Law Updates

Subject

Summary: Indian businesses that export certain meat and meat products to Egypt now have more time under the i-CAS-Halal regime. As per DGFT's Notification No. 28/2026-27 dated 5 August 2026, the transition period for Egypt has been increased from six months to nine months, effective from Notification No. 59/2025-26 dated 9 February 2026. This provides additional time for implementation. DGFT stated that the additional time period will help complete system readiness, as well as the onboarding and accreditation process for Halal certification bodies in Egypt. This notification is neither an exemption from the requirement itself nor a revision of the earlier regime. All other aspects of Notification No. 59/2025-26 remain the same. For exporters, it provides valuable time. However, it should be viewed more as time for preparation rather than as an exemption from the requirement. Notification at a Glance Particular Details Issuing authority Directorate General of Foreign Trade (DGFT) Ministry Ministry of Commerce and Industry Department Department of Commerce Notification number 28/2026-27 Notification date 5 August 2026 Subject Streamlining of Halal Certification Process for Meat and Meat Products Earlier notification amended Notification No. 59/2025-26 dated 9 February 2026 Scheme involved India Conformity Assessment Scheme (i-CAS)-Halal Products concerned Specified meat and meat products Export destination Egypt Earlier transition period 6 months Revised transition period 9 months Additional time 3 months Reason stated by DGFT System readiness and onboarding/accreditation of certification bodies Other provisions Remain unchanged This amendment is minor yet significant from a commercial standpoint. It does not introduce a new certification process. All that it does is modify the time at which the existing requirement for Egypt takes effect. The notification itself is dated 5 August 2026. The attached Gazette issue carries the publication date of 21 August 2026. What Is DGFT Notification No. 28/2026-27 About? Notification No. 28/2026-27 does one main thing: it provides more time to implement the i-CAS-Halal framework for specified meat and meat product exports to Egypt. The essay will begin with Notification No. 59/2025-26, issued on 9 February 2026. This notification added 20 more countries to the mandatory i-CAS-Halal list. One of the countries added to this list is Egypt. For most of the additional countries, the February notification provided a two-week transition period. Egypt was treated separately and was originally given a six-month transition period because more time was needed for system readiness and onboarding of certification bodies. DGFT has now increased Egypt's transition period from six months to nine months. That distinction is important. The latest notification does not start a new nine-month period from August. The period continues to be counted from 9 February 2026. The Regulatory Background The Halal certification framework referenced in this amendment has evolved through a series of DGFT notifications. Notification No. 28/2026-27 has been issued under Section 3 read with Section 5 of the Foreign Trade (Development & Regulation) Act, 1992, along with Paragraphs 1.02 and 2.01 of the Foreign Trade Policy 2023. These legal provisions form part of the framework through which the Central Government regulates India's import and export policy. For an exporter, however, the practical chain of notifications matters more than the statutory wording. Notification No. 34/2024-25 DGFT Notification No. 34/2024-25, dated 1 October 2024, introduced revised export policy conditions for specified Halal-certified meat and meat products, effective from 16 October 2024. Under that framework, specified meat and meat products exported as Halal-certified goods to the listed countries must be produced, processed and/or packaged in a facility certified under the India Conformity Assessment Scheme (i-CAS)-Halal of the Quality Council of India. The policy also requires valid Halal certificates issued under i-CAS by certification bodies accredited by the National Accreditation Board for Certification Bodies (NABCB). Where the importing country has its own notified Halal requirements, those requirements also apply. Notification No. 59/2025-26 On 9 February 2026, DGFT included yet another 20 nations in the scheme. Egypt was one of these nations. While the notification initially provided six months for Egypt, it provided only two weeks for the other newly included nations. The conditions of the policies were also left as they were. Notification No. 28/2026-27 The latest notification changes that six-month period to nine months. Nothing more should be read into the amendment than what DGFT has actually changed. What is i-CAS-Halal? The India Conformity Assessment Scheme for Halal Meat and Meat Products for Exports, commonly known as i-CAS-Halal, is a certification scheme established by the Quality Council of India for Halal meat and meat products intended for export. The official QCI portal states that Halal Certification Bodies operating under the scheme must be accredited by NABCB. It also provides a system through which meat processing facilities and exporters, as well as accredited Halal Certification Bodies, can operate under the scheme. For an exporter, this means the DGFT framework is not based simply on obtaining any certificate labelled “Halal”. The applicable certification arrangement has to fit within the notified i-CAS-Halal structure, while importing-country requirements may also need to be met. The August notification has not replaced that wider framework. Only the Egypt transition period has changed. What Exactly Has Changed? The change can be explained in one line: For Egypt, the transition period has increased from six months to nine months from the date of Notification No. 59/2025-26 dated 9 February 2026. DGFT has substituted the second point under Paragraph 3 of the February notification. The revised provision allows a nine-month period for Egypt to complete system readiness and the onboarding/accreditation of certification bodies. The explanatory part of the notification confirms that this is an additional three-month extension. Earlier vs Revised Position Area Other provisions Revised Position What It Means Egypt's transition period 6 months 9 months Three additional months are available Date from which the period is counted 9 February 2026 9 February 2026 The starting date has not changed Certification-body readiness Six-month preparation window Nine-month preparation window More time for onboarding/accreditation Geographic scope of amendment Egypt Egypt This amendment is not a general extension for every country Other provisions Continued to apply Remain unchanged The wider framework has not been withdrawn The difference looks small on paper, but three months can matter where certification-body recognition, internal compliance work, and export planning have to move together. What Is the Revised Implementation Timeline? Stage Position Notification No. 59/2025-26 issued 9 February 2026 Original period for Egypt 6 months from that notification Notification No. 28/2026-27 issued 5 August 2026 Additional transition time 3 months Revised period for Egypt 9 months from 9 February 2026 The latest notification does not separately print a calendar date for the end of this period. Instead, DGFT uses the wording nine months from the date of Notification No. 59/2025-26 dated 09.02.2026. For compliance planning, businesses should follow that official wording and also check whether DGFT issues any later clarification before the transition period closes. Why Did DGFT Give Egypt Another Three Months? DGFT has given a clear reason. The extra time is intended to allow for system readiness and the onboarding/accreditation of Egyptian Halal certification bodies. That tells businesses something useful about the nature of the delay. Implementation depends not only on the exporter's preparedness. The certification system supporting the exports also has to be ready. The February notification had already recognized this issue by granting Egypt six months, whereas the other newly added countries received a two-week transition period. The August amendment shows that the original six-month period was not enough for the relevant onboarding process to be completed. For exporters, this lowers immediate time pressure. It does not remove the need to prepare. Who Should Pay Attention to This Change? The notification is not intended for every food or meat business in India. Its direct relevance is much narrower. Exporters Sending Covered Products to Egypt Indian businesses exporting specified meat and meat products to Egypt are the main commercial group affected by the revised timeline. These exporters need to understand both the extension and the underlying requirements that remain in place. Export-Oriented Meat Processing Facilities Where a processing facility produces, processes, or packages products covered by the i-CAS-Halal export framework, its certification readiness may affect future exports to Egypt. Under the underlying DGFT framework, Halal-certified exports of the specified products to notified countries are linked with facilities certified under i-CAS-Halal. Halal Certification Bodies Certification bodies are particularly relevant because the extension was issued specifically to allow additional time for their onboarding and accreditation. Compliance, Quality and Export Teams The notification may also require practical coordination among regulatory, quality, export documentation, sales, and operations teams. That does not mean Notification No. 28/2026-27 creates a new legal duty for each of these departments. It simply means they may need to work together to properly prepare the business. Does the Nine-Month Extension Apply to Every Export Destination? No. This amendment is specifically for Egypt. This is an easy point to misunderstand. Notification No. 59/2025-26 added 20 countries to the mandatory i-CAS-Halal framework. For the newly added countries other than Egypt, the notification prescribed a two-week transition period. Egypt alone was originally given six months. Notification No. 28/2026-27 replaces only the Egypt-related point. A business exporting the same product to two different countries should therefore not assume that the same implementation timeline applies to both. Destination matters. What Has Not Changed? DGFT has been equally clear about what it has not changed. The notification says that all other provisions of Notification No. 59/2025-26 remain unchanged. That single line is important because it prevents the extension from being interpreted too broadly. The August notification does not: Withdrawal Notification No. 59/2025-26, Remove Egypt from the covered framework, Make i-CAS-Halal voluntary, Give exporters a permanent exemption, Replace the underlying certification conditions, or Change every country-specific implementation period. Notification No. 59/2025-26 itself preserved the other policy conditions set out in Notification No. 34/2024-25, including the NABCB-accredited certification requirement and applicable importing-country regulations. So exporters should read all three notifications together, rather than treating the latest amendment as a standalone rulebook. Does the Extension Make i-CAS-Halal Optional? No. DGFT itself describes the affected framework as the mandatory India Conformity Assessment Scheme (i-CAS)-Halal for exports of specified meat and meat products to Egypt. The amendment changes timing, not the nature of the requirement. There is a simple difference: An extension gives more time. An exemption removes a requirement for a defined case. A withdrawal removes an earlier requirement. A suspension temporarily stops its operation. A relaxation changes or reduces the obligation. The present notification provides an extension. For businesses, that means the better approach is to use the extra time rather than wait for the requirement to disappear. What Does the Extension Mean for Halal Certification Bodies? Certification-body readiness is the reason this notification exists. The February notification referred to giving Egypt time to ensure system readiness and to onboard certification bodies. The August amendment now refers specifically to onboarding/accreditation. Its explanatory section states that the additional three months are intended to help complete the onboarding and accreditation process for Egyptian Halal certification bodies. The QCI i-CAS-Halal portal also confirms that Halal Certification Bodies operating under the scheme must be accredited by the NABCB. The notification, however, does not prescribe new accreditation fees, forms, or detailed procedures. Those details should not be added to the amendment unless supported by the relevant official scheme documents. How Does This Affect Indian Meat Exporters? For exporters, the biggest immediate benefit is simple: more time to prepare. What businesses do during that time will decide whether the extension is actually useful. Exporters Can Recheck Product Coverage A company should first determine whether the products it exports fall within the specified meat and meat products covered by the applicable DGFT framework. There is little value in building a compliance process around a notification before confirming that it applies to the product. Existing Certification Arrangements Can Be Reviewed Firms which have been exporting products with Halal certification will be able to verify whether they meet the criteria of the i-CAS-Halal regime. This is more critical when the firm has previously used another form of certification. Egypt-Bound Orders Can Be Mapped Early Commercial teams should know which confirmed and expected orders may fall around the revised implementation period. This gives the compliance and quality teams enough time to review those consignments before they reach the dispatch stage. Internal Records Can Be Checked The export process, the certification procedure, and the commercial documents should all say the same thing. When there are differences among product descriptions, facility information, certifications, and shipping documents, discrepancies are easier to resolve sooner rather than later. Notification No. 28/2026-27 does not create a fresh document checklist. This is simply sensible internal preparation. Practical Impact on Different Stakeholders Stakeholder What Changes Now Main Area to Review Meat exporters to Egypt Three more months of transition time Applicability and certification readiness Export meat processors Longer preparation window Facility certification status Halal Certification Bodies More time for onboarding/accreditation Scheme readiness Compliance teams The revised timeline must be tracked DGFT notifications and certification status Export teams Future shipments may need review Shipment timing and destination Commercial teams Order planning may need alignment Contracts and delivery schedules For larger exporters, the issue may cross several departments. For smaller businesses, one person may handle most of these tasks. Either way, someone should be clearly responsible for tracking the revised position. How Can the Extension Affect Export Planning? A three-month extension may look like a regulatory detail, but it can influence practical export decisions. A business with regular shipments to Egypt may want to look at: Confirmed orders, Proposed shipment dates, Product coverage, Facility certification status, Availability of the appropriate certification body, Certificates and supporting records, Buyer requirements, Applicable Egyptian requirements, and Any DGFT or QCI update issued before dispatch. Contracts deserve attention as well. If a company promises a delivery date without checking whether the shipment will fall before or after the revised implementation point, the compliance team may later be asked to solve a problem that could have been identified earlier. The extension gives businesses more room to avoid that type of last-minute situation. What Are the Practical Benefits of the Extension? The notification does not promise commercial benefits, but the additional time can help businesses in several practical ways. More time for certification readiness: Exporters and processing facilities can review the position before the revised implementation point. More time for certification bodies: This is the stated purpose of the amendment and is particularly relevant for the Egyptian certification ecosystem. Less pressure on internal teams: Quality, export, and compliance staff get a wider window to identify gaps. Better shipment planning: Businesses can review future orders for Egypt before committing goods to dispatch. Time to monitor official updates: If further operational clarifications are issued, exporters have an opportunity to incorporate them before implementation. These are possible operational advantages. They should not be presented as guaranteed savings, guaranteed certification, or guaranteed market access. What Problems Can Still Remain? An extension solves a timing problem. It does not automatically solve every compliance problem. One exporter may still be unsure whether a particular product is covered. Another may need to clarify whether its existing facility certification fits the notified framework. A third may have the right certification arrangement, but weak coordination between its quality, export and commercial teams. Importing-country rules can also remain relevant. The underlying DGFT framework expressly recognizes that exporters may have to meet the importing country's applicable requirements in addition to i-CAS conformity. The extra three months, therefore, reduce immediate pressure. They do not remove the need to check the business's actual position. Is the Extension Genuine Relief or Just More Preparation Time? It is both, but in a limited sense. Where the Extension Helps What Still Needs Attention Gives three additional months The underlying framework remains mandatory Allows more certification-body preparation Exporters still need to check readiness Reduces immediate time pressure Product and destination applicability still matter Provides more planning time Importing-country requirements may still apply Helps internal coordination Other provisions remain unchanged For exporters facing a certification-system readiness issue, another three months can provide useful relief. But it is not a relief from compliance itself. A business that spends the entire extended period waiting may find itself facing the same rush later. What Should Exporters Use the Extra Time For? The current notification does not create a new application process. There is therefore no reason to manufacture one. A practical approach would be to use the extension for the following work: Applicability check. Ensure that the product falls under the scope of meat and meat products, and that the destination country is Egypt. Read the notifications as a whole. October 2024, February 2026, and August 2026 are part of a coherent chain of notifications. Review facility certification. Check whether the facility's position aligns with the applicable i-CAS-Halal requirements. Check certification-body arrangements. Confirm the current position rather than relying on assumptions based on an older certification route. Review future shipments. Identify consignments likely to move around the end of the transition