Dated. October, 2025
Issued By. DGFT
Subject: Advance Authorisation - Export Obligation Discharge Certificate – Clubbing
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Advance Authorisation - Export Obligation Discharge Certificate – Clubbing
Advance Authorisation holders now have more flexibility – and clearer boundaries – when it comes to clubbing licences for Export Obligation Discharge Certificate (EODC) purposes. DGFT has amended para 4.36 of the Handbook of Procedures 2023 through Public Notice No. 40/2023 DGFT dated 12 February 2024, widening the period within which authorisations can be clubbed and, for the first time, putting a firm time limit on which exports can be counted for clubbing.
What exactly has changed in EODC clubbing rules?
Public Notice No. 40/2023 modifies para 4.36 to “ease the clubbing provisions in respect of the Advance Authorisation Scheme”, mainly in three dimensions: the issue window for eligible licences, the treatment of imports, and the treatment of exports. Earlier, only AAs issued within 18 months of the earliest licence could be clubbed, and only imports made within 30 months from that earliest licence were counted, while exports were not explicitly time-boxed in the clubbing clause. The amendment keeps the 30-month import cap but extends the issue window to 24 months and introduces a new 48-month export cap from the date of the earliest AA.
New 24-month issuance window for clubbing
Under the amended para 4.36(vi), only those Advance Authorisations can be clubbed which have been issued within 24 months from the date of issue of the earliest authorisation in the clubbed set, irrespective of whether these AAs are currently valid or expired. This replaces the earlier 18-month rule and makes it easier to combine licences that support longer production or export cycles.
For exporters, this means you can now plan “batches” of AAs over a two-year issuance horizon and still retain the option to club them later for a single EODC, provided other policy conditions are satisfied. Licences that would previously have fallen just outside the 18-month window (and therefore required separate redemption) can now, in many cases, be merged into a combined clubbing strategy.
Import validity for clubbing is still capped at 30 months
On the import side, DGFT has intentionally left the safeguard unchanged. Even after clubbing, only imports made within 30 months from the date of issue of the earliest authorisation will be considered for clubbing; any imports beyond this 30-month limit must be regularised separately under para 4.49 of the HBP. In other words, the earliest AA in the set now drives both the 24-month issuance window and the 30-month import window used for clubbing calculations.
Practically, if you intend to rely on clubbing, you should avoid scheduling major duty-free imports beyond 30 months from the earliest AA you may later club, because those consignments will sit outside clubbing and may attract separate duty and interest regularisation.
New 48-month export window for clubbing
The most significant conceptual change is the introduction of a clear export cut-off. The amended para 4.36 now provides that, upon clubbing, only exports made within 48 months from the date of issue of the earliest authorisation will be considered for clubbing, and any exports beyond this 48-month period will not be acceptable. This provides a definitive, rule-based export obligation horizon for clubbing assessments.
All shipping bills you want to count towards the combined export obligation of the clubbed set must therefore fall within 48 months of the earliest AA in that group. Exports made after that 48-month point cannot be used to plug EO shortfalls for clubbing purposes, so if the combined EO is still not met, you will need to use normal EOP extension and/or duty plus interest routes for regularisation. Commentaries also point out that while you can still seek standard EOP extensions under FTP, for clubbing computations, this 48-month ceiling from the earliest licence is now the default reference unless DGFT specifically relaxes it.
What does the “latest clubbing update” mean day to day
Putting the revised rules together, the current EODC clubbing framework for Advance Authorisation effectively operates as follows:
- Licences that can be clubbed: Only AAs issued within 24 months of the earliest authorisation in the proposed clubbed set, subject to the usual conditions such as the same RA and compatible norms.
- Imports that count after clubbing: Only imports made within 30 months from the earliest AA’s issue date; imports beyond that must be regularised under para 4.49 and are excluded from clubbing.
- Exports that count after clubbing: Only exports made within 48 months from the earliest AA’s issue date; exports beyond that cannot be used for clubbing and will not reduce combined EO shortfall.
- What still remains unchanged: Foundational requirements like the same RA, adherence to minimum value addition, scheme-specific restrictions, and exclusion of some older or special category authorisations continue to apply.
Strategic implications for exporters
These amendments make clubbing more flexible in terms of which licences can be merged, but more structured in terms of which imports and exports count. Exporters should now:
- Intentionally issue related AAs within a 24-month band and with similar norms so they remain clubbable at the EODC stage.
- Maintain an internal tracker keyed to the earliest AA in each potential clubbing set and monitor both the 30-month import and 48-month export cut-offs from that date.
- Aim to front-load a reasonable portion of exports within the 48-month horizon, instead of pushing large EO volumes to the tail end.
- Decide early between pursuing individual EODCs or a clubbed EODC by running combined calculations and documentation checks before filing with DGFT.
Exporters who align their licence planning and documentation with this 24 / 30 / 48 month logic will find it easier to obtain smooth, consolidated EODCs and avoid avoidable duty, interest, and compliance surprises under the Advance Authorisation scheme.