TRACE Scheme 2026 for Shipyards: IRS Certification Is Eligible, but the Intent to Claim Form Will Not Let You Select It

Short answer

IRS (Indian Register of Shipping) ship classification is eligible for TRACE reimbursement, but no exporter can select it on the TRACE Intent to Claim form today. IRS is Sl. No. 243 of Annexure I to DGFT Trade Notice No. 09/2026-27 dated 01.07.2026. Annexure I tags it to the country “India”. The form shows a certificate only when its country is chosen as the Country of Export, and India is not an export country.

This matters because the Intent to Claim must be filed before the certificate is issued (para 3(b), Annexure II, Trade Notice No. 26/2025-26). Each day the form stays closed, a class certificate can arrive and that vessel’s claim is gone.

Who this is for: MSME shipyards, boat builders, marine equipment makers and any exporter whose certificate sits under “India” in Annexure I (BIS, IBR, ARAI, WPC, MTCTE, DCG and others).

Who this is not for: exporters whose certificate is listed under a foreign country or under “International”. Your form should work normally.

Last verified on 25 October 2026 against Trade Notice No. 26/2025-26, Trade Notice No. 09/2026-27, the DGFT TRACE FAQ Manual and the Trade Connect User Guide for the Intent Claim Form (v1.1).

What TRACE pays a shipyard: the rules that decide the claim

For a shipyard, eligibility is settled by Annexure I. Timing and the yearly cap are the real limits. TRACE (Trade Regulations, Accreditation and Compliance Enablement) was launched by DGFT on 20 February 2026 and amended on 1 July 2026.

What 95% means on one vessel (illustration only). Say IRS bills Rs 10 lakh net of GST for one vessel. A Small enterprise can claim up to Rs 9.5 lakh: Rs 4.75 lakh at RC-1 and Rs 4.75 lakh at RC-2. Annexure I prints no ceiling amount against any entry, so the 95% is worked on the actual bill.

One line in this table controls everything else: Intent comes first.

Is IRS classification eligible for TRACE?

Yes. IRS classification is entry 243 of the 462 entries in Annexure I to Trade Notice No. 09/2026-27. That notice replaced the earlier Positive List and Priority Positive List with one list, set out in four columns. Entry 243 reads:

Source: page 20 of Trade Notice No. 09/2026-27 dated 01.07.2026, issued from File No. 01/02/33/AM-26/EPM.

What a class certificate is. It is the approval a classification society gives after it checks a vessel’s design plans, its construction and its sea trials against the society’s rules. IRS (IRClass) is India’s classification society and a member of IACS (International Association of Classification Societies). For a vessel built for a buyer abroad, class is usually a condition of the sale contract, the flag registration and the insurance.

That fits what TRACE pays for. Para 3 of Trade Notice No. 26/2025-26 covers conformity assessment “mandated vide regulations required for market access, or necessary to demonstrate compliance with internationally recognised standards”.

Three checks decide whether a shipyard’s IRS cost qualifies:

1. Name match. The certificate must be the one named in entry 243, IRS classification.
2. Product match. The exported product must fall within “Ship-Related Products”. FAQ Manual Q14 says the export country and the product must match the details against the entry.
3. Date match. The work must be done on or after 20 February 2026, and the certificate must be issued after the Intent to Claim is filed.

Not just ships: all 12 India entries in Annexure I

Twelve of the 462 entries in Annexure I carry “India” as their Country / Geography. If the Intent form filters every entry the same way, none of these 12 can be selected for any export market. We have tested only IRS on the live form, so treat the other 11 as at risk until you try them yourself.

Source: Annexure I, Trade Notice No. 09/2026-27 dated 01.07.2026. Names are quoted as printed.

Marine and ship certifications in Annexure I: what a shipyard can claim

A shipyard has more than IRS on the list. Annexure I also carries foreign class societies, marine type approvals and welding standards. Entries tagged “International” should appear for every export country, so a shipyard can file Intents for those today.

Source: Annexure I, Trade Notice No. 09/2026-27. The last column is our reading of how the form filtered on 23 October 2026, not a DGFT statement. Names are quoted as printed.

What this means for a shipyard. Classed by DNV, LR, ABS, BV, ClassNK or RINA and selling to a country other than the society’s own? The same filter may hide your certificate too. Welding and quality certificates tagged “International” (WPS, ISO 3834, ISO 9001) are the safest TRACE claims a yard can file right now.

The case: a Small MSME shipyard, three vessels and one certificate

A Small MSME shipyard asked us one question: can we get our IRS class fees back under TRACE? It builds commercial vessels for owners abroad. The vessels fall in Chapter 89 of ITC(HS) (ships, boats and floating structures) and leave India on a shipping bill. Each one is a physical export, not a deemed export.

