The short answer. An Export Obligation Discharge Certificate (EODC) is the closure document the DGFT issues when it accepts that you have completed the export obligation attached to your EPCG authorisation. Without it your authorisation stays open, your customs bond stays live and the duty you saved on your machinery remains legally recoverable from you with interest. The automatic extension granted by DGFT Public Notice No. 51/2025-26 dated 6 March 2026 ran out on 31 August 2026.
The rule that decides everything: the export obligation is not one obligation. It is two running at the same time, and completing only the bigger one still fails your closure.
Key facts about EPCG closure and the EODC
| Scheme name | Export Promotion Capital Goods (EPCG) Scheme |
| Governing body | Directorate General of Foreign Trade (DGFT), Ministry of Commerce and Industry |
| Parent policy | Foreign Trade Policy 2023, Chapter 5, read with Handbook of Procedures 2023, Chapter 5 |
| Closure document | Export Obligation Discharge Certificate (EODC), also called redemption |
| Who it is for | Manufacturer exporters, merchant exporters tied to a supporting manufacturer, and service providers holding an Importer Exporter Code (IEC) |
| What you get at import | Zero basic customs duty on eligible capital goods |
| What you owe | Specific export obligation of 6 times the duty saved within 6 years, plus average export obligation maintained every year |
| Latest relief | Automatic extension to 31 August 2026 under Public Notice No. 51/2025-26 dated 6 March 2026, for obligations expiring between 1 March 2026 and 31 May 2026 |
| Where you apply | DGFT portal at dgft.gov.in, form ANF 5B, filed with the Regional Authority that issued the authorisation |
Verified as on 7 September 2026.
Why we are writing this now
On 6 March 2026 the DGFT issued Public Notice No. 51/2025-26. It gave an automatic extension of the export obligation period, and of the block wise fulfilment period, up to 31 August 2026 for every Advance Authorisation and EPCG authorisation whose obligation was expiring between 1 March 2026 and 31 May 2026. The Press Information Bureau confirmed the same day that the extension needed no application, no amendment and no composition fee.
That date has now passed. Every exporter who was carried by that extension is in one of two positions today. Either the obligation was completed and the EODC is pending, or it was not completed and the authorisation is now in default.
Fact checked against DGFT Public Notice No. 51/2025-26 dated 6 March 2026 and DGFT Trade Notice No. 34/2026-27 dated 1 April 2026. Last regulatory review: September 2026.
Rasp International has worked on capital goods licensing, installation compliance and closure filings for Indian exporters since 2005. Most of the EPCG files that reach us are not failures of exporting. They are failures of paperwork on shipments that already happened.
What an EODC actually is
An Export Obligation Discharge Certificate is a document that closes an EPCG authorisation. The Regional Authority of the DGFT issues it after checking that both parts of your export obligation were met inside the allowed period.
Until the EODC is issued, three things remain true. Your bond and bank guarantee with Customs stay live. The duty saved on your imported machinery stays recoverable under Section 28 of the Customs Act 1962. Your authorisation continues to show as open on the DGFT portal, which affects fresh applications.
Getting the EODC is not an administrative formality at the end. It is the point of the whole exercise.
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The two obligations that run at the same time
This is where most closures fail, so read it slowly.
The specific export obligation. Under Chapter 5 of the Foreign Trade Policy 2023, an EPCG authorisation carries an export obligation equal to 6 times the duties, taxes and cess saved on the capital goods. It must be met within 6 years counted from the date the authorisation was issued. For a direct import, the duty saved is the actual amount. For capital goods sourced from an Indian manufacturer, it is the notional customs duty on the FOR value.
The average export obligation. Separately, you must maintain the average of your export turnover in the same and similar products across the three financial years before the authorisation was issued. You must hold that average every single year until the specific obligation is finished. This is not a target you grow into. It is a floor you must not drop below.
A company that exports far more than 6 times the duty saved, but lets its yearly turnover fall below its own historic average in one financial year, has failed the average obligation. The extra exports do not cover the shortfall. They are different tests.
