India’s trade in goods is not simply free to flow. The Directorate General of Foreign Trade (DGFT) controls who may import and export, which goods need authorisation, and – at the sensitive end – which dual-use and strategic items may leave the country at all. For a business trading along the India–UAE corridor, the DGFT and export-control regime sits alongside customs as a second gate that goods must pass.
ATB Legal advises importers, exporters, manufacturers and technology businesses on the DGFT framework and on India’s export controls – obtaining the Importer-Exporter Code, securing import authorisations for restricted goods, and managing SCOMET classification, authorisation and end-use compliance, including the emerging-technology controls introduced in 2025.
1. The DGFT Regime & the Foreign Trade Policy
The DGFT, under the Ministry of Commerce and Industry, administers India’s Foreign Trade Policy and the machinery around it – the registration of traders, the licensing of restricted imports and exports, the export-promotion schemes, and the export-control list. Its decisions sit on top of, and interact with, customs clearance.
ATB Legal advises on how the DGFT regime applies to a particular business and trade flow, and on the registrations, authorisations and compliance steps it requires.
2. The Importer-Exporter Code (IEC)
Almost every importer and exporter in India needs an Importer-Exporter Code – a PAN-linked registration issued by the DGFT, without which goods generally cannot be cleared. It is the foundational registration for cross-border trade.
ATB Legal advises on obtaining and maintaining the IEC and on the related registrations a trading business needs to operate compliantly.
3. Import Licensing & Restricted Goods
Under the ITC(HS) import schedule, goods are classified as Free, Restricted, Prohibited, or importable only through State Trading Enterprises. Freely importable goods need no DGFT licence; restricted goods require a DGFT import authorisation, granted on conditions; and prohibited goods cannot be imported at all.
Knowing which category a product falls into – and securing the authorisation where one is needed – is essential before goods are shipped. ATB Legal advises on the import-policy status of goods and on obtaining the necessary authorisations.
4. SCOMET – India’s Export-Control List
At the sensitive end of trade sits SCOMET – Special Chemicals, Organisms, Materials, Equipment and Technologies – India’s control list for dual-use and munitions items, set out in Appendix 3 to Schedule 2 of the ITC(HS). Items on the list cannot be exported without a SCOMET authorisation, and the controls extend to technology and software, not only physical goods.
The first question for any exporter of technical or sensitive goods is classification: whether a product, technology or piece of software falls within a SCOMET category. ATB Legal advises on SCOMET classification and on the authorisation and compliance that follow.
5. The 2025 Category 7 – Emerging Technologies
India expanded SCOMET in 2025 with a new Category 7 covering certain emerging technologies – introduced by a DGFT notification in September 2025 and in force from late October 2025. It brings items such as advanced semiconductors, quantum-computing technologies, cryogenic systems and certain additive-manufacturing equipment within the export-control net, aligning India with international non-proliferation and export-control regimes.
For technology businesses and advanced manufacturers, this is a material change: products and know-how that were previously outside the regime may now require authorisation to export or share across borders. ATB Legal advises on whether the new category captures a given product or technology and on the compliance it requires.
6. SCOMET Authorisation, End-Use & End-User Controls
Exporting a SCOMET item requires an authorisation from the DGFT, and the regime looks beyond the item to its destination and use. End-use and end-user undertakings, and in some cases end-user certificates, are part of the process, and the exporter carries responsibility for knowing its customer and the intended use.
ATB Legal advises on the SCOMET authorisation process, on the end-use and end-user documentation, and on building the internal checks – classification, screening and recordkeeping – that a controlled-goods exporter needs.
7. Enforcement & Penalties
Breaching the import-licensing or export-control regime carries consequences under the Foreign Trade (Development and Regulation) Act and related laws – from denial of trading privileges and penalties to, in serious export-control cases, prosecution. Enforcement attention on dual-use and emerging-technology exports has increased.
ATB Legal advises on potential and actual breaches, on voluntary disclosure where appropriate, and on responding to DGFT action – and coordinates with the UAE export-control side (see our UAE Sanctions and Export Controls page) for corridor businesses handling controlled goods on both sides.