Every vessel needs an IRS class certificate before delivery. On a single vessel the class fee runs into many lakhs of rupees. Our first answer was yes, because IRS is on the eligible list. What came next is the reason for this post.

Before touching the portal, we checked that the yard could claim at all. Then we checked the cost and status of each vessel.

Proof of payment comes at RC-1. The shipping bill and e-BRC come at RC-2 (FAQ Manual Q8). The sixth row of this table changed the case.

The deadline nobody announces: your certificate date

TRACE has no calendar last date for the Intent to Claim. Your own certificate sets it. Para 3(b) of Annexure II to Trade Notice No. 26/2025-26 says the exporter “shall file an online Intent-to-Claim prior to obtaining certifications, test reports, and compliance documents”. The day the certificate is issued, the door for that certificate closes.

Before the work or before the certificate? The guideline’s words are “prior to obtaining”. Some councils read it more strictly: AEPC Circular No. 252 dated 28.07.2026 tells members to file “before initiating the certification/testing/audit process”. The safe order is to file before any work starts. If the work has already started, file before the certificate is issued, and do it now.

In our case: by the time the papers reached the filing stage, IRS had already issued the class certificate for one of the three vessels. That vessel can no longer be claimed under TRACE. The other two had no certificate yet, but their builds were close to finishing, so either certificate could be issued any day.

What the Trade Connect form showed us on 23 October 2026

The Certification Name list is filtered by Country of Export, and that filter hides every “India” entry. We opened the TRACE Intent to Claim form with the exporter’s login (My Dashboard, then Trade Regulations, Accreditation & Compliance Enablement (TRACE), then Apply for Intent). This is what we saw, field by field.

1. Exporter’s Basic Details. Auto-filled from the IEC and locked, as the user guide says.
2. Sector. We picked the sector for the vessels.
3. Country of Export. We picked the real buyer countries.
4. Certification Name. The list did not show all 462 entries. It showed only entries tagged to the chosen export country, plus the “International” ones.
5. IRS was missing. Annexure I tags IRS to “India”, so the form would show it only if India were the Country of Export.
6. India is not in Country of Export. You cannot export from India to India, so IRS never appears.
7. No “Others” option on the live form. The Trade Connect User Guide for the Intent Claim Form (v1.1), page 10, says: “If your certificate is not available in the list, select ‘Others’ and manually enter the certificate name in the field provided.” We could not find that choice. Even where it appears, the guidelines do not say whether an “Others” entry is paid like a listed certificate.
8. No draft without a certificate. The form would not save a draft until a Certification Name was chosen.

Result: an eligible certificate, a valid IEC, a live deadline and no way to file.

One more gap: the user guide is dated January 2026 on its cover, while its revision table shows version 2.0 dated 15 November 2025. Both dates come before TRACE launched on 20 February 2026 and before the two-stage claim of 1 July 2026, so the guide may not match the live form.

We did not try to force a value into the form. The Intent is signed with a DSC (Digital Signature Certificate) or Aadhaar e-sign (User Guide v1.1, pages 5 and 12) under a declaration (Annexure IV, Trade Notice No. 26/2025-26). Editing the page code to inject “India” or another certificate would put that signed declaration on data the system never offered. A claim filed under the wrong certificate name is worse than a claim not filed.

Portal bug or DGFT rule? How to read “India” in Annexure I

Our reading: for the 12 India entries, “India” names where the certifying body sits, not the export market. It is easy to call the form a bug, so here is the other reading first.

The DGFT TRACE FAQ Manual, Q14, says: “Eligibility is limited to specific certification/test name appearing in Annexure-I of Trade Notice No. 09/2026-27 dated 01.07.2026 as on the date of application provided the export country and the exported product matches with that the details specified against that entry.” Para 2 of Trade Notice No. 26/2025-26 also speaks of “importing-country regulatory requirements”. Read strictly, IRS could be claimed only on exports to India, and the form would be correct.

Four things in the same documents point the other way:

1. Nobody exports to India from India. If “India” meant the market, 12 of 462 entries could never be used by anyone.
2. The SEZ route is closed too. Supplies to SEZ units and deemed exports are excluded (para 2(e), Annexure II; FAQ Manual Q6), so no Indian sale can stand in for an export.
3. The form keeps the two apart. Annexure IV to Trade Notice No. 26/2025-26 lists Certification Name and Country of Export as separate fields in Part B. Part C even asks: “Are accredited labs in India adequate for your product certification?”
4. Class societies are tagged by home country. ABS is tagged “USA”, DNV “Norway”, LR “UK”. Shipyards use these classes for buyers everywhere, not just in those three countries. The column records the body’s home.

That is our view, not a DGFT ruling. We have asked DGFT to confirm it in writing. Para 3 of the same notice also covers standards needed “to demonstrate compliance with internationally recognised standards”, which fits class work for a foreign buyer.