period. Check documents early. Product, facility, certification, and shipment information should be consistent. Inform the commercial team. Sales targets should align with the most recent regulatory stance. Check official sources. Future notifications by DGFT, QCI, NABCB, or APEDA could impact plans. This is just sensible planning. Not all items here are statutory requirements in Notification No. 28/2026-27. Exporter Readiness Checklist Verify that the goods are being shipped to Egypt. Verify if the product qualifies under the applicable DGFT policy conditions. Check Notification No. 34/2024-25. Check Notification No. 59/2025-26. Check Notification No. 28/2026-27. Verify the facility's current i-CAS-Halal status. Check the pertinent Halal Certification Body agreement. List the future Egypt-bound shipments. Verify consistency of certification/export documentation. Brief the export/commercial team on the new schedule. Wait for further government notifications before dispatching the consignments in question. This is an internal preparation checklist, not a document checklist as per the August notification. What Are the Risks of Waiting Until the Last Moment? Notification No. 28/2026-27 does not prescribe a new fine or penalty for businesses that use the transition period. The more immediate risk is operational. A business that waits may discover late that its certification arrangement needs attention. A consignment may be scheduled around the implementation period without the commercial team realizing it. Records held by different departments may not match. Communication with a certification body may also take longer than expected. None of these outcomes should be presented as an automatic legal consequence of the notification. They are avoidable business problems that become harder to solve as time runs out. What Happens After the Nine Months? The notification states that the relevant requirement for Egypt will take effect nine months after the date of Notification No. 59/2025-26 dated 9 February 2026. It does not, in this amendment, introduce a new penalty table, customs-enforcement procedure, inspection system, or separate application mechanism. Those details should not be guessed. Businesses planning consignments near the implementation date should check the latest DGFT position and applicable certification requirements before shipment. What Should Exporters Monitor From Here? The most useful sources to watch are the authorities directly connected with the framework. Businesses should monitor: DGFT notifications and trade notices, QCI i-CAS-Halal updates, NABCB information on accredited Halal Certification Bodies, APEDA notices relevant to meat exporters, Destination-specific requirements for Egypt, and Any later amendment to the February or August notifications. Another extension should not be assumed unless DGFT issues one. Businesses should plan based on the current nine-month framework. What Should Businesses Do Next? Priority Action Responsible Function Why It Matters High Confirm product and Egypt applicability Export/Compliance Establish whether the change affects the business High Review the three linked DGFT notifications Legal/Compliance Understand the full framework rather than only the extension High Check current certification readiness Quality/Compliance Identify gaps while transition time remains High Review certification-body arrangements Quality/Compliance Confirm alignment with the applicable framework Medium-High Map upcoming Egypt shipments Export/Commercial Identify consignments close to implementation Medium Review supporting records Documentation/Quality Reduce inconsistencies before dispatch Ongoing Monitor official updates Compliance Capture later changes or clarification A company does not need to create extra paperwork merely because a new notification has been issued. The first step is to determine whether the amendment applies and, if it does, whether the business is ready to meet the underlying requirement. Where that assessment becomes difficult, professional DGFT compliance services can help businesses review the regulatory chain and identify what actually requires attention. How Corpseed Can Help The challenge for an exporter is rarely contained in a single paragraph of a DGFT notification. The difficulty usually arises when a company has to link the notification to its products, destination, facility certification, certification-body arrangement, export records, and shipment schedule. Corpseed can provide DGFT compliance services and export regulatory support in areas relevant to this amendment. DGFT Applicability Assessment Corpseed can help a business check whether Notification No. 28/2026-27 is relevant to its product and Egypt-bound export activity. This is useful when a company handles several product categories or exports to more than one country and does not want to incorrectly apply the Egypt extension across its entire export business. Review of the i-CAS-Halal Framework The latest amendment is only one part of the regulatory chain. Corpseed can assist exporters in reviewing the applicable i-CAS-Halal framework and understanding how the current requirements relate to their operations. Review of Connected DGFT Notifications Notifications No. 34/2024-25, 59/2025-26 and 28/2026-27 should not be read as unrelated documents. Corpseed can help map these changes together so that a business understands: Where the certification framework began, When Egypt was added, What transition period originally applied What does the latest amendment change? Export Compliance Gap Assessment The extra transition period can be used to compare current business practices with the applicable regulatory position. Through a compliance gap assessment, Corpseed can help identify areas that may require attention before the revised implementation point. The review can focus on the business's actual products, certification status, and export process rather than using a generic compliance checklist. Export Documentation Support Different teams often hold different parts of the export record. Corpseed can provide export documentation support to help businesses organize relevant records and identify obvious gaps or inconsistencies from a compliance-readiness perspective. Document review does not guarantee customs clearance or certification. Its purpose is to reduce avoidable documentation problems. Certification Coordination Support Where certification-related coordination is required, Corpseed can assist businesses in understanding the applicable framework and in organizing the procedural aspects of the process with relevant bodies. Certification and accreditation decisions remain with the competent certification and accreditation organizations. Export Regulatory Advisory Businesses dealing with more than one country may find destination-specific export conditions difficult to track. Corpseed's export compliance consulting support can help businesses understand DGFT policy conditions and amendments and their practical relevance to future shipments. Ongoing Compliance Monitoring The position can change again through a later notification or clarification. Corpseed can support exporters with ongoing regulatory monitoring so that internal teams are not planning shipments on the basis of an outdated deadline or an earlier version of the policy. Professional support can help organize the compliance process, but it cannot replace DGFT, QCI, NABCB, customs authorities, recognized certification bodies, or importing-country authorities. Corpseed does not guarantee Halal certification, accreditation, customs acceptance, regulatory approval or clearance of a particular shipment. Businesses exporting specified meat and meat products to Egypt that need help understanding the revised timeline can use DGFT compliance services to assess applicability, review related notifications, check certification readiness, and organize the compliance work before the transition period ends. Key Takeaways DGFT Notification No. 28/2026-27 dated 5 August 2026 changes the transition period applicable to specified meat and meat product exports to Egypt. The earlier period of six months has been increased to nine months from Notification No. 59/2025-26 dated 9 February 2026. The amendment therefore provides an additional three months. DGFT says this additional time is meant to facilitate system readiness and completion of the onboarding/accreditation process of Egyptian Halal certification bodies. The change is specific to Egypt. It should not automatically be applied to another destination. The mandatory i-CAS-Halal framework has not been cancelled or made voluntary. All other provisions of Notification No. 59/2025-26 remain unchanged. Exporters can use the additional period to check product coverage, certification arrangements, documentation, and future shipment schedules.

Subject

Summary: The Medical Devices (Third Amendment) Rules, 2026, change a small but important part of the Medical Devices Rules, 2017. The Ministry of Health and Family Welfare has added Quality Management System (QMS) compliance to the self-certification requirements under Rules 19H and 19J, changed the heading used for government medical device testing laboratories, and added European Union countries to a specific provision under Rule 63. The QMS change is particularly relevant to manufacturers and importers of Class A non-sterile and non-measuring medical devices. The Rule 63 amendment has a different purpose. It concerns certain investigational medical devices that lack a predicate device and already have regulatory and marketing histories in specified overseas jurisdictions. So, this is not a new licensing system for the entire medical device industry. Its impact depends on the rule under which a business or product currently operates. Notification at a Glance Particular Details Issuing Ministry Ministry of Health and Family Welfare Department Department of Health and Family Welfare Rules Medical Devices (Third Amendment) Rules, 2026 Principal Rules Medical Devices Rules, 2017 Governing Law Drugs and Cosmetics Act, 1940 Provisions Changed Rules 19H, 19J, Rule 19 marginal heading and Rule 63 Main QMS Change Rules 19H, 19J, Rule 19 marginal heading and Rule 63 Rule 63 Change European Union countries added after Japan in Proviso (iv) Main Businesses Affected Relevant Class A manufacturers and importers, applicants covered by Rule 63 The notification itself is only three pages long. The important part is not its length, but where these changes sit within the existing Medical Devices Rules. Rules 19H and 19J address a specific category of Class A devices, whereas Rule 63 addresses an entirely different regulatory situation. What Are the Medical Devices (Third Amendment) Rules, 2026? The Medical Devices (Third Amendment) Rules, 2026, do not replace the Medical Devices Rules, 2017. They amend selected provisions of the existing rules. This distinction matters because a reader could otherwise look at the QMS amendment and assume that a completely new certification or licensing system has been introduced. That is not what it says. The final rules make four changes: QMS is expressly added to the self-certification requirement in Rule 19H(2)(v). The same QMS wording is added to Rule 19J (2) (v). The marginal heading of Rule 19 is changed to “Government Medical Device Testing Laboratories.” European Union countries are added to Rule 63(1), Proviso (IV). Each of these changes must be read in conjunction with the original provision. Looking only at the amendment would tell a business what words have changed, but not necessarily how those words affect its regulatory position. Why Was This Amendment Introduced? The final Gazette gives the legal amendments, but earlier proceedings of the Drugs Technical Advisory Board (DTAB) provide useful background on why some of these changes were proposed. Closing the QMS gap for certain Class A devices Chapter IIIB of the Medical Devices Rules applies to Class A non-sterile and non-measuring medical devices. Under that framework, manufacturers and importers obtain registration by submitting prescribed information through the Online System for Medical Devices rather than following the licensing framework used for other categories. During its 91st meeting, DTAB noted that Rules 19H and 19J already addressed registration and self-certification for these devices. Still, the scope of conformity with the Quality Management System was not expressly included in those clauses. The Board's discussion linked QMS with the need to ensure that medical devices meet applicable standards and essential principles relating to safety and performance. DTAB therefore agreed with the proposal to add QMS requirements to Rules 19H and 19J. The 2026 amendment puts that proposal into the rule text. Distinguishing government laboratories from private testing laboratories There was also a terminology issue around Rule 19. The Medical Devices Rules separately use the term “medical devices testing laboratory” to refer to laboratories registered to test or evaluate devices on behalf of manufacturers. DTAB considered that the Rule 19 heading should make it clearer that the laboratories covered there are government testing laboratories. Its minutes specifically record the proposal to change the heading from “Medical Device Testing Laboratories” to “Government Medical Device Testing Laboratories.” Adding the European Union to Rule 63 The EU-related change has a longer history. DTAB records show that the exclusion of the European Union from the countries listed in Rule 63 had been raised during an India-EU Sub-Commission on Trade meeting held on 6 June 2018. The Board later recommended amending Rule 63(1) to include the European Union. It now makes that addition in the final rules. From Draft Rules to the Final Amendment The Government first placed these changes before the public in draft form. Proposed amendments to Rules 19H, 19J, Rule 19 and Rule 63. The draft notification invited objections and suggestions from people likely to be affected. The consultation period was 30 days from the date on which copies of the Gazette were made available to the public. The final notification records that the Gazette copies were made available on 10 April 2026 and that the Central Government considered the objections and suggestions it received before finalising the rules. For compliance purposes, the difference is straightforward: It was a draft proposal. IT contains the final rules. Companies that reviewed the April draft should now update their internal notes and work from the final notification. When Do the Medical Devices (Third Amendment) Rules, 2026 Apply? The rules say that, unless a provision states otherwise, they come into force on the date of their final publication in the Official Gazette. There are a few dates on the document, which can be confusing. The Ministry's notification is dated 14 August 2026. The Gazette issue carrying the notification is dated 19 August 2026. Because commencement is tied to final publication rather than merely the date written below the Ministry heading, businesses should work from the final Gazette publication dated 19 August 2026. The notification does not provide a separate transition period for the four amendments. What Has Actually Changed? The easiest way to understand the amendment is to separate the four changes rather than treating them as one large reform. Provision Earlier Position Position After IT What It Means Rule 19H(2)(v) Manufacturer self-certified compliance with standards specified in the Rules QMS is now also expressly included Relevant Class A manufacturers must address QMS in the self-certification Rule 19J(2)(v) Importer self-certified compliance with standards specified in the Rules QMS is expressly added Relevant Class A importers must also address QMS Rule 19 heading “Medical Device Testing Laboratories” “Government Medical Device Testing Laboratories” Makes the government-laboratory context clearer Rule 63(1), Proviso (iv) UK, USA, Australia, Canada and Japan were listed European Union countries are added Certain EU regulatory history may now be considered under the existing proviso The first two changes affect the wording of an existing compliance declaration. The Rule 19 change mainly clarifies terminology. The Rule 63 amendment expands a country list inside an already conditional provision. Those differences should be kept in mind before deciding what action, if any, a business needs to take. QMS Is Now Expressly Included Under Rule 19H Rule 19H applies to the manufacturer of a Class A non-sterile and non-measuring medical device. Chapter IIIB states that these devices are registered via a designated online portal. Rule 19H then lists the information the manufacturer must upload. That includes manufacturing-site details, device details, classification-related declarations, and self-certification relating to safety, performance, and standards. Before IT, clause (v) required the manufacturer to self-certify compliance with the standards specified in the Rules. The new amendment inserts the words “and Quality Management System” after “standards”. That may look like a small drafting change, but it changes what the manufacturer's self-certification must cover. A manufacturer relying on Rule 19H now needs to be confident that it can support a declaration covering both the applicable standards and the QMS required under the Medical Devices Rules. This is where a proper internal quality review becomes more useful than simply updating the wording on a regulatory checklist. What Changes Under Rule 19J for Importers? Rule 19J deals with the import of Class A non-sterile and non-measuring medical devices. The importer uploads prescribed information on the Online System for Medical Devices. Under the existing rule, this includes information about the importer and manufacturing site, details of the device, an undertaking about its Class A status, self-certification against essential safety and performance principles, self-certification against applicable standards, and specified overseas establishment or free-sale evidence. IT now adds “and Quality Management System” to clause (v). For an importer, the practical issue is slightly different from that faced by an Indian manufacturer. The importer makes the declaration in India, but the overseas manufacturing site controls the manufacturing process. The importer therefore needs enough reliable information from that manufacturer to understand whether the QMS requirement being certified is actually met. This does not mean an importer should automatically start collecting every quality document held by a foreign manufacturer. It does mean that the basis for the self-certification should be clear and defensible. Businesses uncertain about how much QMS evidence is relevant to a particular registration may need a product-specific review rather than a generic checklist of documents. This is one area where a medical device regulatory consultant can help identify the applicable rule and avoid unnecessary filings or unsupported declarations. What Does “Quality Management System” Mean Under the Medical Devices Rules? QMS is not a new term introduced in 2026. The Medical Devices Rules already define the Quality Management System as the requirements for manufacturing medical devices specified in the Fifth Schedule. A QMS is, in practical terms, the organised system through which a manufacturer controls how a medical device is