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EPCG Closure Explained: EODC, Regularisation & Surrender — Which Route Fits You? Kireeti Group, Exim

You've finished the export obligation on your EPCG licence. Exports done, money realised — file shut. Except it isn't. Until DGFT formally discharges the authorisation, it's still a live liability in your books.

EPCG lets you import capital goods at zero customs duty. In return, you take on an expo

24 Aug, 2026
You've finished the export obligation on your EPCG licence. Exports done, money realised — file shut. Except it isn't. Until DGFT formally discharges the authorisation, it's still a live liability in your books.

EPCG lets you import capital goods at zero customs duty. In return, you take on an export obligation — that's the bargain, under Chapter 5 of the Foreign Trade Policy 2023.

DGFT doesn't close the file for you. You have to apply, and what comes back is an Export Obligation Discharge Certificate — the EODC. That certificate is your proof. It's what lets Customs cancel the bond and release the bank guarantee you gave at registration.

So closure isn't a fresh benefit — it's the mandatory last step of a scheme you've already used.

Not everyone reaches this stage having met the obligation in full. The policy gives you three routes out, and picking the wrong one costs real money.

Route 1: EODC Closure. You've met the obligation in full, proven with shipping bills and e-BRCs. Interest is minimal or nil, and the bank guarantee returns once DGFT grants the certificate.

Route 2: Regularisation. You fell short during the obligation period. You pay duty on the proportionate duty saved value, plus interest. As of August 2026, the notified rate under Section 28AA of the Customs Act, 1962 is 15% a year — worth re-checking before you budget.

Route 3: Surrender. The licence was never used, no capital goods imported — nothing to recover, no interest. But surrender isn't an escape route: if you've imported against the authorisation, it's not open to you.

Before filing, build the file properly. You'll need:

The original authorisation with every amendment letter and extension
Bills of entry, to check over- or under-utilisation
Shipping bills and e-BRCs covering the exports claimed
Installation certificate for the capital goods
A CA Certificate confirming export performance

One more that saves pain later: a reconciliation note mapping each shipping bill to its export obligation block — Years 1–4 is the first block, Years 5–6 the second. DGFT checks block-wise, not just on the total. A file that clears on the total but fails on a block comes straight back to you.

A few things hold up most closures: assuming the file is ready because the total looks met, when the block-wise position is actually short; amendments that never made it into the DGFT system, triggering a deficiency letter; and simply waiting — an unresolved authorisation can be treated as a defaulted case, turning a routine closure into duty plus interest.

There's no fixed turnaround for an EODC — it depends on the regional authority, its workload, and how complete your file is. The file is the part you control.

Once the EODC is granted, go back to Customs for bond cancellation and bank guarantee release. That's your money — it's been sitting blocked.

Not sure which route fits your authorisation? The EPCG closure page is linked below, or book a consultation and we'll go through the file with you.

This is general information, not advice on your specific case. Rules change — please confirm the current position.

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