority.
Depending on the product, separate requirements may arise under BIS, WPC, CDSCO, FSSAI, PESO, environmental legislation or another sector-specific framework. These approvals should be mapped individually rather than assumed.
DGFT’s ANF-2M captures information including the restricted item, ITC HS code, quantity, country of origin, CIF value, purpose of import and other product-specific information. Machinery and some specialised categories require additional details.
This is especially important.
Under the current HBP, the date of import is reckoned with reference to the shipment or dispatch date from the supplying country, rather than merely the date on which the consignment reaches an Indian port. The authorisation must be valid on the relevant date.
This makes “we will apply after the cargo reaches India” a dangerous compliance strategy.
There is no single universal checklist for every restricted product.
The document file should be built around the product and policy condition.
Core information generally includes:
The present ANF-2M process is electronic, and DGFT states that paper or scanned ANF-2M forms are not to be submitted merely as substitutes for the online workflow.
Review the product description, technical literature and intended use and identify the appropriate 8-digit classification.
Do not start with the licence form.
Start with the classification.
Check whether the item is actually Restricted and whether any exemption, end-use condition, quota, technical recommendation or other regulatory condition applies.
Where relevant, determine whether another government authority must issue an NOC, recommendation, registration or product approval.
The HBP expressly allows DGFT to obtain assistance and advice from technical authorities or ministries when considering restricted-item applications.
The application should accurately match commercial and technical records.
Particular care is required with:
DGFT’s restricted-import workflow is available through:
Services → Import Management System → Restricted Imports → Apply for Restricted Imports Authorisation.
The applicant’s DGFT profile must be linked with its IEC, and DGFT’s restricted-import FAQ also identifies a registered digital signature as a prerequisite for the workflow.
Under the currently published Appendix 2K, the application fee for an import licence for a restricted item is calculated at ₹1 per ₹1,000 or part thereof, based on the relevant CIF/duty-saved amount, subject to a minimum ₹500 and maximum ₹1,00,000.
Consultancy fees are separate from this statutory government fee.
An application for a restricted item can be considered by DGFT with assistance from the EXIM Facilitation Committee (EFC) and relevant technical authorities.
The current HBP states that the EFC normally meets once every month. However, that is not a guaranteed one-month approval timeline. Technical comments, policy complexity, deficiencies and product-specific requirements can affect the actual processing period.
DGFT may return an application for clarification.
The online portal allows the applicant to view the deficiency, amend application details where needed, upload supporting documents and submit the response back into the workflow.
A strong response should answer the regulator’s exact question rather than simply uploading more documents.
Before using the licence, verify:
For EDI ports, DGFT discontinued the routine physical issuance of restricted import authorisations from 19 October 2023 and transmits the relevant authorisation electronically to the Customs port of registration.
Under the current Handbook of Procedures, an import authorisation for restricted items normally has a validity of 18 months from its date of issue, unless another provision specifies otherwise.
Specific authorisations may have shorter or longer periods where the competent authority provides accordingly.
The current HBP also permits an import authorisation to be revalidated on merits for six months from expiry by DGFT Headquarters, subject to the applicable restrictions and circumstances.
Businesses should therefore rely on the conditions appearing on their actual authorisation instead of assuming every restricted licence operates identically.
A restricted-import application often becomes difficult because information was inconsistent before the application reached DGFT.
Frequent risk areas include:
The right objective is therefore customs-ready compliance, not simply “application submitted”.
A good filing begins with this sequence:
Product → 8-digit ITC HS → Current Import Policy → Restricted Condition → Technical Authority/NOC → ANF-2M → DGFT/EFC Review → Authorisation → Customs
Skipping the middle steps is one of the easiest ways to obtain a licence file that does not match the actual shipment.
A DGFT consultant should provide more than portal filing.
A structured engagement can include:
Classification review – examining product information and the proposed ITC HS classification.
Policy-condition assessment – checking whether the product is Free, Restricted, Prohibited, STE-controlled or subject to another condition.
Approval mapping – identifying connected product, environmental or technical approvals where applicable.
Document-gap review – comparing available records with ANF-2M and product-specific requirements.
Application preparation – preparing consistent descriptions, quantity, value, origin, end-use and technical information.
Query response – analysing DGFT deficiencies and preparing supporting clarification.
Authorisation review – checking licence conditions before commercial use.
Import-readiness coordination – aligning the authorisation with Customs documentation and other applicable registrations.
Green Permits’ broader compliance model already combines DGFT with other market-entry requirements rather than treating each licence in isolation.
Ideally, complete the classification and regulatory assessment before finalising shipment instructions.
A useful sequence is:
Supplier quotation → HS/policy review → approval mapping → DGFT filing → licence grant → final shipment documentation → dispatch → Customs clearance
This sequence is particularly important because the HBP’s date-of-import provisions refer to shipment or dispatch from the supplying country rather than simply arrival at an Indian port.
No. Most products are not imported under a restricted-import authorisation. The requirement depends on the applicable ITC HS import policy and product-specific conditions.
ANF-2M is the application framework used for import authorisation of restricted items. The current process is electronic through the DGFT portal.
DGFT’s restricted-import FAQ states that multiple products may be included, provided the items being applied for are restricted items.
DGFT’s FAQ states that restricted-import authorisations are non-transferable.
The normal validity under the current HBP is 18 months unless otherwise specified.
A universal government processing time should not be promised. HBP 2023 states that the EFC normally meets monthly, but the actual time depends on application completeness, technical comments, product conditions and queries.
No. Under the presently published Appendix 2K, the restricted import application fee is linked to the relevant CIF/duty-saved value, subject to the specified ₹500 minimum and ₹1 lakh maximum.
If your overseas supplier is ready to dispatch but you are uncertain about the ITC HS code, restricted-import requirement, ANF-2M documents or connected regulatory approvals, complete the compliance review before the shipment moves.
Green Permits can assist with classification review, document-gap assessment, DGFT application preparation, query handling and connected import compliance.
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