How the six year period is split into blocks
The 6 year export obligation period is divided into two blocks.
| Block | Period | Minimum specific export obligation |
| First block | Years 1 to 4 from date of issue | At least 50 percent of the total specific obligation |
| Second block | Years 5 and 6 | The remaining balance |
You are required to inform the Regional Authority when a block is completed. If the first block target is missed, an extension of that block can be applied for, with a composition fee. The DGFT FAQ document on the EPCG scheme states plainly that there is no extension available for the second block. That single line catches people out every year.
What happens when the obligation is not met
The consequence is not a fine. It is repayment.
Where the export obligation is not fulfilled, the authorisation holder must pay back the customs duty that was saved, in proportion to the shortfall, together with interest. Recovery is available to the department under Section 28 and Section 142 of the Customs Act 1962. Action can also follow under the Foreign Trade (Development and Regulation) Act 1992.
The practical damage is usually larger than the duty figure. An open default sits against your IEC and it complicates every fresh authorisation you apply for afterwards.
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Where EPCG closures actually fail
These are the failure points we see repeatedly. None of them are about whether the goods left India.
The shipping bill did not name the authorisation. This is the one that cannot be undone easily. An export counts towards your EPCG obligation only if the shipping bill was filed under the EPCG scheme with the correct authorisation number recorded on it. Exports made on a plain shipping bill, with no reference to the authorisation, do not automatically count. The goods went out, the payment came in, and the obligation still shows as unfulfilled. Fixing it after the fact means an amendment request with Customs, and it is not guaranteed.
The average obligation was never tracked. Most exporters track the 6 times figure because it is the headline number. Very few maintain a year by year record of the average. The shortfall is discovered at closure, years after the year it happened, when nothing can be done about it.
The installation certificate was never filed. The certificate confirming that the capital goods were installed at the declared premises has to reach the Regional Authority. It can come from the jurisdictional Customs authority or from an independent Chartered Engineer. Machines that have been running productively for years still fail closure because nobody filed the certificate.
Payment realisation could not be evidenced. Exports count on realisation. If the electronic Bank Realisation Certificate (e-BRC), which is the electronic record proving your export payment came in, does not tie cleanly to the shipping bills you are claiming, the Regional Authority will not accept those shipments.
Capital goods were moved without intimation. The authorisation ties the machinery to a declared address. Shifting it to another unit is permitted within the units listed on your IEC and Registration cum Membership Certificate (RCMC), but it requires a fresh installation certificate filed with the Regional Authority. Quiet moves surface during closure verification.
A conflict in the rules you should know about
The installation certificate timeline is an area where published guidance does not agree with itself.
The long standing position under the Handbook of Procedures was that the installation certificate had to be submitted within six months of completion of imports. Public Notice No. 15/2024-25 dated 25 July 2024 introduced a considerably longer window, widely reported as three years from the date of completion of imports for both capital goods and spares, extendable further within the export obligation period. Commentary published after that notice noted that it did not clearly state how it applies to authorisations issued under older policy periods.
What this means for you in practice. Do not rely on a summary you read anywhere, including this one, for your own authorisation. Check the condition printed on your authorisation itself and confirm the current position with your Regional Authority before you assume you have three years.
The closure filing, step by step
Closure is applied for online at dgft.gov.in using form ANF 5B, filed with the Regional Authority that issued the authorisation. Before you file, assemble the following.
- A copy of the EPCG authorisation and any amendment sheets issued against it
- Bills of entry for every capital goods import made under the authorisation
- The installation certificate, from Customs or a Chartered Engineer
- A shipping bill wise statement of exports claimed, each one showing the EPCG scheme and the authorisation number
- e-BRC records matching those shipping bills
- A Chartered Accountant certified statement of export performance covering both the specific obligation and the average obligation, year by year
- Proof of the average export turnover for the three financial years before the authorisation was issued
- Evidence of any composition fee paid for a block extension or an export obligation period extension
The Regional Authority verifies the file, raises deficiencies if any, and issues the EODC on satisfaction. Where a shortfall exists, the file moves to regularisation instead, which means paying proportionate duty and interest before closure.
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Relief measures currently in play
Two DGFT measures from 2026 matter here.