made and checked. It is broader than testing the finished product. Depending on the applicable requirements, it addresses matters such as documented processes, responsibilities, manufacturing controls, quality checks, records, and problem handling. That distinction explains why the Government chose to mention QMS alongside standards expressly. A product can be designed against a particular technical standard, but consistent quality also depends on how the manufacturing operation is controlled day after day. DTAB's own discussion described QMS as important for ensuring that devices meet relevant standards and essential principles of safety and performance, and referred to adherence to the Fifth Schedule. Does the Amendment Mean Every Business Needs a New QMS Certificate? No. IT does not itself create a new standalone QMS certificate or say that every Class A registrant must obtain a new ISO 13485 certificate. The actual amendment is narrower. It changes the existing self-certification requirement so that the manufacturer or importer certifies compliance with the standards and Quality Management System specified under the Medical Devices Rules. That wording should be followed as written. A company should therefore avoid two extremes. One is to ignore the QMS addition, as no new licence form has been introduced. The other is to assume that the notification automatically creates a completely new certification procedure that is not actually stated in the rule. The right compliance response begins with the device category, the applicable registration provision, and the QMS requirements relevant to the manufacturing operation. What Has Changed for Government Medical Device Testing Laboratories? Rule 19 now carries the marginal heading: “Government Medical Device Testing Laboratories.” The reason behind the wording is easier to understand when Rule 19's recent history is considered. A 2023 amendment changed the framework to recognise State Medical Devices Testing Laboratories. It allowed a State Government to establish such a laboratory or designate an eligible laboratory for specified testing and evaluation functions. At the same time, the Rules also use the expression “medical devices testing laboratory” for laboratories registered under a different provision to perform testing or evaluation on behalf of manufacturers. DTAB later observed that the headings should distinguish government testing laboratories from private medical device testing laboratories. The 2026 amendment therefore changes the heading. It does not, by itself: Create a new government laboratory, Introduce a fresh testing procedure, Change test parameters, Establish a new laboratory registration form, or Introduce a separate testing fee. For most manufacturers and importers, this is therefore a terminology and regulatory-reference issue rather than a new filing obligation. Rule 63 Now Includes European Union Countries The fourth change differs significantly from the QMS amendments. Rule 63 concerns permission to import or manufacture a medical device that has no predicate device. Under the existing rule, the authorised agent in the case of import, or the manufacturer in the case of domestic manufacture, applies to the Central Licensing Authority in Form MD-26 along with the prescribed information and fee. Where permission is granted, it is issued in Form MD-27. The rule also contains several provisos addressing situations in which clinical data requirements may be treated differently. One of those provisos covered devices approved by regulatory authorities in the: United Kingdom, United States of America, Australia, Canada, or Japan. IT inserts “European Union countries” after Japan. That is the legal change. What it does not do is give every EU-approved medical device an automatic right to enter the Indian market. What Was the Earlier Rule 63 Position? Under the pre-amendment wording, results of clinical investigation could, subject to the rule, not be required to be submitted where a regulatory authority had approved an investigational medical device in one of the listed countries. But foreign approval was only one part of the condition. The rule also required that the device have been marketed in that country for at least two years. The Central Licensing Authority had to be satisfied with its safety, performance and pharmacovigilance data. The provision further addresses whether there is evidence or a theoretical possibility of differences in behaviour and performance in the Indian population and requires a written undertaking concerning post-market clinical investigation. So even before the EU was added, the provision did not operate as a simple “approved abroad = automatically approved in India” rule. That remains true after the amendment. What Does the EU Addition Change in Practice? The main change is that qualifying regulatory history from European Union countries can now fall within this particular Rule 63 proviso. For an applicant with a device that does not have a predicate device, this may be relevant where the product already has the required approval and marketing history in an EU country. The applicant still needs to satisfy the remaining conditions. The Central Licensing Authority also continues to have a regulatory role. IT has not removed the Rule 63 permission process. This means phrases such as “EU medical devices are now exempt from Indian clinical investigation” would be too broad. A more accurate way to describe the amendment is: EU countries have been added to the overseas jurisdictions recognised under a conditional Rule 63 provision in which clinical investigation results may not be required to be submitted if the prescribed conditions are met. For companies dealing with such products, a review of medical device import compliance services may be useful before relying on the amended provision, particularly where foreign approvals, marketing history and Indian regulatory evidence need to be read together. Why Was the European Union Added? The Government's regulatory discussion on this issue dates back several years. Minutes of the 91st DTAB meeting record that the matter had been raised during the India-EU Sub-Commission on Trade held on 6 June 2018. The concern was that Rule 63 referred to the US, the UK, Australia, Canada, and Japan, but not the EU. DTAB subsequently recommended amending Rule 63(1) to include the European Union. The final 2026 amendment gives effect to that recommendation. For businesses, the important takeaway is not that Indian requirements have been removed for EU devices. The change is that EU regulatory history now receives express recognition under this provision, subject to the conditions already set out in Rule 63. Who Should Pay Close Attention to the Amendment? The amendment is not equally relevant to every company in the medical device sector. Stakeholder Main Issue to Review Indian manufacturers of Class A non-sterile and non-measuring devices QMS self-certification under Rule 19H Importers of Class A non-sterile and non-measuring devices QMS self-certification under Rule 19H Overseas manufacturers supplying such Class A products QMS information needed to support the Indian importer's position Authorised agents handling devices without predicate devices QMS information needed to support the Indian importer's position Manufacturers of devices without predicate devices QMS information needed to support the Indian importer's position Manufacturers of devices without predicate devices Updated Rule 19 terminology Regulatory affairs teams Correct applicability and updated rule references Quality teams Evidence supporting QMS compliance A manufacturer of a Class C device with no connection to Rule 63, for example, should not assume that a new Rule 19H registration requirement suddenly applies to it. The first question should always be: Which amended rule actually covers this product or activity? What Does This Mean for Class A Medical Device Manufacturers? For a manufacturer already registered under the Class A non-sterile and non-measuring route, the practical focus should be on self-certification. The company should review whether its quality system is aligned with the relevant Fifth Schedule requirements and whether its regulatory records are consistent with that position. This is not simply a paperwork exercise. When a business signs a self-certification, the value of that declaration comes from the records and controls behind it. Rule 19L also requires manufacturers and importers under this chapter to maintain relevant manufacturing or import records together with sales or distribution records and to produce specified records when requested by the licensing authorities. The amendment therefore makes it sensible to review QMS evidence alongside the existing registration record, rather than updating a single sentence in isolation. What Does This Mean for Importers? Importers have an extra layer to manage because the manufacturing site is outside India. Rule 19J places the self-certification obligation on the importer. At the same time, the underlying quality processes will generally sit with the overseas manufacturer. A sensible review may therefore cover: Whether the device is correctly treated as Class A non-sterile and non-measuring, Whether the overseas manufacturing site details match the registration record, What information supports QMS conformity Whether applicable product standards have been correctly identified, Whether free-sale or establishment documentation remains consistent with the registration, and Whether the submitted declaration can be supported by the records available to the importer. Not every importer will need the same documents. The exact evidence depends on the product, manufacturing arrangement, and regulatory record. A medical device regulatory consultant or an experienced internal regulatory team can be useful here, as the aim is not to compile the largest possible file. It is to identify what actually supports the legal declaration. Does IT Create a New License or Registration? IT does not introduce a new license category, a new registration form, or a separate application merely because QMS has been added to Rules 19H and 19J. The Class A registration route already existed. The amendment changes what is expressly covered by the self-certification within that route. Similarly: The Rule 63 permission mechanism already existed, Form MD-26 and Form MD-27 already formed part of that framework, Rule 19 already dealt with testing laboratories, and The 2026 notification does not prescribe a new standalone government testing-laboratory filing. This distinction can save companies from unnecessary compliance work. The correct response is to update the existing applicable process rather than invent a new one. Compliance Readiness Checklist for Medical Device Businesses The purpose of this exercise is not to create more documents. It is to make sure the documents already relied upon tell the same regulatory story as the amended rules. Compliance Risks Worth Avoiding Treating the Amendment as Applicable to Every Medical Device Rules 19H and 19J have a defined scope. They fall under the framework for Class A non-sterile, non-measuring devices. Applying these provisions to an unrelated device category can lead to the wrong compliance route. Updating the Declaration but Not Checking the QMS Changing the wording of a self-certification is easy. Being able to support it is the more important part. Affected manufacturers and importers should understand the evidence underpinning the QMS declaration before submitting or relying on it. Assuming ISO Certification Is Automatically the Entire Answer The 2026 amendment refers to the Quality Management System specified in the Medical Devices Rules. The Rules themselves link QMS to the Fifth Schedule. A certificate may be relevant in a particular compliance setting, but IT should not be rewritten to require every affected business to obtain a new ISO certificate. Assuming Any EU Approval Is Enough under Rule 63 The amendment adds EU countries to the list. It does not delete the other conditions. A company should therefore avoid relying solely on an EU approval certificate and instead consider factors such as marketing history, safety, performance, pharmacovigilance, and other requirements under the proviso. Confusing Rule 63 with the Regular Import Route Rule 63 deals with medical devices without a predicate device. It is not a general shortcut for every medical device being imported from Europe. Is This More of a Regulatory Clarification or an Additional Burden? It is a mixture of both, although the nature of the impact differs across the four amendments. Regulatory Benefit Possible Business Effort QMS responsibility is stated more clearly for the relevant Class A registration route Businesses may need to review the evidence supporting self-certification Government testing laboratories are more clearly distinguished from other testing laboratories Internal regulatory references may need updating EU countries are expressly brought within the specified Rule 63 proviso Applicants still need to prove that all other conditions are met Existing gaps in wording are reduced Regulatory and quality teams need to understand the amended text For Class A manufacturers and importers, the QMS addition clarifies compliance expectations. That can mean additional work where QMS records were not previously reviewed as part of the registration process. At the same time, the Government has not added an entirely separate application or licensing layer. The Rule 63 amendment is more clearly a regulatory expansion of an existing provision. It gives EU regulatory history a place within the specified proviso. However, the protection built into the rule remains: the applicant must still meet the conditions, and the Central Licensing Authority must still be satisfied. The Rule 19 heading is the least burdensome of the changes. Its main purpose is clarity. What Should Businesses Do Now? The best response is not to reopen every medical device file in the company. Start with the products that actually fall under one of the amended provisions. First, check classification. Manufacturers and importers should determine whether any product is registered as a Class A non-sterile, non-measuring medical device. Next, review the current registration record. Review the self-certification used under Rule 19H or Rule 19J, and ensure the amended QMS requirement is understood. Then look behind the declaration. Quality and regulatory teams should assess whether the available QMS records provide a reasonable basis for certification. For imports from the EU, separate ordinary imports from Rule 63 cases. The fact that a device comes from Europe does not, by itself, make the new proviso relevant. For genuine Rule 63 cases, review every condition. Country approval is only one part of the analysis. Update internal references. SOPs, regulatory trackers and compliance notes that reproduce the old wording of the affected provisions should be corrected. Keep watching official CDSCO updates. If operational guidance is issued later on implementation, affected businesses should assess whether it changes their existing processes. How Corpseed Can Help With Medical Device Regulatory Compliance A three-page amendment can still raise difficult questions when applied to an actual product. A manufacturer may know that its product is Class A but be unsure whether the non-sterile and non-measuring registration route applies. An importer may have QMS documents from an overseas manufacturer but still need to understand whether those records adequately support the Indian self-certification. A company dealing with a device without a predicate may have European approval but may not know whether the complete Rule 63 conditions are satisfied. Corpseed can support medical device businesses in areas such as: Medical device regulatory applicability assessment: Reviewing the product, classification, and business activity to identify the relevant provisions of the Medical Devices Rules. Class A medical device registration support: Assistance with the registration framework applicable to Class A non-sterile and non-measuring devices. Quality Management System compliance review: Assessing the QMS requirements relevant to Rules 19H and 19J and reviewing whether available records support the required regulatory position. CDSCO registration services: Supporting businesses with applicable CDSCO registrations , submissions and regulatory documentation. Medical device import compliance services: Reviewing the regulatory route for imported devices, overseas manufacturing information and India-specific requirements. Rule 63 regulatory assessment: Examining whether the device falls within the no-predicate-device framework and whether the amended EU provision may be relevant. Technical document review: Checking regulatory records, declarations, product information and supporting documents for consistency before submission. Medical device compliance gap assessment: Comparing existing documentation and processes against the applicable Medical Devices Rules. Overseas manufacturer and authorised-agent support: Helping organise information used for Indian medical device regulatory filings involving a foreign manufacturing site. Medical device registration and licence support: Assisting with applications, amendments or ongoing regulatory processes where the applicable law requires them. Regulatory monitoring: Tracking later CDSCO and Ministry notifications that may affect the product or regulatory route. Using a medical device regulatory consultant is most useful where there is a genuine question of applicability or documentation. The aim should be to identify the right route first and file only what the law actually calls for. Corpseed's role is to assist businesses with regulatory interpretation, documentation, and filing support. Approval, permission, registration, exemption and other regulatory decisions remain with CDSCO and the competent licensing authorities. Businesses reviewing IT, Class A registration, QMS compliance, or the revised Rule 63 position can use Corpseed's medical device compliance services to organise the regulatory review and address gaps before the next filing or regulatory interaction. Key Takeaways The Medical Devices Third Amendment Rules 2026 are targeted amendments rather than a new medical device regulatory system. The most immediate change is for manufacturers and importers of Class A non-sterile and non-measuring devices, because QMS is now expressly included in the self-certification wording under Rules 19H and 19J. The other changes should also be read carefully: IT contains the final amendment to the Medical Devices Rules, 2017. The Ministry notification is dated 14 August 2026 and appears in Gazette No. 678 dated 19 August 2026. Rules 19H and 19J now expressly include the Quality Management System alongside standards. The QMS referred to under the Rules is connected with the Fifth Schedule. The Rule 19 marginal heading is now “Government Medical Device Testing laboratories.” European Union countries have been added to Rule 63(1), Proviso (IV). EU approval alone does not automatically remove Indian regulatory requirements. The notification does not create a new general license or a new registration category. Affected companies should first check applicability and then review the records behind their existing regulatory declarations.