8. Our Process
A typical engagement runs in four steps: a review of the business and its goods to map the DGFT and export-control position; the registrations and authorisations needed – IEC, import authorisations, SCOMET classification and authorisation; the end-use, screening and recordkeeping controls; and representation if a breach or enforcement issue arises. Corridor matters are coordinated with our UAE export-control advice. Remote handling is available throughout.
Frequently asked questions
What is the DGFT, and what does it do?
The Directorate General of Foreign Trade, under the Ministry of Commerce and Industry, administers India’s Foreign Trade Policy – registering traders, licensing restricted imports and exports, running export-promotion schemes, and maintaining the SCOMET export-control list. Its decisions sit alongside customs clearance, and we advise on both.
What is an Importer-Exporter Code (IEC)?
A PAN-linked registration issued by the DGFT that almost every Indian importer and exporter needs; without it, goods generally cannot be cleared. We advise on obtaining and maintaining it and the related registrations.
Do restricted goods need a DGFT import licence?
Yes – under the ITC(HS) schedule, restricted goods require a DGFT import authorisation, granted on conditions, while freely importable goods need none and prohibited goods cannot be imported. We advise on a product’s import-policy status and on obtaining authorisations.
What is SCOMET?
India’s export-control list – Special Chemicals, Organisms, Materials, Equipment and Technologies – covering dual-use and munitions items in Appendix 3 to Schedule 2 of the ITC(HS). Listed items, including related technology and software, cannot be exported without a SCOMET authorisation.
What is the 2025 SCOMET Category 7 for emerging technologies?
India added a new Category 7 for certain emerging technologies – introduced in September 2025 and in force from late October 2025 – covering items such as advanced semiconductors, quantum-computing technologies, cryogenics and certain additive-manufacturing equipment. We advise on whether it captures a given product or technology.
Do I need a SCOMET authorisation to export controlled items from India?
If the item, technology or software is on the SCOMET list, yes – a DGFT authorisation is required before export, and the regime considers the destination and end-use as well as the item. We advise on classification and on the authorisation.
What are end-use and end-user controls under SCOMET?
Part of the SCOMET process: documentation about who will receive a controlled item and how it will be used, with end-use and end-user undertakings and, in some cases, an end-user certificate. The exporter is responsible for knowing its customer and the intended use, and we advise on the documentation and checks.
What are the penalties for breaching India’s export controls?
Breaches of the import-licensing or export-control regime carry consequences under the Foreign Trade (Development and Regulation) Act and related laws, from denial of trading privileges and penalties to prosecution in serious cases. We advise on potential and actual breaches and on voluntary disclosure where appropriate.
How do India’s SCOMET controls interact with the UAE’s export-control regime?
A corridor business may face controls on both sides – SCOMET in India and the UAE’s dual-use regime under the EOCN. We coordinate the two so controlled goods are handled consistently (see our UAE Sanctions and Export Controls page).
Can you coordinate India SCOMET with the UAE export-control side?
Yes – with offices in both, we handle India’s DGFT and SCOMET requirements and coordinate the UAE export-control side in one relationship, which corridor trade in controlled or technical goods often requires.
⭐ Representative Experience (anonymised)
A technology exporter was advised on whether its product fell within the new SCOMET emerging-technology category and on the authorisation and end-use compliance that followed.
An importer of restricted goods was advised on the DGFT import-authorisation route and the conditions attached, before committing to the shipment.
A manufacturer handling dual-use items across the corridor was advised on SCOMET classification and screening and on coordinating with the UAE export-control regime.
🏆 How we work
- Both gates – DGFT licensing and SCOMET export controls alongside customs, so a consignment clears every requirement, not just one.
- Current on emerging-tech controls – the 2025 SCOMET Category 7 and what it means for advanced products and know-how.
- Classification-first – the SCOMET and import-policy classification that determines the whole compliance path.
- Compliance-programme capable – end-use, screening and recordkeeping built for controlled-goods exporters.
- Corridor coverage – India SCOMET coordinated with the UAE’s EOCN regime in one relationship.