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Law Update
Quick note
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Importers dealing in ATS-8 now have a little more clarity on the immediate import-policy position.
The Directorate General of Foreign Trade has issued Notification No. 39/2026-27 dated 30 September 2026, extending the existing Minimum Import Price applicable to ATS-8 imports up to 30 November 2026. The MIP remains USD 111 per kilogram on CIF basis.
This is not a fresh MIP introduced in September 2026. The condition already existed under Notification No. 30/2025-26 dated 18 September 2025. The latest notification mainly extends the validity period and clearly says that the remaining terms and conditions of the earlier notification stay the same.
For businesses importing ATS-8, the practical issue is simple: check the product, the correct eight-digit ITC HS code, the CIF value and the import date before finalising the shipment.
| Particular | Details |
| Issuing Authority | Directorate General of Foreign Trade |
| Ministry | Ministry of Commerce and Industry |
| Department | Department of Commerce |
| Notification Number | 39/2026-27 |
| Notification Date | 30 September 2026 |
| S.O. Number | S.O. 5397(E) |
| Product | ATS-8 |
| Nature of Measure | Extension of existing Minimum Import Price |
| MIP | USD 111 per kg |
| Valuation Basis | CIF |
| Earlier Notification | Notification No. 30/2025-26 dated 18 September 2025 |
| Extended Till | 30 November 2026 |
| ITC HS Codes Mentioned | 10 |
| Governing Law | Foreign Trade (Development and Regulation) Act, 1992 |
| Policy Reference | Foreign Trade Policy, 2023 |
The legal basis mentioned in the notification includes Sections 3 and 5 of the Foreign Trade (Development and Regulation) Act, 1992, read with paragraphs 1.02 and 2.01 of the Foreign Trade Policy, 2023.
The change is narrower than the headline may first suggest.
DGFT has not increased the MIP, changed the product name, or announced a new valuation basis. What it has done is extend the period for which the existing MIP condition will continue.
The position after the notification is:
That is the core of the update.
Minimum Import Price, commonly called MIP, is a price-based import-policy condition applied to a specified product.
For ATS-8, the notified figure is:
USD 111 per kilogram on CIF basis.
This amount should not be confused with:
The notification does not describe the USD 111/kg figure as a tax or duty. It is a minimum import price condition under the import policy.
For an importer, the immediate compliance question is whether the imported ATS-8 is being assessed against the notified price condition on the correct basis.
The notification specifically refers to:
ATS-8 {(4R-Cis)-1,1-Dimethylethyl-6-cyanomethyl-2,2-dimethyl-1,3-dioxane-4-acetate}.
Why the Exact Product Description Matters
Import-policy conditions are not meant to be applied merely because a product falls somewhere under the same broad tariff chapter.
The importer should first establish that the actual product being imported is the ATS-8 described in the notification.
That review should be matched with the relevant ITC HS classification.
The notification itself does not give a separate technical specification, CAS number, end-use description or product standard. Those points should not be added unless independently verified from another official source.
DGFT has listed ten ITC HS codes in the notification.
| S. No. | ITC HS Code | Product Covered |
| 1 | 29329990 | ATS-8 |
| 2 | 29339990 | ATS-8 |
| 3 | 29333990 | ATS-8 |
| 4 | 29321990 | ATS-8 |
| 5 | 29349990 | ATS-8 |
| 6 | 29420090 | ATS-8 |
| 7 | 29189990 | ATS-8 |
| 8 | 29159099 | ATS-8 |
| 9 | 29163990 | ATS-8 |
| 10 | 29225090 | ATS-8 |
These are the exact tariff codes stated in the Gazette.
The wording matters here. The notification refers to ATS-8 under these listed codes. It should not be read as a blanket MIP on every chemical falling under Chapter 29.
No. The notification is specific to ATS-8 under the listed ITC HS codes. Chapter 29 covers a much wider range of chemical products. A business importing another chemical cannot assume that the same USD 111/kg condition applies only because that product also falls under Chapter 29. A proper review should look at three things together:
This is where ITC HS classification services and broader import compliance services can become useful, especially where the same chemical is described differently across supplier, shipping and customs documents.
The notification says that the MIP is USD 111 per kg on CIF basis. That means the relevant value should be considered on a Cost, Insurance and Freight basis.
CIF Means
The notified price condition is therefore not based only on the supplier’s base price. An importer should be careful not to compare the MIP with a figure that excludes freight or insurance where those elements are relevant to the CIF value. The notification itself does not provide an illustrative calculation, and one should not be invented.
| Compliance Point | Earlier Position | Position After Notification No. 39/2026-27 |
| Product | ATS-8 | No change |
| MIP | USD 111/kg | No change |
| Valuation Basis | CIF | No change |
| ITC HS Codes | Specified codes | Same ten codes listed |
| Regulatory Measure | Existing MIP condition | Continued |
| Validity | Earlier notified period | Extended till 30 November 2026 |
| Other Conditions | As per Notification 30/2025-26 | Continue unchanged |
This table makes the nature of the update clear: the date has changed, but the MIP itself has not.
One point should not be overlooked.
Notification No. 39/2026-27 does not rewrite every condition attached to the ATS-8 import policy. Instead, it says that the existing terms and conditions of Notification No. 30/2025-26 remain the same.
This means importers should not rely only on the latest two-page notification.
The compliance review should include:
Where the earlier notification contains additional terms, those terms remain relevant unless they have been changed separately.
The notification has been issued using powers under:
Why This Matters for Businesses
The ATS-8 MIP is not simply a commercial recommendation.