Subject

Summary: The Ministry of Electronics and Information Technology (MeitY) has introduced the Mobile Phone Manufacturing Scheme 2026, or MPMS, to support mobile phone manufacturing in India and encourage the growth of Indian mobile brands. The Scheme Notification was issued on 21 August 2026 under F. No. W/11/2026-IPHW. MPMS has a budgetary outlay of 62,500 crore rupees, including administrative charges, and runs for five financial years, from FY 2026-27 to FY 2030-31. Instead of using one common eligibility and incentive structure for everyone, MeitY has divided the Scheme into two parts. Target Segment 1 (TS1) focuses on mobile phone manufacturing, while Target Segment 2 (TS2) targets qualifying Indian mobile phone brands. For manufacturers, the Scheme is mainly a performance-based financial opportunity. It is not a compulsory licence, certification or manufacturing approval. A company must satisfy the applicable eligibility conditions and meet the required sales or brand-related criteria to benefit from the incentives. Notification at a Glance Particular Details Scheme Mobile Phone Manufacturing Scheme (MPMS) Issuing Authority Ministry of Electronics and Information Technology Division IPHW Division Document Type Scheme Notification File Number F. No. W/11/2026-IPHW Notification Date 21 August 2026 Gazette Gazette of India, Extraordinary, Part I—Section 1 Scheme Budget 62,500 crore rupees, including administrative charges Scheme Period FY 2026-27 to FY 2030-31 Target Segment 1 Incentivizing mobile phone manufacturing Target Segment 2 Supporting Indian mobile phone brands TS1 Minimum Turnover 10,000 crore rupees in FY 2025-26 TS2 Minimum Turnover 1,000 crore rupees in FY 2025-26 Domestic Sourcing Incentive Up to 1.5% of Eligible Sales TS2 Design and R&D Incentive An additional 3% of Eligible Sales Detailed Scheme Guidelines To be issued separately by MeitY Application Deadline Not expressly specified Separate Effective Date Not expressly specified The distinction between the notification date and the performance period deserves attention. The Gazette is dated 21 August 2026, while FY 2026-27 is stated to be the first performance year for TS1. The notification does not separately declare an effective date. Businesses should therefore use the dates exactly as the Scheme describes them rather than treating the publication date as an assumed effective date. The Regulatory Framework MPMS is a Government incentive scheme administered through MeitY. Its purpose differs from that of rules that require a manufacturer to obtain a licence or comply with a compulsory product standard. A company does not become non-compliant simply for not participating in MPMS. Participation matters to manufacturers and brands seeking the financial and other support offered under the Scheme. Three Government-level bodies are particularly relevant to its implementation.  The first is MeitY, which has issued the Scheme and will issue separate implementation guidelines. The second is the Project Management Agency (PMA), which will examine applications, verify eligibility and check eligible claims. The third is the Empowered Committee (EC), which will consider cases examined by the PMA and make recommendations to the competent authority. This structure also means that meeting a turnover condition alone should not be treated as a guarantee of an incentive. The application, eligibility verification, claim examination and approval process still applies. Why Has the Mobile Phone Manufacturing Scheme Been Introduced? MeitY links the Scheme with the growth of India's electronics and mobile phone manufacturing sector. According to the notification, electronics manufacturing has grown sevenfold, and electronics exports have grown elevenfold since FY 2014-15. The Government also states that smartphones became the country's single largest exported product in 2025, overtaking diesel fuel and cut diamonds. Against this background, MPMS has several stated objectives. It aims to: Increase the global competitiveness of India's mobile manufacturing sector, Increase manufacturing scale, Deepen the mobile phone manufacturing supply chain, Raise Domestic Value Addition, or DVA, Build stronger domestic manufacturing capabilities, Support the development of Indian mobile phone brands, and Generate employment. The design of the incentives shows where the Government wants businesses to focus. Manufacturing growth receives support, but additional benefits are attached to domestic component sourcing and, for qualifying Indian brands, domestic design and R&D. MPMS Budget, Duration and Target Segments The total budget for MPMS is 62,500 crore rupees, including administrative charges. The Scheme is described as budget-limited. It also allows the incentive allocation to shift between TS1 and TS2 based on funding requirements and the response received in each Target Segment. The five Scheme years are: FY 2026-27 FY 2027-28 FY 2028-29 FY 2029-30 FY 2030-31 The division between TS1 and TS2 is more than an administrative classification. TS1 is aimed at manufacturers operating at substantial scale and places considerable importance on additional sales. TS2 has a lower turnover threshold but asks Indian brands to meet conditions relating to Indian ownership, management control, intellectual property and in-house design and R&D. This makes Target Segment one of the first questions a business should examine. Who Does the Mobile Phone Manufacturing Scheme Apply To? Direct eligibility under MPMS mainly concerns mobile phone manufacturers, including qualifying Electronics Manufacturing Services companies. Business Category MPMS Relevance Mobile phone manufacturers Can qualify under the relevant Target Segment if conditions are met EMS companies Expressly included among eligible manufacturers Existing mobile brands Can be relevant under TS1 New mobile brands Can enter TS1 after satisfying the prescribed sales condition New mobile brands Specifically covered by TS2 Component manufacturers Mainly indirect beneficiaries of the localisation push, unless otherwise covered Electronics Manufacturing Services (EMS) companies manufacture electronic products for brands and other businesses. MPMS expressly recognises these companies rather than restricting the Scheme only to businesses selling phones under their own brand. Component manufacturers sit in a different position. The Scheme can make domestic component sourcing more attractive, but the notification does not say that every component manufacturer becomes a direct MPMS applicant. TS1: Who Is Eligible for Mobile Phone Manufacturing Incentives? TS1 is meant for large-scale mobile phone manufacturing. A mobile phone manufacturer, including an EMS company, must: Be registered in India, and Have a minimum turnover of 10,000 crore rupees in FY 2025-26. That is the starting eligibility test. Claiming an incentive involves additional conditions. For existing brands, the Scheme sets annual Threshold Sales. For new brands, it first requires the brand to reach a prescribed annual sales level in India. The calculations are made on a brand-by-brand basis, which is particularly relevant when one applicant handles several brands or when a brand uses more than one EMS manufacturer. Existing Mobile Phone Brands For TS1, the Scheme defines an existing brand as one that had domestic manufacturing and sales in FY 2025-26. Such a brand must achieve the specified additional sales each year to be eligible to claim the incentive for that year. This requirement is called Threshold Sales. New Mobile Phone Brands A new brand follows a different route. It becomes eligible under MPMS only after achieving total annual sales of 10,000 crore rupees in India. After reaching that level, it must satisfy a Threshold Sales requirement of 5,000 crore rupees year-over-year to avail the incentive. The notification does not prescribe a minimum number of years for which the new brand must have existed. Annual Sales Thresholds under TS1 For an existing brand, the threshold rises each year. Financial Year Threshold Sales Over and Above FY 2025-26 Total Sales FY 2026-27 5,000 crore rupees FY 2027-28 10,000 crore rupees FY 2028-29 15,000 crore rupees FY 2029-30 20,000 crore rupees FY 2030-31 25,000 crore rupees These figures should not be confused with the 10,000 crore rupees turnover condition for entry into TS1. The turnover requirement checks whether the manufacturer falls within the eligible applicant category. Threshold Sales determine whether the existing brand meets the sales condition for claiming the incentive in a particular Scheme year. By FY 2030-31, an existing brand must therefore reach Threshold Sales of 25,000 crore rupees in addition to its total FY 2025-26 sales. How Are Baseline Sales and Eligible Sales Calculated Under TS1? The actual incentive calculation starts with Baseline Sales. The Scheme states that FY 2026-27 is the first performance year. Baseline Sales For each financial year, Baseline Sales are determined by taking the brand's domestic sales of the Target Segment product in the preceding financial year and adding 15% to that amount. In simple terms: Baseline Sales = Previous financial year's domestic Target Segment sales + 15% The baseline is therefore not fixed permanently at FY 2025-26. It moves from year to year. That makes the sales hurdle more demanding than a structure based on one fixed base year. As the previous year's sales rise, the next year's baseline also changes. Eligible Sales Once the baseline has been established, Eligible Sales are calculated as: Eligible Sales = Total Target Segment sales for the financial year – Baseline Sales The Scheme calculates Baseline Sales, Eligible Sales, and Threshold Sales separately for each brand. This point matters because the incentive is not simply calculated on a company's total turnover. The relevant brand and Target Segment sales have to be identified correctly. TS1 Incentive Rates from FY 2026-27 to FY 2030-31 The TS1 incentive structure is slightly more complicated than a simple flat percentage. It has two parts. First Portion of Eligible Sales For the first portion, paragraph 7.3(a) refers to Eligible Sales up to the difference between: The average sales of FY 2023-24, FY 2024-25 and FY 2025-26, and Baseline Sales for the relevant financial year. The applicable rates reduce gradually over the Scheme period. Financial Year Incentive Rate FY 2026-27 2.75% FY 2027-28 2.75% FY 2028-29 2.50% FY 2029-30 2.50% FY 2030-31 2.25% The wording of this part is technical, and the Gazette does not explain every possible calculation situation in detail. Businesses should therefore be careful about building financial projections around their own interpretation before the detailed Scheme Guidelines are available. Remaining Eligible Sales Eligible Sales remaining over and above the portion described above are subject to another rate. Financial Year Incentive Rate FY 2026-27 5% FY 2027-28 5% FY 2028-29 4.5% FY 2029-30 4.5% FY 2030-31 4% For this reason, calling TS1 simply a "5% incentive scheme" would leave out an important part of the actual calculation. The incentive depends on which portion of Eligible Sales is being considered and on the financial year in which the claim is made. Additional Incentive for Domestic Sourcing of Mobile Components MPMS provides manufacturers with an additional incentive when certain mobile phone components and sub-assemblies are sourced domestically. The maximum additional incentive is 1.5% of Eligible Sales. The break-up is: Component or Sub-Assembly Additional Incentive Display Module 0.30% Camera Module 0.30% Enclosure 0.50% Batteries, including cells 0.20% USB cables, including connectors 0.20% Maximum Total 1.50% This part of MPMS is particularly relevant to manufacturers considering the economics of localisation. Domestic sourcing, however, is not described as a blanket requirement that every applicant must fulfil to participate in MPMS. The additional 1.5% is an extra incentive linked to localisation. That is an important distinction. When Can the Domestic Sourcing Incentive Be Claimed? Simply purchasing one of the listed components in India is not enough to establish eligibility for the additional incentive. The notification says that the relevant component or sub-assembly must be localised for at least 25% of the total mobile phone units sold in a financial year. The additional incentive is paid on a pro rata basis. The Gazette does not specify the detailed evidence manufacturers must provide to prove localisation. For instance, it does not specify in this notification: A supplier certificate format, A domestic-value calculation, An auditor's certificate, A prescribed component-origin declaration, or A particular verification process. Businesses should wait for the official implementation requirements before treating any internally developed documentation process as sufficient. What Is the Incentive Ceiling Under MPMS? The incentive percentages are only one part of the calculation. MPMS also sets a brand-wise incentive ceiling based on the annual commitment submitted by the applicant or brand. The total incentive disbursement is limited to the lower of: The cumulative annual commitment, or The overall budgetary outlay available under the Scheme. This makes it difficult to estimate an applicant's potential benefit merely by multiplying a sales figure by the headline incentive percentage. The annual commitment and the overall Scheme ceiling have to be considered as well. TS2: Supporting Indian Mobile Phone Brands TS2 takes a different approach. Its focus is not simply on producing more phones. The segment is meant to help develop Indian mobile brands that retain ownership, management, intellectual property and design capability within India. It provides both fiscal and possible non-fiscal support. The initial turnover requirement is also much lower than TS1, although businesses must satisfy a more detailed Indian-brand test. Who Is Eligible Under TS2? An applicant under TS2 must be a mobile phone manufacturer, including an EMS company, that: is registered in India, and Has a minimum turnover of 1,000 crore rupees during FY 2025-26. The qualifying brand must then meet all the prescribed Indian-brand conditions. One major difference from TS1 is that Indian brands under TS2 do not have a minimum Threshold Sales requirement. Eligibility of Indian brands under this segment is subject to selection by the Empowered Committee. What Makes a Mobile Phone Brand an "Indian Brand" Under MPMS? A brand does not qualify under TS2 merely because its phones are manufactured in India or because it markets itself as Indian. The Scheme gives five specific conditions. The Brand Must Be Registered or Incorporated in India The brand should be registered or incorporated in India. This creates the basic domestic corporate link required under TS2. Intellectual Property and Trademark Must Be Held in India The intellectual property and trademark associated with the brand must be held within India. Businesses with complicated overseas IP structures may therefore need to examine this condition carefully before assuming TS2 eligibility. Management Control Must Remain With Indian Citizens The brand's management must be in the hands of Indian citizens. This is a separate requirement from shareholding. A company should therefore not look only at its equity ownership while reviewing the Scheme. Indian Citizens Must Hold More Than 51% Shareholding The entity claiming Indian Brand status must have more than 51% shareholding held by Indian citizens. The wording is "more than 51%". It should not be simplified to "51% or more". In-House R&D and Design Must Be in India The brand must also have in-house Research and Development (R&D) and design capabilities in India. This gives TS2 a clear product-development element. The Gazette, however, does not tell businesses exactly how much R&D expenditure, infrastructure, staffing or design activity will be considered sufficient. Those details should come from the official implementation framework rather than assumptions. How Does the One-Year Gestation Period Work Under TS2? TS2 applicants may be given a one-year gestation period. Without that period, FY 2026-27 is the first performance year. If the applicant opts for the gestation period, FY 2027-28 becomes the first performance year. The baseline changes at the same time. For a normal TS2 applicant: Baseline Sales = FY 2025-26 sales For an applicant using the gestation period: Baseline Sales = FY 2026-27 sales The notification does not spell out all the consequences of this one-year shift. In particular, it does not separately explain in this provision whether the gestation option changes the end of the five-year Scheme tenure. That point should be read together with the detailed Scheme Guidelines when they are issued. How Are Eligible Sales Calculated Under TS2? TS2 uses a simpler calculation than TS1. Eligible Sales are calculated by subtracting the applicable Baseline Sales from the brand's total sales for that financial year. Eligible Sales = Total sales during the relevant financial year – Baseline Sales Both Baseline Sales and Eligible Sales are calculated brand-wise. Unlike TS1, the TS2 notification does not add a moving 15% increment to the previous year's baseline. What Incentives Are Available to Indian Mobile Phone Brands? A qualifying Indian brand can potentially access three forms of fiscal incentive under TS2. 