Public Notice No. 51/2025-26 dated 6 March 2026. Automatic extension of the export obligation period, and of block wise fulfilment periods, to 31 August 2026, for Advance Authorisations and EPCG authorisations whose period was expiring between 1 March 2026 and 31 May 2026. No application, no amendment, no composition fee. The DGFT also clarified that composition fees already paid for an extension would not be refunded.
Trade Notice No. 34/2026-27 dated 1 April 2026. Extension of a special disposal drive for expedited issuance of EODCs under the Advance Authorisation and EPCG schemes, running from 1 April 2026 to 31 May 2026, following an earlier drive during March 2026.
Both of those windows have closed. If your obligation was carried to 31 August 2026 and you have not filed, the position now is ordinary procedure, not relief.
The early fulfilment route most exporters never use
There is a benefit in the policy for finishing early, and it is underused.
Where an authorisation holder has fulfilled 75 percent or more of the specific export obligation and 100 percent of the average export obligation to date, in half or less than half of the original export obligation period, the remaining specific export obligation is condoned and the authorisation is redeemed. In plain terms, a strong exporter who front loads performance in the first three years can close a six year authorisation early and stop carrying the bond.
Separately, exporters of notified green technology products get a 25 percent reduction in the specific export obligation.
This week checklist
- Open your EPCG authorisation on the DGFT portal and write down the date of issue and the export obligation end date as the system currently shows it.
- Pull a shipping bill wise export list and check that each shipment you intend to claim actually carries the EPCG scheme code and the authorisation number.
- Calculate your average export obligation year by year and find the first year, if any, where turnover fell below it.
- Confirm whether the installation certificate for every imported machine was filed with your Regional Authority, and get written acknowledgement if you cannot find it.
Rasp International handles RoDTEP claims and rate verification.
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Frequently asked questions on EPCG closure and EODC
What is an EODC under the EPCG scheme?
An Export Obligation Discharge Certificate (EODC) is the document issued by the Regional Authority of the DGFT confirming that the export obligation attached to an EPCG authorisation has been fulfilled. It closes the authorisation and releases the bond executed with Customs.
What happened to EPCG export obligation deadlines on 31 August 2026?
31 August 2026 was the end of the automatic extension granted by DGFT Public Notice No. 51/2025-26 dated 6 March 2026. That notice extended export obligation periods and block wise fulfilment periods that were expiring between 1 March 2026 and 31 May 2026. No further blanket extension had been notified as on 7 September 2026.
Who was covered by the automatic extension under Public Notice 51/2025-26?
Holders of Advance Authorisations, including Advance Authorisation for Annual Requirement and Special Advance Authorisation, and holders of EPCG authorisations, where the export obligation period or block wise fulfilment period was expiring between 1 March 2026 and 31 May 2026. The extension applied automatically with no application and no composition fee.
What is the difference between specific export obligation and average export obligation?
The specific export obligation is 6 times the duty saved, to be completed within 6 years. The average export obligation is your export turnover in the same and similar products averaged over the three financial years before the authorisation was issued, which you must maintain in every year until the specific obligation is complete. Both must be met. Exceeding one does not cover a shortfall in the other.
How is the specific export obligation calculated?
It is 6 times the duties, taxes and cess saved on the capital goods imported under the authorisation. For direct imports it is based on the actual duty saved. For capital goods sourced from a domestic manufacturer it is based on the notional customs duty on the FOR value.
What are the two blocks in an EPCG export obligation period?
The first block is years 1 to 4 from the date the authorisation was issued, in which at least 50 percent of the specific export obligation must be completed. The second block is years 5 and 6, in which the remaining balance must be completed.
What happens if the first block export obligation is not met?
An extension of the first block period can be applied for with the Regional Authority on payment of a composition fee. The fee structure was revised by Public Notice No. 15/2024-25 dated 25 July 2024, so confirm the current slab applicable to your duty saved value before you file.
Can the second block period be extended?
The DGFT frequently asked questions document on the EPCG scheme states that a block wise extension is available for the first block only and that you cannot apply for an extension of the second block. Extension of the overall export obligation period is a separate application with its own composition fee.
What documents are needed to file an EODC application?
