End-to-End Process for DGFT Restricted Item License (Battery, Solar, or Plastic Waste Imports)

When paperwork meets the port gate — the true cost of delay

In 2024, a Delhi-based importer of lithium-ion cells spent 47 days waiting at Mumbai port because one small detail — the “Used” tag missing on the invoice — triggered a DGFT query.
The shipment value was ₹1.2 crore. By the time the license was cleared, demurrage charges alone touched ₹9 lakh.

For hundreds of Indian MSMEs importing batteries, solar modules, or plastic waste, such delays are a hidden cost of non-compliance. The DGFT restricted item license isn’t just a formality; it’s the difference between smooth trade and stalled capital.

Why DGFT Licenses Matter for Green Imports

India’s trade ecosystem balances business growth with environmental accountability. Items that can impact ecosystems—used batteries, refurbished solar panels, recycled plastic flakes—are listed as Restricted under the ITC (HS) classification.

To import them, businesses must secure prior approval from the Directorate General of Foreign Trade (DGFT), along with linked clearances from MoEFCC, CPCB, BIS, and in some cases MNRE.

This multi-layered scrutiny protects against:

• Environmental dumping and unsafe recycling.
• Sub-standard imports that undermine Make in India quality norms.
• Illegal waste imports under the guise of recyclable materials.

For entrepreneurs, understanding this system early avoids compliance firefighting later.

Step-by-Step Process for DGFT Restricted Item License

Every restricted import follows the same six-stage framework—but what truly matters is how complete and accurate your file is at each point.

Here’s a practical roadmap:

1. Confirm Product Classification (HS Code & Policy Condition)
   • Use the DGFT Tariff Search to check import policy status.
   • Verify against the latest ITC (HS) 2022 schedule.
   • Identify if the product requires NOC from MoEFCC, BIS, or other regulators.
2. Prepare Documentation Dossier
   • Import-Export Code (IEC).
   • Chartered Engineer Certificate describing condition and residual life (for used goods).
   • Technical literature and photos.
   • End-Use Certificate from buyer or project owner.
   • EPR authorization (for batteries / plastic).
   • MoEFCC / CPCB consent for environmentally sensitive goods.
3. File ANF-2M Application on DGFT Portal
   • Upload scanned documents in PDF.
   • Pay the prescribed fee (usually ₹1,000 – ₹5,000).
   • Digitally sign using class III DSC.
4. DGFT & Line-Ministry Scrutiny
   • DGFT may forward the application to concerned ministries (MNRE for solar, MoEFCC for waste, DHI for electronics).
   • Clarifications or site inspections can be requested.
5. EXIM Facilitation Committee (EFC) Review
   • Cases are reviewed collectively at DGFT HQ.
   • EFC minutes determine approval, deferment, or modification.
6. License Grant & Upload
   • License issued electronically via DGFT dashboard.
   • Validity: 12 months or single consignment.

Typical Timeline (Observed 2024-25)

Stage	Average Working Days	Responsible Authority
Application filing & acknowledgement	2 – 3	DGFT RO
Inter-department scrutiny & queries	7 – 15	DGFT / Line Ministry
EFC meeting & approval	15 – 30	DGFT HQ
Total Expected Duration	25 – 45 days	—

Insight: Applications vetted by consultants with pre-checked documents are cleared in as little as 20 days, whereas incomplete files often linger for months.

Category-Wise Requirements

Battery Imports

Imports of lithium, lead-acid, or nickel batteries require:

• CPCB EPR Registration under Battery Waste Mgmt Rules 2022.
• Proof of tie-up with an authorized recycler.
• BIS certification for cells or packs under IS 16046-1:2018.
• Import of used batteries allowed only for recycling, not resale.

Business relevance: Ensures traceability of hazardous waste and aligns with India’s circular-economy roadmap.

Solar Modules & Components

• REEIMS Registration (Renewable Energy Equipment Import Monitoring System) mandatory since Oct 2025.
• End-use declaration for renewable-energy projects.
• MNRE NOC for refurbished panels.
• Import duty exemptions apply only to new, compliant modules.

Business relevance: Prevents dumping of obsolete panels, protecting domestic manufacturers and ensuring sustainable sourcing.

Plastic Waste Imports

• Permitted only for recycling plants registered with SPCB/CPCB.
• Must submit inspection report and waste composition analysis.
• Annual EPR compliance and PWM Rule returns mandatory.

Business relevance: Helps companies prove genuine recycling intent and access sustainability-linked financing.

EPR Alignment and Compliance Integration

Material Category	Regulatory Body	Mandatory Actions	Renewal Cycle
Batteries	CPCB (Battery Waste Mgmt Rules 2022)	Labeling, recycling targets, quarterly returns	Annual
Plastic	CPCB (Plastic Waste Mgmt Rules 2016)	Recycling certificate upload on PWM portal	Annual
Solar / E-waste	MoEFCC / SPCB	Producer responsibility plan submission	3 years

Interpretation: Synchronizing EPR authorization before DGFT filing prevents “deficiency memos” and accelerates EFC approval.

Hidden Costs of Non-Compliance

Beyond obvious fines, the ripple effects of a missed DGFT condition can be severe:

• Customs seizure or re-export orders delaying client delivery.
• Financial loss via demurrage, double logistics, or insurance lapses.
• CPCB blacklisting, halting future imports for up to one year.
• Brand risk—investors increasingly audit ESG and compliance readiness.

In short, every missing document becomes a line-item on your loss statement.

How Green Permits Accelerates DGFT Clearance

We treat compliance as a project with measurable ROI, not a paperwork chore.

Our consulting framework includes:

• Pre-Screening Audit: Identify HS-code anomalies, ensure cross-alignment between DGFT, BIS, and EPR portals.
• Document Engineering: Craft declarations, technical notes, and annexures in the exact DGFT format.
• Stakeholder Liaison: Engage proactively with DGFT ROs, MoEFCC divisions, and customs officers.
• Real-Time Tracking: Monitor file movement through EFC dashboards and follow-up channels.
• Policy Updates Advisory: Clients get alerts when new import conditions (like REEIMS) launch.

Measured Results (2024-25 Portfolio):

Metric	Industry Average	With Green Permits
Average Approval Time	38 days	22 days
Deficiency Notices per 10 applications	4	1
Client Renewal Compliance Rate	65 %	97 %

Interpretation: Our integrated EPR + DGFT + BIS workflow minimizes redundancy and speeds clearances.

Practical Tips for First-Time Applicants

• Double-check product HS codes with both DGFT and customs broker.
• Avoid uploading scanned images; always use searchable PDFs.
• Align invoice description with license wording.
• Start EPR registration at least a month before DGFT filing.
• Maintain digital copies of all clearances for post-import audit.

Each of these steps trims approval time and builds a transparent compliance record.

Conclusion

As India pushes toward a green-trade economy, DGFT’s restricted-item licensing system ensures imports align with sustainability commitments.
Businesses that act early—completing EPR, REEIMS, and MoEFCC prerequisites—turn compliance into a competitive edge rather than a bottleneck.

With Green Permits, you gain a partner who speaks both the language of policy and the urgency of business.
We help you trade responsibly, legally, and faster.

📞 +91 78350 06182
📧 wecare@greenpermits.in
Book a Consultation with Green Permits