5% Incentive on Eligible Sales The main TS2 incentive is 5% of Eligible Sales of mobile phones manufactured in India. The notification does not show a tapered, year-by-year TS2 base rate, unlike the TS1 table. Additional Domestic Sourcing Incentive Indian brands can also benefit from the domestic sourcing incentive. The Scheme states that the calculation criteria for this incentive are the same for both Target Segments. This brings the same component categories, localisation requirement and maximum 1.5% additional incentive into the TS2 structure. Additional 3% for Indian Design and R&D A further 3% incentive on Eligible Sales is available for Indian product design and R&D. This is one of the most commercially interesting parts of TS2 because the Scheme does not look only at where the phone is assembled. It also gives financial weight to where the product is designed and developed. The notification does not yet provide detailed qualification parameters for this 3% incentive. Applicants should therefore avoid defining "Indian design and R&D" until the Government provides the implementation criteria. TS1 vs TS2: What Is the Real Difference? Parameter TS1 TS2 Main focus Increasing mobile phone manufacturing Supporting Indian mobile phone brands Minimum FY 2025-26 turnover 10,000 crore rupees 1,000 crore rupees Threshold Sales Applicable for existing brands No minimum Threshold Sales Baseline Previous year's domestic sales + 15% FY 2025-26 sales, or FY 2026-27 with gestation Main incentive Two-part tapered structure 5% of Eligible Sales Domestic sourcing incentive Up to 1.5% Up to 1.5% Indian design and R&D incentive No separate 3% stated Additional 3% One-year gestation Not stated Available subject to Scheme provision Indian ownership conditions Not prescribed in the same manner Mandatory Indian IP/trademark condition Not prescribed in the same manner Mandatory EC selection of Indian brands Not stated in the same form Applicable TS1 is therefore more closely linked with scale and continued sales growth. TS2 asks a different question: whether the business is genuinely structured as an Indian brand with Indian control, ownership, and IP and product-development capability. Fiscal and Non-Fiscal Support for Indian Mobile Brands The financial incentives under TS2 are clearly identified in the notification. Non-fiscal support is less specific. MeitY states that because fiscal and non-fiscal measures need to work together to build Indian brands, the Government may introduce necessary non-fiscal measures as required. The Empowered Committee can recommend such measures. What those measures will actually be is not stated. There is therefore no basis at present to promise an Indian brand: Procurement preference, Tax relief, Customs benefits, Advertising assistance, Export subsidies, or Market-development support Under this clause. Those benefits should be discussed only if the Government formally introduces them. Can an Applicant Submit More Than One MPMS Application? The notification is direct on this point. An applicant making multiple applications will not be eligible under MPMS. The Gazette does not go further into group-company situations, related entities or common promoter structures. Businesses with complicated corporate arrangements should therefore wait for more detailed guidance rather than assuming how the restriction will apply across an entire group. Can MPMS Applicants Participate in Other Government Schemes? Yes, at least from the standpoint of basic eligibility. The notification states that eligibility under MPMS does not affect eligibility under any other Scheme, and vice versa. That does not necessarily mean two Government incentives can always be claimed on the same sale, investment or expenditure. Those questions depend on the conditions of MPMS and the other Scheme involved. The safer reading is that participation in one Scheme does not automatically disqualify a business from another. How Will MPMS Approval and Incentive Disbursement Work? Incentives are to be disbursed to mobile phone manufacturers, including EMS companies, in India. The sales calculations behind those incentives are nevertheless performed for the brand. Applicants can submit claims quarterly, provided they meet the eligibility criteria. The Scheme Notification does not provide the entire claim workflow. Instead, it states that the approval and disbursement procedures will be handled under the Scheme Guidelines. For businesses preparing early, this distinction matters. There is no reason to rely on unofficial document lists, filing portals, application dates or processing periods until MeitY publishes them. What If One Brand Uses Several EMS Manufacturers? This situation is specifically covered. Where one brand gets its phones manufactured through more than one EMS Company, that brand must provide the necessary certification for: Baseline Sales, Threshold Sales, and Eligible Sales. The logic is fairly practical. MPMS measures performance at the brand level, even when manufacturing is divided among several companies. Sales information, therefore, needs to be consolidated in a way that prevents the same brand's performance from being counted inconsistently across different EMS manufacturers. The notification does not identify the certifying person, the prescribed certificate, or the required format. Those details should come from the Scheme Guidelines. Role of the Project Management Agency MPMS will be implemented through a Project Management Agency (PMA). The PMA is not simply a payment-processing body. Its role covers much of the Scheme's initial administration. According to the notification, its responsibilities include: Appraising applications, Verifying eligibility, Examining claims eligible for incentive disbursement, Compiling Scheme progress and performance information, Collecting data relating to incremental investment and Eligible Sales, and Providing secretarial, managerial and implementation support. MeitY may also assign further responsibilities to the PMA from time to time. The reference to incremental investment in the PMA's data work should not be read as an invented minimum investment threshold. The eligibility clauses reproduced in this notification do not prescribe such a figure. What Does the Empowered Committee Do? The Secretary, MeitY, will chair the Empowered Committee (EC). Its members will come from: NITI Aayog, Department of Economic Affairs, Department of Expenditure, Department of Revenue, Department for Promotion of Industry and Internal Trade, and Directorate General of Foreign Trade. Members must be at least of Joint Secretary Rank. The Committee will consider applications that the PMA has found eligible and recommend suitable cases to the competent authority. It performs a similar review for claims submitted for incentive disbursement. The EC also has an ongoing review function. It can examine the performance of eligible companies in areas such as production, employment generation and value addition. Where changes are needed for implementation, the Committee may recommend amendments to the Scheme. Can New Mobile Products Be Included Later? MPMS has been written with technological change in mind. The notification allows the Empowered Committee to consider adding new or advanced products under a Target Segment based on technological advancement in the mobile phone sector. No future products are named in the Gazette. Businesses should therefore treat this as an enabling provision rather than assuming that any particular emerging device or technology is already covered. How Will MPMS Affect Mobile Manufacturers and the Supply Chain? The impact will not be the same for every business. Large Mobile Phone Manufacturers For a large manufacturer, TS1 can provide a meaningful production-linked financial benefit, but the sales hurdles are high. A business has to consider: 10,000 crore rupees FY 2025-26 turnover eligibility, Brand-wise Threshold Sales, A moving Baseline Sales calculation, The two-part incentive rate, Localisation requirements for additional incentives, and Quarterly claim readiness. The commercial question, therefore, is not simply "Are incentives available?" It is "Can this brand realistically generate Eligible Sales after meeting the Scheme's thresholds and baseline rules?" EMS Companies EMS businesses have been expressly brought into the Scheme. This matters because a large part of modern mobile production can take place through contract manufacturing rather than a brand operating every factory itself. The Scheme recognises that model while continuing to calculate sales at the brand level. Indian Mobile Brands TS2 gives Indian brands a route that does not require the same 10,000 crore rupees turnover entry threshold as TS1. In return, the brand must demonstrate a much stronger Indian connection through ownership, control, and IP and product development capabilities. For a qualifying brand, the combination of: 5% Eligible Sales incentive, Up to 1.5% domestic sourcing incentive, and 3% Indian design and R&D incentive Makes TS2 materially different from a basic manufacturing subsidy. Component Suppliers Suppliers of display modules, camera modules, enclosures, batteries, cells and USB cable assemblies may see greater interest from manufacturers trying to improve localisation. That is a likely commercial effect, not a guaranteed outcome for the Government. Whether a supplier gains new orders will still depend on technical qualification, pricing, production capacity, quality and commercial decisions made by handset manufacturers. Finance and Compliance Teams Companies considering MPMS will need reliable internal data. Brand-level sales numbers, turnover, manufacturing arrangements and sourcing information can directly affect eligibility and incentive calculations. TS2 applicants will also need clarity on corporate ownership, IP, trademarks, management control and R&D arrangements. This is where poor internal records can become a practical problem, even if the underlying business appears eligible. What Are the Potential Benefits of MPMS? For businesses that fit the Scheme, the benefits are fairly clear. First, incentives are linked to actual manufacturing performance. A manufacturer that produces in India and generates Eligible Sales may access financial support according to the applicable rate. Second, localisation receives an extra reward. The additional incentive of up to 1.5% gives manufacturers another reason to examine domestic component sourcing. Third, Indian brands receive separate treatment. They are not simply placed inside the same framework designed for very large manufacturing companies. Fourth, product development receives financial recognition. TS2 gives an additional 3% incentive for Indian design and R&D. Fifth, EMS manufacturing is recognised. The Scheme acknowledges that a brand may rely on specialist manufacturing companies. None of these benefits is automatic. Actual payment depends on Scheme eligibility, performance, verification, approval, applicable ceilings and future procedural requirements. What Could Be Difficult for Businesses? MPMS is financially attractive on paper, but some conditions will require careful planning. TS1 Is Designed for Scale The 10,000 crore rupees turnover threshold already limits the pool of potential TS1 applicants. The annual Threshold Sales then rise from 5,000 crore rupees above FY 2025-26 sales to 25,000 crore rupees above the same base by FY 2030-31. This makes TS1 difficult to treat as an easy incentive for smaller manufacturers. The Baseline Keeps Moving For TS1, Baseline Sales are based on the previous year's domestic sales plus 15%. A company cannot therefore rely on a fixed historical benchmark throughout the Scheme. Localisation Needs to Reach a Meaningful Level A manufacturer cannot claim the extra domestic-sourcing incentive merely because it has started buying a small number of components locally. The 25% unit condition has to be considered. TS2 Requires More Than Indian Incorporation An Indian-registered company may still fall short if its IP, management control, shareholding, or in-house R&D structure does not meet the stated conditions. Important Procedural Details Are Still Outside the Notification The Gazette provides the policy structure but leaves many practical steps to be detailed in separate Guidelines. Businesses should therefore be careful about committing to an application strategy based on assumptions. Is MPMS a Benefit or an Additional Business Burden? The Scheme is voluntary and incentive-based, so describing it simply as an additional compliance burden would not be accurate. At the same time, claiming a substantial Government incentive naturally comes with performance and verification conditions. What Businesses May Gain What They Need to Manage Production-linked financial incentive High turnover and sales conditions Up to 1.5% domestic sourcing incentive Localisation threshold Separate route for Indian brands Ownership and control tests Additional 3% for Indian design and R&D In-house capability requirement Five-year Scheme period Ongoing performance tracking Recognition of multi-EMS manufacturing Brand-level certification Possible non-fiscal support Details not yet defined For businesses already operating at the required scale, TS1 may provide a useful way to support further production growth. TS2 may be particularly relevant for Indian brands that already have the ownership, IP and product-development structure described in the Gazette. The harder question will be commercial viability. A company still needs to compare the potential incentive with the sales growth, localisation effort, internal controls and investment decisions required to earn it. Business Opportunities Created by MPMS 2026 MPMS is primarily a mobile manufacturing incentive, but its commercial effects can extend further into the supply chain. Mobile Phone Manufacturing Eligible manufacturers have a direct financial reason to expand production and increase qualifying sales. EMS Manufacturing Contract manufacturers can participate in the Scheme structure where the eligibility conditions are met. This may make large-scale EMS capacity strategically important for brands that do not manufacture all phones themselves. Component Localisation The Scheme specifically identifies: Display modules, Camera modules, Enclosures, Batteries and cells, and USB cables and connectors. Indian businesses manufacturing these parts may find themselves relevant to handset makers reviewing localisation plans. Indian Mobile Brands TS2 gives qualifying domestic brands a separate policy route, particularly where they control their IP and maintain product design and R&D capabilities in India. R&D and Product Design The additional 3% TS2 incentive makes Indian design and R&D commercially relevant for the incentive calculation, rather than treating them as background activities. The Scheme does not guarantee new orders, market share or revenue in any of these areas. These are business opportunities that may arise from the incentive design. Scheme Guidelines Will Be Important Before Applications Begin The Gazette sets out the core structure of MPMS, but it is not the final procedural manual. MeitY expressly states that Scheme Guidelines for implementation will be issued separately. That means businesses still need official details on several practical matters. The notification itself does not presently give: An application opening date, An application closing date, An application portal, Prescribed application forms, A complete document list, Detailed localisation evidence requirements, The certification format for multi-EMS brands, The method for proving Indian design and R&D, Application fees, Claim-processing timelines, or A complete disbursement workflow. These should not be filled in from older schemes or unofficial sources. There are also areas where the Guidelines may help businesses understand the Gazette more clearly, including the practical calculation under TS1 paragraph 7.3(a) and the working of the TS2 gestation period within the Scheme tenure. Can MPMS Change During Its Five-Year Period? Yes. The notification allows MPMS and its Guidelines to be reviewed and amended from time to time. The areas that can be reconsidered include: Products covered under TS1 and TS2, Applicable incentive rates, Scheme tenure, Sales, Gestation period, and Other matters considered necessary for effective implementation. The Empowered Committee may recommend such amendments, subject to approval by the Minister of Electronics and Information Technology. Manufacturers planning around MPMS should therefore monitor subsequent MeitY notifications and Guidelines rather than relying solely on the original Gazette. What Should Mobile Manufacturers and Indian Brands Do Now? There is no reason to wait until an application window opens before checking whether MPMS is commercially relevant. Businesses can start with the information already available. Identify whether TS1 or TS2 is relevant. A large manufacturer and an Indian brand may face very different eligibility tests. Check FY 2025-26 turnover carefully. The basic threshold is 10,000 crore rupees for TS1 and 1,000 crore rupees for TS2. Review sales at the brand level. TS1 applicants should understand their FY 2025-26 position, annual Threshold Sales and moving baseline before estimating possible incentives. Map domestic component sourcing. Manufacturers interested in the extra 1.5% should check the listed components and the extent to which sourcing is already localised. Test the Indian-brand conditions for TS2. Incorporation alone is not enough. IP, trademarks, management control, shareholding, R&D and design all need attention. Review multi-EMS manufacturing arrangements. Brands using more than one EMS Company should prepare for consolidated brand-level sales certification. Keep the financial model conservative. Do not treat the maximum headline rates as guaranteed incentive receipts before applying the correct Eligible Sales rules and ceiling. Track Meet’s Scheme Guidelines. Application procedures, evidence requirements and claim mechanics should be taken from the final official instructions. How Corpseed Can Help With MPMS A first reading of MPMS may make eligibility look like a turnover question. In practice, there is more to review. For TS1, businesses need to understand the relationship between turnover, Threshold Sales, Baseline Sales, Eligible Sales and incentive rates. For TS2, the assessment covers areas such as Indian shareholding, management control, intellectual property, trademarks, domestic R&D, and product design. Corpseed can provide PLI scheme consulting services for manufacturers and brands that want to assess their position before moving into the formal application or claim stage. Relevant support can include: MPMS eligibility assessment: Checking whether the applicant's business profile fits TS1 or TS2. Target Segment review: Comparing the company's manufacturing and brand structure with the conditions applicable to the relevant segment. PLI eligibility assessment: Reviewing turnover, brand status and Scheme-specific qualifying conditions before an application is prepared. Sales-data review: Helping organise Baseline Sales, Threshold Sales and Eligible Sales information for internal assessment and future claim preparation. Indian-brand eligibility review: Assessing incorporation, Indian shareholding, management control, IP, trademarks and in-house R&D/design position under TS2. Domestic sourcing assessment: Reviewing the listed components, localisation position and conditions attached to the additional sourcing incentive. Multi-EMS readiness support: Helping organise brand-level sales and manufacturing information where a brand uses several EMS companies. Scheme Guideline review and application support: Interpreting later MeitY Guidelines and assisting with the formal process once application and claim procedures are officially notified. Incentive claim support: Helping businesses organise information for claims based on the final Government requirements. Ongoing regulatory compliance services: Supporting electronics manufacturers with related regulatory and documentation matters where separately applicable. The purpose of professional support is to help a business determine whether the Scheme fits its actual operating structure and to organise the information needed for an accurate application. It cannot guarantee selection by the Empowered Committee, approval by the competent authority or payment of a particular incentive amount. Mobile phone manufacturers, EMS companies and Indian brands considering MPMS can seek PLI scheme consulting services to review their eligibility, sales structure, localisation position and application readiness against the official Scheme conditions. Key Takeaways The Mobile Phone Manufacturing Scheme 2026 offers substantial financial support, but it has been designed for specific categories of manufacturers and Indian mobile brands rather than the entire electronics sector. The practical points businesses should remember are: MPMS has a budget of 62,500 crore rupees and runs from FY 2026-27 to FY 2030-31. TS1 requires a turnover of at least 10,000 crore rupees in FY 2025-26. Existing TS1 brands must satisfy rising annual Threshold Sales. TS1 uses a moving Baseline Sales calculation based on the previous year's domestic sales plus 15%. Domestic sourcing of specified components can provide an additional incentive of up to 1.5%. TS2 has a lower 1,000 crore rupees turnover threshold, but qualifying brands must meet Indian ownership, control, and IP and R&D conditions. Eligible TS2 brands receive a 5% base incentive, with an additional 3% available for Indian design and R&D. Applicants making multiple applications are not eligible. Quarterly claims are permitted subject to the Scheme conditions. Detailed application and disbursement requirements will depend on separate MeitY Scheme Guidelines.