What we did, in order, to protect the claim

When the deadline is a certificate that can arrive any day, the only protection is a dated record that you tried to file in time. The FAQ Manual itself calls Intent form errors “a recurring, commonly reported technical issue” (Q18) and gives the route.

1. Told the exporter first. IRS is eligible, the form does not let anyone select it, and we will raise it with DGFT. We promised no fix date, because we do not control the portal.
2. Took the exporter’s go-ahead. No ticket and no email went out in their name before they agreed.
3. Raised a Service Request on the Trade Connect portal on 23 October 2026. This is the route FAQ Manual Q18 gives for Intent form errors.
4. Emailed DGFT the same day at trace.epm-dgft@gov.in, tradeconnect-dgft@gov.in and epm-dgft@gov.in, the three addresses in Q18. Q22 says trace.epm-dgft@gov.in must always be on the mail. We quoted the IEC, the Service Request number, the draft number and the Annexure I entry, with screenshots.
5. Asked for four things in writing: make the India entries selectable, treat the Service Request date as the Intent date, give a timeline, and confirm what “India” means in entry 243. The second ask follows FAQ Manual Q21, which tells exporters facing a portal failure near a deadline to request “deadline relaxation/condonation given the system unavailability”.
6. Asked the exporter to tell us the same day IRS gives any date for the two open certificates.
7. Saved the proof in one folder: the ticket screenshot with number and time, the sent email and every screenshot. If the claim is ever questioned, this is the evidence.

Certificate not showing on the TRACE Intent form? Do this today

Do not wait for the portal. Build your dated record the same day.

• Find your entry in Annexure I to Trade Notice No. 09/2026-27. Note the Sl. No., Country / Geography, name and coverage exactly as printed.
• Confirm your certificate is not issued yet. If it is, that certificate is lost; plan the next one.
• Ask your certifying body in writing for the expected certificate date, so you know how much time you have.
• Retry the form once in a private window and once in another browser (FAQ Manual Q18). Screenshot the Country of Export list and the Certification Name list with the date and time visible.
• Raise a Service Request on the Trade Connect portal describing the exact error, with screenshots. Note the number and time.
• The same day, email trace.epm-dgft@gov.in, tradeconnect-dgft@gov.in and epm-dgft@gov.in. Quote your IEC, Service Request number, draft number and Annexure I entry. Mark it urgent, as Q18 allows when a deadline is at risk.
• Ask in writing that the Service Request date be treated as your Intent date (a condonation request, as FAQ Manual Q21 allows).
• Tell your Export Promotion Council. Q22 sets the ladder: FAQ first, then your council, then trace.epm-dgft@gov.in.
• File Intents now for any “International” entries you also need, such as ISO 3834, WPS or ISO 9001. They are not blocked.
• Keep the certifying body’s invoices showing the fee net of GST, the base for the 95%.
• Keep every screenshot, ticket and email in one folder.

Mistakes that can cost the whole claim:

• Picking a different certificate just to get past the form.
• Editing the page code with browser tools to add “India” or a certificate name.
• Waiting for the fix before asking the certifying body for its date.
• Filing the Intent after the certificate is issued.
• Claiming the same cost under another Central or State scheme (para 3(d), Annexure II).
• Treating a supply to an SEZ unit as an export (para 2(e), Annexure II).

Email template: report a missing TRACE certificate to DGFT

Copy this, fill the brackets and send it the same day you raise the Service Request. It carries everything FAQ Manual Q18 to Q22 ask for.

Where it stands on 25 October 2026

We are waiting for DGFT’s reply, and the two open vessels still have no class certificate. If either certificate is issued before the form opens, the exporter’s money depends on DGFT accepting the dated Service Request as the Intent.

No TRACE notice has come after Trade Notice No. 09/2026-27. DGFT’s Trade Notices list, last checked by us on 23 October 2026, runs to Trade Notice No. 31/2026-27 dated 21.10.2026. The later Export Promotion Mission notices (12/2026-27, 13/2026-27, 17/2026-27 and 29/2026-27) deal with branding, interest subvention and trade finance, not TRACE.

We are not blaming anyone. TRACE runs “on a pilot basis for feedback, institutional learning, and data-driven refinements” (para 5, Trade Notice No. 26/2025-26). The FAQ Manual says it “will be periodically updated based on clarifications and queries received from stakeholders”. A gap like this is what a pilot is meant to surface. But the cost of the gap falls on a small shipyard that paid for a certificate the government lists as eligible.

We will update this post when DGFT replies.

Frequently asked questions on TRACE, IRS and the Intent to Claim

Is IRS ship classification eligible under the TRACE scheme?

