FAQs on Eligible Manufacturer Importer Scheme

The Central Board of Indirect Taxes and Customs (‘CBIC’) has issued a set of Frequently Asked Questions (FAQs) on the Eligible Manufacturer Importer (EMI) Scheme for Trade & Industry under Customs laws to provide clarity on various operational and eligibility aspects. The key clarifications are summarized below on a section-wise basis:

Section Key Questions Clarifications
Introduction What is the EMI Scheme and its purpose?
  • Facilitates trade for Manufacturer Importers
  • Supports Make in India, improves cash flow, and eases compliance
  • Encourages transition to Authorised Economic Operator (AEO) status
Who can avail and what are the benefits?
  • Available to ‘Eligible Manufacturer Importers’ as approved by the Directorate of International Customs including MSMEs
  • Allows deferred payment of import duty, payable on monthly basis instead of per transaction
What is the validity of EMI Scheme?
  • Scheme valid until 31 March 2028 as a transition period for higher compliance
  • Post 31 March 2028, entities can continue if they obtain AEO Tier 2 certification before the deadline
  • Existing EMI-approved entities can also apply for AEO accreditation
Eligibility Criteria Who can apply under the EMI Scheme?
  • The Applicant must have a valid IEC and who qualifies as Manufacturer under the CGST Act
  • Importer who is not manufacturer but sending goods to job worker having a GSTIN
  • Traders and service providers can apply only if they qualify as Manufacturer Importers
What are the eligibility criteria for businesses?
  • Annual turnover ≥ ₹5 crore in Last Financial Year (‘FY’)
  • New importer also eligible if filed 25 Exim documents (Reduced to 10 for MSME registered on Udyam portal) in previous ‘FY’
  • Start-ups must have operated for at least two FY’s.
  • Insolvent or bankrupt entities are ineligible
What is compliance and documentation requirements?
  • At least one active GST registration with nature of business declared as ‘factory/manufacturing activity’
  • All GSTR-3B must have been filed and complete details of factory & machinery, along with ownership or lease proof to be provided and uploaded as part of application
  • Documents such as Audited financial statements and CA certificates confirming solvency to be submitted
Application Process and Manner of Filing What is the process for applying under the EMI Scheme?
  • Fully online via AEO India portal
  • Email-based OTP/communication; no physical interface or fee
  • Rejected/returned applications must be resubmitted online
What are the key features of approval and post-approval benefits?
  • Valid across all Customs stations
  • No bond or bank guarantee required
  • Enables deferred duty payment via ICEGATE
  • Application status can be tracked online; rejections intimated by email
How does the deferred duty payment mechanism work?
  • Duty (including IGST) payable monthly on a consolidated basis
  • Option to choose deferred or transaction-wise payment
  • No interest if paid on time; early payment allowed
  • Repeated defaults may lead to suspension
What are the key limitations and scope of the scheme?
  • No monetary cap on deferred duty
  • Not applicable to ex-bond clearances for home consumption
  • Does not grant priority customs facilitation
  • Allows consolidation of multiple Bills of Entry across ports
  • Available to AEO Tier 2 & 3 entities and Authorized Public Undertakings
Suspension of Approval Is EMI approval permanent and when can it be suspended?
  • EMI approval is not permanent
  • Suspension occurs if eligibility conditions are violated or false/forged information is provided
  • Status communicated via email and portal
Can a suspended entity re-apply under the EMI Scheme?
  • Re-application allowed if eligibility is restored
  • Permanent disqualification for fraudulent declarations
Are entities with rejected/expired AEO applications eligible, and is any support available?
  • Entities with rejected/expired AEO applications may still apply if they meet criteria
  • Assistance available via dedicated Helpdesk (telephone/email).

Key Takeaway:
The EMI Scheme is a significant trade facilitation measure that improves working capital efficiency for manufacturer importers while encouraging a transition to higher compliance standards under the AEO framework.

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