Subject

Summary: The Ministry of Commerce and Industry has notified the Agricultural and Processed Food Products Export Development Authority (Adjudication of Penalties) Rules, 2026  The Rules came into force from the date they were published in the Official Gazette. They have been issued under clauses (ma) and (mb) of Section 32(2), read with Section 25A of the Agricultural and Processed Food Products Export Development Authority Act, 1985. For businesses, the important point is not that a fresh penalty has suddenly been introduced for every APEDA exporter. That is not what this notification does. The Rules mainly explain how penalty adjudication will be carried out when a matter covered by Section 25A comes before the adjudicating officer. They set out the procedure for a show-cause notice, response, inquiry, hearing, evidence, written order and appeal. This makes the process much easier to follow. At the same time, it means a business receiving an APEDA notice will need to pay close attention to dates, records and the exact allegation made against it. Notification at a Glance Particular Details Issuing Ministry Ministry of Commerce and Industry Notification G.S.R. 741(E) Notification Date 19 August 2026 Rules Agricultural and Processed Food Products Export Development Authority (Adjudication of Penalties) Rules, 2026 Parent Law Agricultural and Processed Food Products Export Development Authority Act, 1985 Legal Basis Section 32(2)(ma) and (mb), read with Section 25A Effective Date Date of publication in the Official Gazette Main Subject Procedure for adjudication of penalties Adjudicating Officer Officer appointed by the Chairman under Section 25A Appellate Authority Chairman of the Authority designated under Section 25A(2) Minimum Show-Cause Period Not less than 7 days from service Inquiry Completion Period Within 6 months from issuance of notice Normal Appeal Period 30 days from receipt of order Appeal Defect Rectification 15 days Appeal Disposal Period 60 days from filing Prescribed Forms Form-I and Form-II File Number F. No. 6/6/2024-EP (Agri. IV) The notification gives businesses a proper procedural map. Once a matter enters adjudication, the Rules now make it clearer who will issue the notice, how the matter will be heard and what options remain after the order is passed. What Exactly Do the APEDA Adjudication Rules, 2026 Do? The easiest way to understand the notification is to separate the underlying violation from the procedure used to deal with that violation. The APEDA Act contains the legal framework. The 2026 Rules deal mainly with procedure. They explain what happens once a complaint concerning a relevant contravention reaches the adjudicating officer. That process may include: issue of a show-cause notice; explanation of the alleged contravention; submission of a reply; decision on whether an inquiry should be held; appearance before the adjudicating officer; production of documents and evidence; hearing of the matter; passing of a written order; service of that order; and appeal before the appellate authority. This distinction matters because the arrival of a show-cause notice does not mean that the business has already been found guilty. A notice starts the process. The conclusion comes later, after the response and evidence have been considered. What Is the Legal Framework Behind the Rules? The 2026 Rules do not work independently. They sit within the larger structure of the Agricultural and Processed Food Products Export Development Authority Act, 1985. APEDA Act, 1985 The APEDA Act is the parent legislation. Where a business wants to understand the actual contravention alleged against it, the relevant provision of the Act remains important. The 2026 Rules mainly tell the authority and the affected person how the adjudication process will move forward. Section 25A Section 25A forms the basis of the adjudication mechanism referred to in these Rules. The Rules define an adjudicating officer as an officer appointed by the Chairman under Section 25A. They also identify the appellate authority as the Chairman of the Authority designated under Section 25A(2). Section 32 The Central Government issued these Rules by exercising the rule-making power available under clauses (ma) and (mb) of Section 32(2), read with Section 25A. So, in an actual case, the Rules and the relevant provision of the APEDA Act have to be read together. Who Can Be Involved in an APEDA Adjudication Proceeding? The notification uses several terms that are easy to confuse. Their roles are different. Complainant A complainant is an aggrieved person who makes a complaint before the adjudicating officer. Person Against Whom Proceedings Are Started This is the person whose alleged contravention is being examined. The Rules give this person an opportunity to explain the position, provide records and appear before the adjudicating officer. Adjudicating Officer The adjudicating officer conducts the inquiry. The officer can examine the matter, hear the person concerned, call for documents or evidence and pass an order where the requirements of the Act are met. Authorised Representative The person facing proceedings does not necessarily have to appear alone. The Rules allow appearance through a duly authorised representative. Appellant If a person is aggrieved by the adjudicating officer's order and chooses to challenge it, that person becomes the appellant. Appellate Authority The appeal goes before the appellate authority identified under the Rules. This structure is useful because it makes the role of each person clear from the start. What Is New About the 2026 Procedural Framework? The notification now puts a detailed sequence in writing. Rather than trying to create an old-versus-new comparison where the notification itself does not fully explain the earlier procedural position, it is more accurate to look at what the 2026 Rules now expressly provide. Area What the 2026 Rules Provide Why It Matters Initial notice Form-I show-cause notice Person gets formal notice of allegation Response time At least 7 days from service Minimum preparation time is protected Appearance Personal or authorised representation Business can arrange representation Evidence Relevant documents and evidence may be produced Records can support the response Non-appearance Inquiry may proceed in absence Ignoring notice may not stop proceedings Inquiry period 6 months from issuance of notice Broad completion timeline is fixed Appeal Form-II Formal challenge route exists Appeal deadline 30 days from receipt of order Receipt date becomes important Defective appeal 15 days to correct defects Opportunity to fix filing problems Appeal decision Within 60 days from filing Defined appellate timeline The strongest feature of the Rules is therefore clarity. A business can now see the major stages of the process instead of dealing with a notice without understanding what may happen next. How Does an APEDA Penalty Inquiry Start? Rule 3 deals with the inquiry. The process begins when the adjudicating officer receives a complaint concerning a contravention covered by the relevant provisions. The officer then issues a notice in Form-I. That notice asks the person concerned to explain why an inquiry should not be held. Two things are especially important at this stage. First, the notice must indicate the nature of the alleged contravention. Second, the time given for showing cause cannot be less than seven days from the date of service. This does not mean every notice will provide exactly seven days. Seven days is the minimum. The notice may give a longer period. A business receiving Form-I should therefore read the actual deadline written in the notice instead of assuming a standard seven-day response period. What Happens After the Show-Cause Reply? Once the person submits an explanation, the adjudicating officer considers it. If the officer believes, after looking at that explanation, that an inquiry is still required, another notice may be issued asking the person to appear on a specified date and time. The person may appear: Personally or through a duly authorised representative. This stage is where the difference between a notice and a finding becomes important. Form-I is not a penalty order. It is an opportunity to explain the position before the matter moves further. That may sound obvious, but in practice businesses sometimes react to regulatory notices as if the final decision has already been made. The structure of these Rules shows that there are several stages before an adjudication order can be passed. How Will the Hearing Take Place? On the date fixed for the inquiry, the adjudicating officer must explain the alleged contravention to the person or the authorised representative. The relevant provision of the APEDA Act connected with the allegation must also be explained. This gives the affected person a clearer understanding of what exactly is being examined. The hearing is therefore not just about appearing before the authority. It is the stage at which the allegation, the relevant legal provision and the supporting material come together. What Type of Evidence Can Be Produced? The person facing proceedings must be given an opportunity to produce documents or evidence considered relevant to the inquiry. The Rules do not give one universal list of documents that will apply in every case. That makes sense because the relevant records will depend on the alleged contravention. For one matter, commercial or export records may be important. In another, correspondence, internal records or other regulatory documents may be more relevant. The practical lesson is simple: a business should identify documents connected to the specific allegation rather than collecting large amounts of unrelated material. The adjudicating officer can also require a person who knows the facts of the case to attend and give evidence. The officer may require production of any document considered useful or relevant to the inquiry. Can the Hearing Be Adjourned? Yes, but the Rules do not leave adjournment completely open-ended. Where necessary, the hearing may be adjourned. Rule 3(5) refers to the next date being not later than fifteen days from the first date and allows adjournment up to the limit stated in the Rule, which refers to a maximum of three dates. This is worth keeping in mind. A business should not prepare on the assumption that a matter can simply be postponed several times if its documents are not ready. Where records, explanations or representatives are required, preparation should begin as soon as the notice is received. What Is the Position on the Bharatiya Sakshya Adhiniyam, 2023? The Rules contain a specific provision on evidence. While taking evidence during the inquiry, the adjudicating officer is not bound to observe the provisions of the Bharatiya Sakshya Adhiniyam, 2023. This sentence needs to be read carefully. It does not mean that the Bharatiya Sakshya Adhiniyam has no relevance whatsoever to every APEDA matter. The notification simply says that the adjudicating officer is not bound to follow its provisions while taking evidence during this inquiry process. For businesses, the more practical point is that relevant records and a clear factual explanation still matter, even though the inquiry is not required to follow every evidentiary rule in the same manner as a regular court proceeding. What Happens if the Person Does Not Appear? Ignoring the hearing does not stop the proceeding. If the person fails, neglects or refuses to appear as required under Rule 3(3), the adjudicating officer may continue with the inquiry in that person's absence after recording reasons. That does not mean a penalty automatically follows. It does mean that the authority does not have to keep the matter pending simply because the person has not attended. This makes hearing notices particularly important. If a business cannot attend in the expected manner, the issue should be dealt with promptly rather than allowing the date to pass without action. How Is the Final Adjudication Order Passed? After considering the available evidence, the adjudicating officer decides whether the contravention has been established. If the officer is satisfied that the person has committed the contravention, a penalty may be imposed under the applicable provisions of the APEDA Act through a written order. The order has to identify: the provision of the Act that has been contravened; and the reasons for imposing the penalty. The Rules do not create one common penalty amount for every proceeding. The actual penalty, where one is imposed, depends on the applicable provision of the Act and the facts of the case. Businesses should therefore be careful about articles or summaries that quote a single "APEDA penalty" without connecting it to the relevant statutory provision. The Rules also require the person against whom the inquiry was held to receive a copy of the order and other copies of the proceedings free of cost. How Long Can the Adjudication Proceeding Continue? Rule 3 gives a clear broad timeline. The adjudicating officer is required to complete the proceeding within six months from the issuance of the notice to the person against whom the inquiry is being held. That six-month period is different from the other time limits in the Rules. For example: the show-cause response period is at least seven days; an appeal ordinarily has to be filed within 30 days from receipt of the order; and the appeal is to be disposed of within 60 days from filing. These periods serve different purposes and should not be mixed together. Major Timelines Businesses Should Track Stage Period Starting Point Show-cause reply Not less than 7 days Date of service Inquiry completion 6 months Issuance of notice Appeal filing 30 days Receipt of adjudication order Correction of defective appeal 15 days Intimation of defects Reply after appeal admission Up to 30 days As specified in appellate notice Appeal disposal 60 days Date of filing of appeal Rule 5 also permits extension of periods mentioned in the Rules where there is a reasonable cause for delay or failure to act and reasons are recorded in writing. That power should not be confused with a guaranteed right to extra time. Until an extension is actually allowed, the safer approach is to work to the original deadline. How Can APEDA Notices and Orders Be Served? The Rules recognise several ways of serving a notice or order. Personal Delivery The document may be delivered or tendered directly to: the person concerned; or an authorised representative. Electronic or Postal Service The notice or order may also be sent through: electronic form; or speed post with registration and proof of delivery. The Rules refer to the person's place of residence, last known residence and relevant business or work address depending on the circumstances. Affixing the Notice at the Premises If service cannot be made using the earlier specified methods, the notice or order may be affixed on the outer door or another conspicuous part of the premises described in the Rules. This provision makes outdated contact information a real practical risk. A business may have a perfectly good case on the merits but still create unnecessary trouble if its regulatory correspondence is not monitored. That is why official addresses and communication channels should be kept under review. What Does "Electronic Form" Mean? The Rules link the expression "electronic form" to the meaning given under Section 2(1)(r) of the Information Technology Act, 2000. The notification does not say that electronic service means only email. It is therefore better to use the broader term used in the Rules rather than narrowing it unnecessarily. How Can an APEDA Adjudication Order Be Challenged? A person aggrieved by the adjudicating officer's order may file an appeal before the appellate authority. The prescribed format is Form-II. The normal appeal period is 30 days from the date of receipt of the order. The words "receipt of the order" are important. The appeal period should not automatically be counted from: the date of the notification; the date of Form-I; the hearing date; or simply the date printed on the adjudication order. The Rule links the 30-day period to receipt. Can an Appeal Be Filed After 30 Days? The Rules allow some flexibility. The appellate authority may admit an appeal even after the normal 30-day period where it is satisfied that the appellant was prevented by sufficient cause from filing the appeal in time. This is discretionary. A late appellant cannot assume that the delay will be accepted. For that reason, the existence of this proviso should not be used as a reason to postpone appeal preparation. What Has to Be Filed with the Appeal? The appeal should be accompanied by: a copy of the order issued by the adjudicating officer; a clear statement of facts being appealed against; the grounds of appeal; and the relevant section of the APEDA Act. This is separate from the fields appearing in Form-II itself. The Rules do not provide a long generic checklist of additional documents for every appeal, so businesses should avoid treating unrelated document lists found online as mandatory requirements. The supporting material should match the case. How Can the Appeal Be Submitted? The Rules allow several filing methods. The appellant may file: personally; through a duly authorised representative appointed in writing; through speed post with registration and proof of delivery; or through electronic form. There is one particularly important point for postal appeals. An appeal sent by post is treated as filed on the day it is received by the appellate authority, not simply on the day it is dispatched. A business using post should therefore allow enough delivery time instead of sending the appeal at the last moment. What if the Appeal Has a Mistake or Missing Information? A defective appeal is not necessarily rejected immediately. If the appellate authority finds defects during scrutiny, it must inform the appellant and allow 15 days to correct them. If the defects are not corrected within that period, the authority may decline to register the appeal. The reasons for doing so must be recorded in writing. The Rules further provide for communication of that order to the appellant within seven days. This gives the appellant a chance to correct an incomplete filing, but that opportunity also comes with a fixed time limit. What Happens After the Appeal Is Accepted? Once the appeal is admitted, a copy is served on the person against whom the appeal is sought. That person is also given a notice asking for a reply. The time specified for that reply cannot exceed 30 days. The appellate authority can call for records of the original proceeding from the adjudicating officer. After giving the parties an opportunity of being heard, the appellate authority may pass the order it considers reasonable. The appeal is to be disposed of within 60 days from the date of filing. Can the Timelines Be Extended? Rule 5 gives the adjudicating officer and appellate authority power to extend periods specified in the Rules. An extension may be given where there is a reasonable cause for the delay or failure to act. The reasons must be recorded in writing. This provision adds some flexibility, but it should not be treated as a fallback plan. The better approach is to meet the stated time limit wherever possible and seek an extension only where there is a genuine reason. What Is Form-I and Form-II? The two forms are short, but they serve very different purposes. Point Form-I Form-II Purpose Show-cause notice Appeal Relevant Rule Rule 3(1) Rule 4(1) Used By Adjudicating officer Appellant Stage Beginning of adjudication After adjudication order Main Use Calls for explanation before inquiry Challenges adjudication order Form-I: Show-Cause Notice Form-I is the notice issued at the beginning of the process. It refers to: the alleged contravention; relevant section of the APEDA Act; place or context of the alleged contravention; period available for showing cause; and possible inquiry under Section 25A. The form leaves the number of days blank. That blank has to be read together with Rule 3(1), which says the response period cannot be less than seven days from service. Form-II: Appeal Form-II is used for filing an appeal. It asks for: name of the appellant; correspondence address; contact number; email; grounds of appeal; date of the adjudicating officer's order; statement of facts; declaration; signature and date; and name of the appellant. The form also refers to enclosing a copy of the adjudicating officer's order. What Opportunities Does the Person Facing Proceedings Get? The Rules give the affected person several opportunities to participate in the process. These include: receiving notice of the alleged contravention; knowing what violation has been alleged; submitting a show-cause response; appearing personally; appearing through an authorised representative; producing relevant documents and evidence; participating in the hearing; receiving a reasoned written order; obtaining copies of the proceeding; filing an appeal; and correcting defects in the appeal within the permitted period. These procedural protections do not decide the final result. They make sure that the matter follows an identified process before and after the adjudicating officer's decision. How Will the Rules Affect Exporters and Other APEDA-Regulated Businesses? For most businesses, the Rules will not create a new monthly, quarterly or annual compliance filing. The impact becomes much more practical when a business actually receives a notice. Exporters An exporter facing proceedings will need to quickly identify: what happened; which transaction or activity is involved; which section has been cited; who handled the matter internally; and what records support the company's position. Compliance Teams Compliance teams may need to take ownership of: deadline tracking; internal fact collection; document retrieval; communication with management; and coordination with representatives. Legal Teams Legal review becomes particularly important where the allegation, statutory provision and available records do not clearly match. The legal team may need to separate what the Act requires from what the notice alleges. Management Senior management may not need to handle every regulatory notice personally, but material adjudication matters should not remain buried in an operational inbox. Someone should have clear ownership. Documentation and Export Teams These teams may be asked to retrieve older records, correspondence or transaction documents. Businesses with scattered record systems may find this stage more difficult than businesses where documents are organised and searchable. What Are the Practical Benefits of the New Procedure? The Rules offer a few clear advantages from a process point of view. 1. The Allegation Has to Be Identified A person should know the nature of the contravention being alleged. 