Yes. IRS (Indian Classification Certification) for Ship-Related Products is Sl. No. 243 of Annexure I to DGFT Trade Notice No. 09/2026-27 dated 01.07.2026.

Why can’t I select IRS on the TRACE Intent to Claim form?

The Certification Name list loads by Country of Export. IRS is listed under India, and India is not an export country on the form. As of 25 October 2026 we found no DGFT notice or FAQ that addresses this.

Which other certificates are listed under India in Annexure I?

Twelve in all: WPC, TRA, STQC, RDSO, IBR, CRS, CPRI, BIS and ARAI (Sl. No. 193 to 201), and MTCTE, IRS and DCG (Sl. No. 242 to 244).

When must the TRACE Intent to Claim be filed?

Before the certificate is obtained, under para 3(b) of Annexure II to Trade Notice No. 26/2025-26. Some councils, such as AEPC, advise filing before the certification work even starts.

Can I claim TRACE if my certificate is already issued?

Not for that certificate. A future certificate can still be claimed if the Intent is filed before it is issued.

How much does TRACE pay a shipyard?

Up to 95% of the cost net of taxes for Micro and Small enterprises and up to 80% for Medium, capped at Rs 50 lakh per IEC per financial year. Half is paid after the certificate and half after the linked export.

Is there an “Others” option on the TRACE Intent form?

The Trade Connect user guide (v1.1, page 10) describes one. We could not find it on the live form on 23 October 2026, and the guidelines do not say whether an “Others” entry is paid like a listed one.

Does a supply to an SEZ or a deemed export count for TRACE?

No. Para 2(e) of Annexure II to Trade Notice No. 26/2025-26 and FAQ Manual Q6 exclude both.

Are DNV, Lloyd’s Register, ABS and Bureau Veritas class eligible under TRACE?

Yes, they are listed at Sl. No. 315, 327, 418 and 323. Each is tagged to its home country (Norway, UK, USA, France), so the form may show it only when that country is the export market.

Can a merchant exporter claim TRACE for ship classification?

Only for tariff lines listed in Annexure VII to Trade Notice No. 26/2025-26 (para 2(d)). Check your six-digit HS code there first. A manufacturer exporter has no such limit.

Who do I contact for a TRACE portal problem?

Raise a Service Request on Trade Connect and email trace.epm-dgft@gov.in, tradeconnect-dgft@gov.in and epm-dgft@gov.in (FAQ Manual Q18). Q22 adds your Export Promotion Council as the step before DGFT.

How long is a TRACE Intent to Claim valid?

Two years. If no reimbursement claim is filed in that time, the Intent lapses and the exporter cannot claim in the next financial year (para 3(e) and 5(a)).

What documents are needed at RC-1 and RC-2?

RC-1: the certificate or test report, the invoice, proof of payment and evidence of the market requirement. RC-2: the shipping bill and e-BRC showing the linked export was paid for (FAQ Manual Q8; Trade Notice No. 09/2026-27, amended para 3(c)).

Can I use browser tools to add India to the Country of Export list?

No. The Intent is signed with a DSC or Aadhaar e-sign under a declaration, and a value the system never offered can sink the claim.

What if my certificate is not in Annexure I at all?

FAQ Manual Q15 allows a representation for inclusion through DGFT’s online form. The Sub-Committee decides whether to add it.

Sources

• DGFT Trade Notice No. 26/2025-26 dated 20.02.2026: launch of TRACE; Annexure II paras 1(a), 1(d), 2(d), 2(e), 2(g), 3(b), 3(d), 3(e), 4(b) and 5(a); Annexure IV form fields
• DGFT Trade Notice No. 09/2026-27 dated 01.07.2026: amended paras 2(b), 2(c), 3(c) and 5(a); Annexure I, 462 entries (India entries on pages 17 and 20)
• DGFT TRACE / EPM Niryat Disha FAQ Manual, via the Trade Connect Export Promotion Mission page: Q6, Q8, Q14, Q15, Q18, Q21 and Q22
• Trade Connect User Guide for the Intent Claim Form, v1.1: pages 3 to 12
• DGFT Trade Notices list, checked on 23 October 2026
• AEPC Circular No. 252 dated 28.07.2026: TRACE application flow
• IRClass (Indian Register of Shipping): IACS membership
• Live check of the TRACE Intent to Claim form by Rasp International, 23 October 2026

Related guides from Rasp International: DGFT TRACE Scheme 2026: the full guide · TRACE application filing guide · Export Promotion Mission: Niryat Protsahan and Niryat Disha

The exporter in this post is not named, to protect their confidentiality.

Filing a TRACE claim, or stuck on the Intent form? Write to info@raspinternational.in or call +91 82180 43048. Send your Annexure I entry and your certificate status, and we will tell you where you stand.