The authorisation and amendment sheets, bills of entry for all imports, the installation certificate, a shipping bill wise export statement showing the EPCG scheme and authorisation number, matching e-BRC records, a Chartered Accountant certified export performance statement covering both obligations, proof of the three year average export turnover, and evidence of any composition fee paid.
How long does an EODC take to be issued?
There is no single guaranteed timeline, because it depends on whether the Regional Authority raises deficiencies on your file. DGFT ran special disposal drives during March 2026 and again from 1 April 2026 to 31 May 2026 under Trade Notice No. 34/2026-27 specifically to clear pending EODC cases faster, which indicates that ordinary processing had been running slow.
What happens if the export obligation is not fulfilled at all?
The authorisation holder must repay the customs duty saved, in proportion to the unfulfilled obligation, together with interest. Recovery powers sit under Section 28 and Section 142 of the Customs Act 1962, and further action is possible under the Foreign Trade (Development and Regulation) Act 1992.
Can the export obligation be reduced for green technology products?
Yes. A reduction of 25 percent in the specific export obligation is available for exports of notified green technology products under the EPCG provisions of the Foreign Trade Policy 2023.
What is the early fulfilment benefit under the EPCG scheme?
Where 75 percent or more of the specific export obligation and 100 percent of the average export obligation have been fulfilled in half or less than half of the original export obligation period, the remaining specific export obligation is condoned and the authorisation is redeemed.
When must the installation certificate be submitted?
The certificate must be filed with the Regional Authority, from either the jurisdictional Customs authority or an independent Chartered Engineer. The timeline is an area where published guidance conflicts. The older Handbook of Procedures position was six months from completion of imports, while Public Notice No. 15/2024-25 dated 25 July 2024 introduced a longer window. Check the condition printed on your own authorisation and confirm with your Regional Authority.
Can EPCG exports be counted if the shipping bill does not mention the authorisation number?
Not automatically. An export counts towards the EPCG obligation when the shipping bill was filed under the EPCG scheme carrying the correct authorisation number. Shipments filed without that reference typically require an amendment with Customs before the Regional Authority will accept them, and the amendment is not guaranteed.
About Rasp International
Rasp International is an ISO 9001:2015 certified EXIM and DGFT advisory firm based at A-39, New Agra, Agra, Uttar Pradesh 282005, with a family legacy in international trade since 2005. We have served more than 500 Indian exporters across DGFT licensing, export incentives, customs compliance and buyer development.
If you are holding an EPCG authorisation that was carried to 31 August 2026, or one where the average obligation was never tracked, send us the authorisation number and the date of issue. We will tell you where the file actually stands before you file anything. Message us on WhatsApp or read more about our EPCG advisory and closure support.
Sources
- DGFT Public Notice No. 51/2025-26 dated 6 March 2026, extension in the export obligation period for Advance Authorisations and EPCG Authorisations. Press Information Bureau release
- DGFT Trade Notice No. 34/2026-27 dated 1 April 2026, extension of the special drive for expedited issuance of EODCs under Advance Authorisation and EPCG schemes
- Foreign Trade Policy 2023, Chapter 5, Export Promotion Capital Goods Scheme
- Handbook of Procedures 2023, Chapter 5
- DGFT Frequently Asked Questions, Export Promotion Capital Goods (EPCG) v1.0
- DGFT Public Notice No. 15/2024-25 dated 25 July 2024, revised provisions on installation certificate submission and composition fee slabs
- Customs Act 1962, Section 28 and Section 142. Foreign Trade (Development and Regulation) Act 1992
Rasp International handles RoDTEP claims and rate verification.
Talk to our team for a free assessment. 20+ years of Bharat EXIM expertise.
Disclaimer and related reading
This page is general guidance, not advice on your specific authorisation. Rules, fees and timelines change. Verify the current position against the notification in force and against the conditions printed on your own authorisation before you act.
Related reading on this site:
- How to claim EPCG in 2026, a step by step guide
- Advance Authorisation scheme for duty free import of inputs
- Duty drawback for Indian exporters
- RoDTEP rates in 2026
- DGFT licensing for restricted items
- Export incentives advisory
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