2. A Minimum Response Period Is Available The show-cause period cannot be less than seven days from service. 3. Evidence Can Be Produced The business has an opportunity to support its explanation with relevant material. 4. Representation Is Allowed The person may appear through a duly authorised representative. 5. Penalty Orders Must Give Reasons Where a penalty is imposed, the order must identify the relevant provision and reasons. 6. An Appeal Route Is Available A formal mechanism exists for challenging the adjudicating officer's order. 7. Defective Appeals Can Be Corrected The appellant gets time to rectify defects rather than facing immediate rejection in every case. 8. Timelines Are Stated The Rules give broad time limits for adjudication and appeal. These features make the procedural path easier to understand. They do not guarantee a favourable outcome, but they make it clearer what the affected person can expect at each stage. What Difficulties Could Businesses Face? The main pressure point is likely to be preparation time. Where a business receives a notice providing a period close to the seven-day minimum, it may need to gather facts quickly. This can become difficult where: the transaction is old; records are stored across departments; the employee involved has left; the legal issue is technical; multiple offices handled the matter; or management approval is needed before filing a response. Appeals can create similar pressure. The 30-day period may appear comfortable at first, but time can be lost while waiting for an internal decision on whether the order should be challenged. For smaller exporters, the issue may be less about the Rule itself and more about having enough internal people to handle a regulatory proceeding while continuing normal business operations. Is This the Right Decision or an Additional Compliance Burden? The answer depends on whether the business is actually involved in an adjudication proceeding. Why the Framework Is Helpful From a regulatory-process perspective, having written procedural rules is useful. Businesses now have clearer answers on matters such as: notice; response period; hearing; evidence; authorised representation; written orders; appeals; and timelines. A reasoned order and an appeal route are particularly useful because the affected person can understand why the authority reached its decision and decide whether there is a basis to challenge it. Where the Burden Appears The burden begins once proceedings start. A notice may require quick fact-finding, internal coordination and document collection. Missing a hearing does not stop the inquiry. A late appeal may require the appellant to establish sufficient cause. A defective appeal must be corrected within the period allowed. For smaller businesses, these procedural requirements may require professional support simply because they do not maintain a separate legal or compliance team. The Practical View On balance, the Rules do not look like a fresh everyday compliance burden imposed on all APEDA exporters. They are better understood as a formal procedure for cases where penalty adjudication has already become relevant. For a business that never enters such a proceeding, there is no routine Form-I or Form-II filing merely because the Rules have been notified. For a business that does receive a notice, however, the Rules make timing, records and response quality much more important. What Mistakes Should Businesses Avoid? The most avoidable problems are usually procedural rather than complicated. Businesses should be careful not to: ignore a Form-I notice; treat the notice as if it were already a final order; miss the response date; respond without first understanding the allegation; submit unsupported statements where records are available; miss the hearing; assume non-appearance will stop proceedings; lose proof of when an order was received; calculate the appeal period from the wrong date; send a postal appeal too close to the deadline; file Form-II without the required information; ignore an intimation about defects; or assume an extension will be granted automatically. A simple internal tracker can prevent many of these problems. What Should a Business Do After Receiving an APEDA Show-Cause Notice? Step 1: Record When the Notice Was Received Write down the date and mode of service. Keep the envelope, electronic communication or other available proof. Step 2: Read the Allegation Before Drafting Anything Identify: the section cited; the allegation; the relevant transaction or activity; dates involved; and person or department connected with it. Step 3: Mark the Reply Deadline Check the deadline stated in the notice. Do not simply count seven days unless the notice actually gives seven days. Step 4: Find the Relevant Records Pull together documents connected with the allegation. Avoid collecting unrelated papers simply to make the response look detailed. Step 5: Verify the Internal Facts Speak to the relevant team members. Where there are differences between someone's memory and the written record, resolve them before drafting the reply. Step 6: Prepare a Clear Response A good response should answer the allegation directly. Long background explanations that do not address the actual issue can make the submission harder to understand. Step 7: Prepare for the Hearing If the adjudicating officer decides to conduct an inquiry, identify who will appear. If a representative will attend, check the authorisation requirements in time. Step 8: Keep Track of the Final Order Record when the order is received. That date may become important if an appeal is considered. Step 9: Decide on Appeal Without Delay If the order needs to be challenged, review the 30-day period and Form-II requirements early. Waiting for the last few days creates unnecessary risk. APEDA Adjudication Checklist Item What to Check Priority Show-cause notice Date and method of service Immediate Alleged violation Section and nature of allegation Immediate Reply deadline Exact period stated in notice Immediate Records Documents linked to the allegation High Representative Whether authorisation is required High Hearing Date and time High Order Reasons and provision cited High Order receipt Proof of date received Immediate Appeal 30-day normal filing period Immediate Form-II Required facts and order copy High Defects 15-day rectification period High The checklist is a practical internal aid. It does not replace the notice itself or the relevant provisions of the Act. How Corpseed Can Help? An APEDA adjudication matter usually cannot be handled properly by looking at the notification alone. The allegation, section cited, business records and stage of proceedings all matter. Corpseed can support businesses through the following areas. APEDA Notice Review Corpseed can review the notice to help identify: the allegation made; relevant provision cited; current stage of proceedings; response period; and immediate documentation requirements. Show-Cause Response Support Support can include: organising the facts; reviewing available records; identifying missing information; structuring the response; and coordinating with the appropriate professional where legal input is required. Compliance Gap Assessment Where the notice points to a wider compliance issue, Corpseed can help review the relevant internal process and identify weaknesses that may require correction. Document and Evidence Review Corpseed can assist in organising relevant records such as: regulatory documents; export records; transaction records; correspondence; and other material linked to the allegation. The exact records required will depend on the individual case. Hearing Preparation Support Businesses may require help arranging documents, creating a clear case file, tracking dates and coordinating with authorised representatives or other professionals before the hearing. Appeal Documentation Support Where an adjudication order is being challenged, Corpseed can support the preparation and organisation of: Form-II information; copy of the adjudication order; statement of facts; supporting documents; grounds and factual records; and procedural timelines. Ongoing APEDA Compliance Support Businesses may also use APEDA compliance services for: regulatory monitoring; compliance reviews; document-control assessment; internal process review; and ongoing export compliance support. The adjudicating officer and appellate authority remain responsible for decisions under the Rules. Professional support can help a business prepare its case and documentation, but it cannot guarantee withdrawal of a notice, avoidance of a penalty or success in appeal. Businesses that have received an APEDA show-cause notice or adjudication order should consider reviewing the matter early, while enough time remains to verify facts and prepare the required response. Key Takeaways The APEDA Adjudication of Penalties Rules, 2026 create a formal process for dealing with penalty adjudication under Section 25A. The main points businesses should remember are: the Rules were notified on 19 August 2026; they took effect from publication in the Official Gazette; Form-I is used for the show-cause notice; the response period cannot be less than seven days from service; the person may appear personally or through an authorised representative; documents and evidence may be produced during the inquiry; the proceeding is to be completed within six months from issuance of notice; an aggrieved person may appeal using Form-II; the normal appeal period is 30 days from receipt of the order; defects in an appeal may be corrected within 15 days; the appeal is to be disposed of within 60 days from filing; and time may be extended for reasonable cause where reasons are recorded in writing. The larger takeaway is that these Rules are not a new recurring filing requirement for every APEDA exporter. Their importance becomes much greater once a complaint, notice, inquiry or adjudication order actually arises.

Subject

Summary: Industrial units in Gujarat that already hold a Consolidated Consent and Authorization (CCA) need to note an important change in how the consent period will be extended. The Gujarat Pollution Control Board (GPCB) has discontinued the earlier CCA renewal process for eligible existing units. Instead of filing a conventional renewal application to continue the CCA period, these units will now move to a CCA Extension Fee system. The process will be handled through GPCB's XGN Portal. The unit has to submit the request online and pay the prescribed Extension Fee. GPCB will then check the information available in the unit's profile against its existing CCA and the records already available with the Board. Once the prescribed fee is received, GPCB will issue an Extension Fee Payment Acknowledgement letter showing the current fee cycle and the next payment due date. At first glance, this may look like a simple replacement of one administrative process with another. In practice, however, the change creates an important distinction that every existing CCA holder should understand. The extension of the CCA period is now distinct from the CCA amendment. A unit that only needs continuation of its existing CCA period may fall under the new Extension Fee system. A unit that needs changes in its existing CCA will still have to follow the prevailing CTE or CCA Amendment procedure. That difference is likely to matter more than the change in terminology itself. GPCB Office Order: Main Details Particular Details Issuing Authority Gujarat Pollution Control Board Type of Document Office Order Main Subject Implementation of CCA Extension Fee system by discontinuing CCA Renewal Main Stakeholders Industrial units/stakeholders already holding GPCB CCA New Process Payment of prescribed Extension Fee instead of CCA renewal application Filing Platform XGN Portal Fee Amount Not expressly specified in the Office Order Payment Timing On or before the due date for each applicable fee cycle Document issued after payment Extension Fee Payment Acknowledgement Letter CTE/CCA Amendment Procedure Existing procedure continues Commencement Immediate effect The Office Order has been issued in the context of the Control of Air Pollution and Control of Water Pollution Consent Guidelines of 2025 and their Amendment Guidelines issued in 2026. Why Has GPCB Changed the CCA Renewal System? The reason given in the Office Order is fairly clear. GPCB states that the Ministry of Environment, Forest and Climate Change had issued the relevant Air and Water Pollution Consent Guidelines and subsequent amendments. According to the Office Order, the amended framework discontinued the renewal of Consent to Operate and provided for the payment of a prescribed Extension Fee. The order also refers to a single-step procedure for common consent and authorisation under the Air Act, Water Act, Hazardous Waste framework and other waste rules. GPCB has adopted the new procedure in Gujarat with the stated objective of implementing the Central Government guidelines and further promoting Ease of Doing Business in the state. For an industrial unit, the practical effect is easier to understand than the legal background. Earlier, the continuation of the CCA period was associated with a renewal process. Under the new arrangement, eligible existing CCA holders will move to a fee-based extension system. What has changed is the method for continuing the CCA period. What has not disappeared is the obligation to comply with environmental law and the conditions already contained in the CCA. Who Will Come Under the New CCA Extension Fee System? The Office Order expressly brings existing CCA holders within the new regime. It states that industrial units and stakeholders that have already obtained Consolidated Consent and Authorization from GPCB will be governed by the new procedure for further extension of their CCA period, subject to payment of the prescribed Extension Fee. This makes existing CCA holders the clearest category affected by the order. The document later uses the expression “eligible units,” but it does not provide a separate detailed list of eligibility criteria in the two-page Office Order. For that reason, it would be unsafe to create additional eligibility conditions that GPCB has not stated. The order should also not be treated as a complete guide for a business applying for its first consent. Its operative provisions on Extension Fee payment apply to units that already have a CCA. What Has Actually Changed for an Existing CCA Holder? The easiest way to understand the reform is to compare the old and new approaches. Area Earlier Approach New Approach Continuation of CCA period CCA renewal application Extension Fee system Method Renewal process Online request and fee payment Portal Existing renewal procedure XGN Portal Board's role Process renewal Verify particulars and vet applicable Extension Fee Document after processing Renewal-related outcome Extension Fee Payment Acknowledgement Amendment of CCA Separate amendment procedure Remains separate and unchanged For an existing unit whose approved position has not changed, this may reduce the need to go through a conventional renewal exercise solely to continue the CCA period. But the new process should not be read too broadly. The Extension Fee mechanism addresses extensions. It does not automatically handle changes to the consent. That difference becomes important whenever the existing CCA no longer reflects the unit's position. CCA Extension and CCA Amendment Need to Be Treated Separately This is one area where a hurried reading of the order can create confusion. The new system does not mean that every CCA-related matter can now be handled by paying an Extension Fee. GPCB specifically states that where an amendment to the CCA is required, there will be no change to the existing prevailing procedure for obtaining a CTE and a CCA Amendment, as applicable. The order further requires the applicant, in such cases, to submit a comprehensive profile containing full details, including both existing and proposed data. In other words, the Board has separated two situations. Situation 1: The existing CCA only needs continuation The Extension Fee route may apply. Situation 2: Something in the CCA needs to be changed The existing CTE/CCA Amendment procedure remains in effect. This distinction should be checked before an Extension Fee request is treated as a routine compliance activity. The Office Order itself does not provide a complete list of every operational change that may require amendment. That question must therefore be assessed under the applicable consent framework and the unit's existing CCA, rather than being inferred from the Office Order. How Will the CCA Extension Fee Process Work on the XGN Portal? GPCB has provided the basic process in a relatively short set of instructions. Online request The first requirement is to submit the Extension Fee request through the XGN Portal. The Office Order does not describe a separate physical filing route for the extension request. Payment through XGN The prescribed Extension Fee is also to be paid through the portal. The amount is not reproduced in the Office Order itself. Verification by GPCB Once the request is made, the Board will verify the particulars furnished in the unit's profile against two sources: The existing CCA, and Records are already available with GPCB. This verification will be used for vetting the prescribed Extension Fee payable under the applicable environmental Acts, Rules and Guidelines. That part of the procedure deserves attention. The new system is not simply a payment button in which every unit pays the same amount without any regulatory checks. The information held by the Board remains relevant to the process. Payment before the due date The unit should see that the Extension Fee, as provided for in the fee cycle, is paid on time. The GPCB has linked this obligation to the unit's functioning. Thus, paying the fee becomes a practical compliance concern rather than a mere accounting matter. Acknowledgement after payment Upon receipt of the prescribed fee, the Board will issue an Extension Fee Payment Acknowledgement letter. The acknowledgement will contain two useful pieces of information: The current fee cycle, and The next due date for payment. For an internal compliance team, that next due date should be recorded as soon as the acknowledgement is received. The Acknowledgement Is Important, but It Should Not Be Misread There is a small but important detail in the wording of the Office Order. GPCB states that an Extension Fee Payment Acknowledgement letter will be issued only upon receipt of the prescribed fee. The order does not say that a fresh CCA renewal certificate will be generated after each payment. That makes the acknowledgement an important record of the extension-fee transaction and fee cycle. A sensible record set for the unit would therefore keep the acknowledgement together with: The existing CCA, Relevant amendments, if any, Fee-payment evidence, and Other related environmental approvals or records. The