It forms part of the import-policy framework administered through DGFT.
That makes correct classification and correct reading of the policy condition important before a shipment is planned.
| Situation | Position |
| ATS-8 under the notified ITC HS codes | Covered |
| ATS-8 imported during the extended period | Covered subject to applicable conditions |
| Other unrelated chemicals under Chapter 29 | Not established as covered by this notification |
| Product under an ITC HS code not listed in the notification | Not established as covered by this notification |
| Imports after 30 November 2026 | Future position not stated in this notification |
This is a useful distinction because a broad reading can easily create the wrong compliance conclusion.
| Event | Date |
| Earlier Notification No. 30/2025-26 | 18 September 2025 |
| Notification No. 39/2026-27 | 30 September 2026 |
| MIP Extended Till | 30 November 2026 |
The latest notification is dated 30 September 2026, but the MIP continues up to 30 November 2026.
These are different dates and should not be mixed up in compliance planning.
The notification does not stop at saying “Chapter 29”.
It identifies ten eight-digit tariff codes.
That means the importer should review the complete tariff classification rather than relying only on a broad product family.
Product Name Alone May Not Be Enough
A commercial invoice may use one description while customs classification follows another technical description.
That is why product identity and tariff classification should be checked together.
Use the Full Eight-Digit Code
Where a DGFT condition is tied to specific eight-digit codes, using only a chapter heading or partial code can create an incomplete compliance check.
Keep Supporting Documents Consistent
Businesses should review consistency across:
This is a practical control, not a fresh documentation requirement created by Notification No. 39/2026-27.
The extension does not change the MIP amount, but it keeps the condition relevant for another period.
That affects import planning.
Pricing Review
Importers should review supplier quotations with the notified CIF-based MIP in mind.
Shipment Planning
Imports planned close to the end of November should be reviewed carefully, especially where the shipment, arrival or clearance timeline may cross the stated date.
The notification does not explain the legal position after 30 November 2026, so businesses should check for a fresh DGFT update where needed.
Procurement Decisions
Procurement teams may need to consider:
Compliance Coordination
The procurement, finance, logistics and compliance teams should work with the same product description and tariff classification.
That is particularly important where the same substance can appear under different commercial descriptions.
The compliance team should focus on four basic checks:
Customs teams should also confirm that the product description and classification used in declarations are consistent with the supporting commercial documents.
Before finalising an ATS-8 shipment, businesses should review the following.
Product Verification
Confirm the technical and commercial identity of the product.
ITC HS Classification
Check the full eight-digit code.
CIF Value Review
Assess whether the import value aligns with the notified MIP condition.
Earlier Notification Review
Read Notification No. 30/2025-26 because the latest notification keeps its other terms and conditions unchanged.
Shipment Timing
Check whether the import falls within the current extension period.
Regulatory Update Check
Where a shipment is planned after 30 November 2026, review the latest DGFT position before proceeding.
| Compliance Check | What Should Be Reviewed |
| Product Identity | Confirm that the imported material is ATS-8 |
| ITC HS Classification | Match the eight-digit code with the notified list |
| MIP | Verify USD 111/kg |
| Value Basis | Check CIF basis |
| Notification Validity | Track 30 November 2026 |
| Earlier Notification | Review Notification No. 30/2025-26 |
| Commercial Documents | Check consistency of description and value |
| Customs Documents | Check tariff classification consistency |
| Future DGFT Update | Monitor position after 30 November 2026 |
Assuming All Chapter 29 Imports Are Covered
That is not what the notification says.
The document deals with ATS-8 under specified tariff codes.
Treating the MIP as Customs Duty
The USD 111/kg figure is an MIP condition, not a customs duty rate.
Ignoring CIF Basis
The notification specifically uses CIF.
A basic supplier price should not be treated as the same thing without considering the valuation basis.
Using an Incomplete ITC HS Code
The notification lists eight-digit tariff codes. A broad chapter-level review may not be enough.
Ignoring the Earlier Notification
The earlier notification still matters because its other terms remain unchanged.
Assuming What Happens After 30 November 2026
The current notification does not tell businesses what will happen after that date.
Any later import decision should be based on the then-current DGFT position.
| Priority | Action | Team |
| High | Confirm product identity | Product/Compliance |
| High | Verify the exact ITC HS code | Customs/Compliance |
| High | Review USD 111/kg CIF MIP | Procurement/Finance |
| High | Check validity up to 30 November 2026 | Compliance |
| Medium | Read the earlier Notification No. 30/2025-26 | Legal/Compliance |
| Medium | Check invoice and customs document consistency | Logistics/Customs |
| Ongoing | Monitor future DGFT notifications | Compliance |
A business does not need to create unnecessary internal paperwork for this update. The focus should be on the actual import transaction and the policy condition that applies to it.
Where an import condition is linked to a specific product, tariff code and valuation basis, the first challenge is usually applicability.
Corpseed can support businesses with import compliance services covering:
For businesses handling multiple chemicals or tariff classifications, a proper DGFT import compliance consultant can also help identify whether a product falls under a specific restriction, condition or import-policy entry before shipment.
Corpseed's role is to assist with classification, interpretation and compliance preparation. Final applicability should always be assessed against the actual product, tariff code and latest official notification.
The present notification only extends the MIP up to 30 November 2026.
It does not state what will happen after that date.
Possible future action could include another notification dealing with continuation, amendment or withdrawal, but that cannot be assumed from the present document.
Businesses planning ATS-8 imports after 30 November should check the latest DGFT notification and ITC HS import-policy position before proceeding.
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