first point is directly based on the Office Order. Keeping these records together is a practical compliance recommendation rather than a separate statutory requirement stated by GPCB. How Much Extension Fee Will a Unit Have to Pay? The Office Order does not give a fixed figure. It refers to the prescribed Extension Fee and explains that GPCB will verify the particulars furnished in the unit's profile against the existing CCA and Board records for vetting the fee payable under the applicable environmental framework. Therefore, if there is an attempt by a company to identify a single universal amount in this Office Order, then the attempt will fail. In other words, the actual Extension Fee is not provided in this document. It is important to note that this is critical from a compliance perspective. The fee for a particular unit should be determined through the relevant GPCB mechanism and applicable regulatory provisions, rather than based on an assumed figure. Why the XGN Profile Becomes More Important Under the New Process The Office Order makes the profile data part of GPCB's verification process. That means the information available through the system should not be treated as a formality. Before submitting an Extension Fee request, it would be sensible for an existing CCA holder to compare its current profile with the consent documents already held by the unit. The review will be conducted to ascertain whether the facts or information presented as the basis for the extension of the application are consistent with the existing approved position. If there have been substantial changes, the compliance team should consider the amendment route first, rather than the Extension Fee. Again, the order does not create a formal pre-filing audit requirement. This is a practical way of reducing the risk of a mismatch when GPCB carries out its own verification. What Remains Unchanged After the New Office Order? The discontinuation of the renewal process does not remove the rest of the environmental compliance framework. That point comes through clearly in the order's enforcement and amendment clauses. Existing CCA conditions still matter A unit can still face action for contravention of a condition of its CCA. So the Extension Fee should never be understood as a payment that allows the unit to operate independently of its existing consent conditions. CTE and CCA Amendment procedures continue Where an amendment is required, the existing procedure remains in place. Environmental laws and directions continue to apply The Office Order specifically refers to compliance with applicable Acts, Rules, Guidelines and directions. Other financial and regulatory obligations remain relevant GPCB also refers to Environmental Compensation, Bank Guarantee and other amounts payable. The Extension Fee is therefore one part of the unit's environmental compliance position, not the whole of it. What Happens If a Unit Does Not Pay the Extension Fee? Failure to pay the Extension Fee is expressly mentioned in the enforcement clause of the Office Order. GPCB states that action may be considered where a unit: Breaches a condition of the CCA, Contravenes applicable Acts, Contravenes applicable Rules or Guidelines, Fails to comply with directions issued under the relevant framework, Fails to pay the prescribed Extension Fee, Fails to pay Environmental Compensation, Fails to pay a Bank Guarantee amount where applicable, or Fails to pay another amount payable under the regulatory framework. These situations should not all be treated as identical, but the Board clearly identifies them as matters that can lead to regulatory action. What Action Can GPCB Take? The Office Order provides GPCB with several options when the conditions for action are met. The Board may: Cancel the CCA, Suspend the CCA, Revoke the CCA, Withdraw the CCA, or Take another action available under the applicable Acts, Rules and Guidelines. The wording is important. It says GPCB may take such action. It does not say that one particular consequence automatically follows every violation or delayed payment. For that reason, it would be inaccurate to write that missing a fee due date automatically cancels the CCA. The actual regulatory response will depend on the applicable legal provisions and circumstances of the case. The Unit Must Be Given an Opportunity to Be Heard The enforcement clause also contains a procedural safeguard. Before the action referred to in the order is taken, the affected unit must be given a reasonable opportunity of being heard. This gives the unit an opportunity to place its position before the Board in relation to the proposed action. It does not remove the underlying obligation to pay fees or comply with consent conditions. It simply means that the Office Order itself recognises an opportunity for a hearing before the specified enforcement action is taken. What Happens to Older GPCB Circulars and Office Orders? Whenever a regulator changes a long-standing process, a practical question follows: what happens if an older circular says something different? GPCB has addressed that point. The Office Order states that its provisions will supersede corresponding provisions contained in any earlier GPCB: Circular, Office Order, Instruction, or Guideline Relating to CCA Renewal, to the extent of inconsistency with the new order. These last words do make a difference. The Office Order does not say that all previous documents concerning CCA have been cancelled. It is better to understand it this way: if there is a conflict between a previous provision regarding the extension of CCA and the new Extension Fee System, the Office Order should take precedence. From Which Date Will the New Process Apply? The Office Order states that requests for Extension Fee payment submitted on or after the order's commencement date will be governed by and processed under the new procedure. It then says that the Office Order will come into force with immediate effect. The document carries an approved date of 31 July 2026. For an existing unit preparing a CCA-related filing after commencement, the immediate practical question is therefore whether the matter is now an Extension Fee case rather than a renewal application. Does the Order Explain What Happens to Every Pending Renewal Application? Not fully. The Office Order clearly deals with Extension Fee requests submitted on or after commencement. It does not, in the text provided, give a detailed, case-by-case treatment of every possible renewal application or proceeding that may have already been pending before commencement. That is an area where businesses should avoid drawing conclusions that are not stated in the order. If a unit had already filed a renewal-related request before the new system began, its status may need to be checked with reference to the actual filing and GPCB's applicable procedure. How Will This Change Affect Compliance Teams? For a unit with a stable operating position and no amendment requirement, the new system may make the continuation process easier. But it also changes the way internal teams should think about the compliance calendar. Previously, a team may have tracked a “CCA renewal” date. From now on, eligible units need to pay closer attention to: The applicable Extension Fee cycle, The due date for payment, The acknowledgement is issued after payment, and The next due date is recorded in that acknowledgement. The wording used in internal compliance trackers may therefore need to change. Instead of simply writing “CCA Renewal Due,” the company may need separate entries for: CCA Extension Fee Due and CCA Amendment Review, if required This small change can prevent two very different regulatory activities from being treated as the same thing. Finance Teams Will Need to Be Involved Earlier The new mechanism also brings finance and environmental compliance closer together. The Extension Fee must be paid within the applicable fee cycle. It means a compliance team cannot afford to identify the payment only at the last moment and then wait for internal financial approval. A better internal practice is to communicate the due date to finance well in advance and maintain proof of payment along with the acknowledgement received from GPCB. This is not a new statutory process set out in the Office Order. It is simply a practical control that follows from the requirement to pay on time. Plant and Operations Teams Also Have a Role Operations teams may not directly handle the XGN filing, but their information can be important. If the operating position of the unit has changed, the compliance team may need to determine whether the existing CCA still reflects the actual position. That is where the difference between extension and amendment becomes particularly relevant. A unit should not wait until the Extension Fee is due to discover that its existing consent may need to be amended. Internal communication among the plant, EHS, compliance, and legal teams can help identify such issues earlier. A Practical Internal Process for Existing CCA Holders The Office Order itself gives the regulatory steps. A business can build a simple internal process around itself. Internal Activity Suggested Responsibility Why It Matters Review existing CCA EHS/Compliance Confirms the approved position Check XGN profile Compliance Helps identify inconsistencies before submission Check whether an amendment is required EHS/Legal/Operations Separates extension cases from amendment cases Confirm applicable fee cycle Compliance Helps identify the correct due date Arrange funds Finance Avoids payment delay Arrange funds Authorised compliance user Follows the GPCB process Pay prescribed Extension Fee Finance/Compliance Required for extension mechanism Preserve acknowledgement Compliance Records current cycle and next due date Update compliance calendar Compliance Helps track future payment This table is a suggested internal management process. It should not be read as an additional list of legal duties imposed by GPCB. Is the New CCA Extension System Easier for Businesses? For units that need continuation of their existing CCA period, the new process appears designed to reduce the need for a recurring renewal application. That may save administrative effort, particularly where no change requires an amendment. The use of an online request and fee-payment mechanism also provides a more direct way to track the extension cycle. Another useful feature is the acknowledgement showing the next due date. If businesses maintain that date properly, it can make future compliance planning easier. Still, “simpler” should not be confused with “automatic.” GPCB continues to verify the unit's information. Existing CCA conditions remain enforceable. Applicable environmental laws continue to apply. Amendment procedures also remain in place. The system is therefore better understood as a simplification of routine continuation rather than a relaxation of environmental compliance. Where Can Businesses Go Wrong? The biggest risks are likely to come from misunderstanding the scope of the change rather than from the payment process itself. Treating the Extension Fee as a substitute for an amendment This is probably the most important risk. If an amendment is required, the existing amendment route still applies. Missing the next due date The acknowledgement issued after payment will mention the next due date. That date should be treated as an active compliance item. Relying on outdated profile information Because GPCB will verify profile particulars against the existing CCA and its records, a mismatch may need attention. Assuming a universal fee The Office Order does not provide a fixed Extension Fee amount. Thinking the CCA conditions no longer matter They continue to matter, and violation can lead to regulatory action. Treating the acknowledgement as a new CCA The Office Order calls it an Extension Fee Payment Acknowledgement letter. It should not be given a different legal character without a supporting provision. Questions the Office Order Leaves Open The Office Order is short and focused. It explains the new mechanism, but it does not answer every practical question a unit may have. The following points are not expressly specified in the document: A single Extension Fee amount applicable to all units, One universal fee-cycle duration, A complete fee-calculation formula within the Office Order, A detailed list of supporting documents for every Extension Fee request, A fixed processing time for GPCB to issue the acknowledgement, Detailed treatment of every application already pending before commencement, and A complete first-time CTE or CCA application procedure. These gaps should not be filled with assumptions. Where one of these issues affects an actual filing, the unit should check the applicable GPCB procedure or obtain case-specific regulatory guidance. What Existing CCA Holders Should Do Now For an existing CCA holder, the next steps need not be complicated. Start with the current consent. Check what has already been approved and whether the unit's current operating position remains consistent with that approval. Then review the XGN profile. If no changes are needed to the consent, determine which Extension Fee schedule applies. However, if anything needs to be changed, determine whether a CTE or CCA Amendment is required before considering this a normal extension. Once an Extension Fee request is submitted and payment is completed, retain the acknowledgement and record the next due date shown by GPCB. The process can be summarised as follows: Review the existing CCA. Check the current regulatory profile. Decide whether the case is an extension or an amendment. Confirm the applicable Extension Fee and due date. Submit the request through the XGN Portal. Pay the prescribed fee on time. Keep the acknowledgement safe. Record the next payment due date. Continue monitoring all existing CCA conditions and environmental obligations. The first six steps reflect the practical effect of the new GPCB mechanism. Maintaining records and internal calendars is recommended as a compliance-control measure. What Does the Change Mean for MSMEs and Smaller Industrial Units? The Office Order does not create a separate MSME category or special MSME exemption. Smaller units that already hold CCA therefore need to assess the new procedure in the same way as other affected existing CCA holders, subject to whatever fee framework and consent conditions actually apply to them. From an operational perspective, smaller units may benefit from fewer recurring renewal-related activities if their case involves only a routine extension. At the same time, they may also need tighter internal due-date management because smaller businesses often do not have a separate full-time environmental compliance team. That latter point is a practical observation rather than a special legal rule created for MSMEs. What Does the Change Mean for Larger Industrial Units? Larger units may find the payment mechanism straightforward, but their internal compliance position can be more complex. A large manufacturing facility may have several departments involved in environmental approvals, operations, finance, projects, and expansion activities. For these units, the bigger question may not be how to make the payment. It may be that the existing consent continues to accurately cover the unit's current and proposed operations. The Extension Fee process should therefore be linked with an internal amendment review rather than handled purely as a finance task. Is This Mainly an Ease of Doing Business Measure? GPCB expressly links the Office Order with further promotion of Ease of Doing Business in the State. From a business perspective, the reasoning is understandable. Where a unit already has consent and nothing substantive needs to be changed, repeatedly submitting a renewal application may add administrative work. A fee-based extension mechanism can reduce that repetition. But the order also preserves the Board's enforcement powers and the existing amendment procedure. The result is therefore not a removal of regulation. It is a change in the administrative treatment of routine continuation. That balance is important when explaining the reform. How Corpseed Can Assist Existing GPCB CCA Holders The new CCA Extension Fee system may look simple, but businesses still need to ensure that their existing CCA, XGN profile, and current operations are aligned. Corpseed can support units in reviewing their current position and identifying the correct compliance route before any filing or payment is made. 1. Review of Existing CCA Corpseed can help businesses review their present Consolidated Consent and Authorization and understand what is already approved. Check the existing CCA details and conditions. Identify the current consent position of the unit. Highlight areas that may need further review before extension. 2. Extension or Amendment Assessment One of the main questions under the new system is whether the unit requires only an extension or a CCA amendment. Corpseed can assist in: Reviewing the nature of proposed or existing changes. Checking whether the matter can be handled through the Extension Fee route. Identifying cases where CTE or CCA Amendment may need to be considered. 3. XGN Portal Compliance Support Since the Extension Fee request and payment are handled through the XGN Portal, the information available on the portal should match the unit's regulatory records. Support may include: Reviewing the details available in the XGN profile. Identifying visible mismatches with the existing CCA. Assisting with the relevant online compliance process. 4. CCA Extension Fee Filing Assistance Corpseed can assist existing CCA holders in organising the information required for the Extension Fee process. This may cover: Preparing the filing information. Coordinating the Extension Fee request. Supporting the online submission process. Helping businesses maintain payment and acknowledgement records. The applicable fee and final acceptance remain subject to GPCB and the relevant regulatory framework. 5. CTE and CCA Amendment Support Where a unit requires a change in its existing consent, the Extension Fee alone may not be sufficient. Corpseed can support businesses with: Review of existing and proposed operational details. Preparation of information required for amendment matters. Assistance with CTE or CCA Amendment-related documentation. Coordination of the applicable regulatory filing process. 6. Environmental Compliance Gap Review A CCA Extension Fee payment does not replace the need to comply with existing consent conditions. Corpseed can help businesses review: Existing CCA conditions. Pending environmental compliance requirements. Gaps in regulatory records or documentation. Areas that may require corrective action or further assessment. This can help a unit understand its broader compliance position rather than treating the Extension Fee as a standalone requirement. 7. Ongoing Pollution-Control Compliance Support Environmental compliance does not end once the Extension Fee is paid. Corpseed can assist businesses with ongoing support such as: Tracking relevant compliance dates. Reviewing changes that may affect the existing CCA. Organising environmental records and regulatory documents. Supporting future consent, amendment and compliance requirements. Corpseed's role is to help businesses understand the applicable process, prepare the required information and follow the appropriate regulatory route. Final approval, fee determination, acceptance of filings and other regulatory decisions remain with the Gujarat Pollution Control Board. Businesses that need help with GPCB consent matters can seek pollution control consent consultant support based on their existing CCA, operating activities and specific compliance requirements. Key Takeaways The GPCB Office Order changes the process that existing CCA holders use for the routine continuation of their CCA period. Eligible units will now pay the prescribed Extension Fee instead of filing the earlier CCA renewal application. The request and payment are to be handled through the XGN Portal, where GPCB will verify the unit's information against the existing CCA and Board records. After payment, the unit will receive an Extension Fee Payment Acknowledgement that identifies the current fee cycle and the next due date. There are five points worth remembering. The Extension Fee mechanism for eligible existing units has replaced the CCA renewal process. Extension and amendment are not the same thing. The existing CTE/CCA Amendment procedure remains in effect when an amendment is required. Timely payment of the Extension Fee is essential for continued operation. Existing CCA conditions and other environmental obligations remain enforceable. The practical benefit is a simpler route for routine extension. The practical responsibility is to ensure that the unit is genuinely an extension case, pays on time, and continues to comply with the consent it already holds.