Can Your Advance Authorisation Shipment Still Claim Duty Exemption After the New SION Fixation?

DGFT fixed three new SIONs for Chemical and Allied Products on 08 July 2025. Check if your existing AA still clears duty-free or needs an amendment before your next consignment.

The question

DGFT fixed three new Standard Input Output Norms for Chemical and Allied Products on 08 July 2025. If your Advance Authorisation covers those inputs or resultant products, you need to know whether your existing AA still clears duty-free, or whether the fixation forces an amendment before your next consignment.

What changed

Public Notice No. 14/2025-26 dated 08 July 2025 fixes SIONs A-3687, A-3688 and A-3689 under Product Code 'A'. The notice is issued under paragraph 1.03 of the Foreign Trade Policy 2023 and is effective from 08 July 2025.

The operative principle is paragraph 4.02 of FTP 2023: an authorisation is issued in accordance with the Policy and Procedures in force on the date of issue of the authorisation. That cuts both ways. It protects an existing AA from retroactive invalidation merely because a new SION is fixed later. But it also means that if you now seek to import inputs or export a resultant product that was not covered by the SION position at the date of issue, the new fixation may be the governing norm.

Who this hits

Three groups face immediate exposure.

• Exporters with pending or in-transit AA shipments where the bill of entry or shipping bill is filed on or after 08 July 2025 and the goods correspond to the chemical products now covered by A-3687 to A-3689. Customs may seek confirmation that the AA's input-output norms align with the newly fixed SION before extending the duty exemption.
• Exporters whose AA was issued on a self-declaration basis under paragraph 4.07 of the Handbook of Procedures, or on an ad hoc norm, where the product has now been brought under a fixed SION. The fixation may supersede the self-declared norm for future imports, requiring reconciliation of quantities already imported against the newly fixed wastage allowances.
• Exporters planning a fresh AA application for the same chemical products. Once a SION is fixed, the Regional Authority will ordinarily apply that SION rather than entertain a self-declared norm for the same product, unless the applicant can justify a different input-output ratio under the applicant-specific norm route.

The compliance trap

A common trap is assuming that a newly fixed SION automatically amends an existing Advance Authorisation. It does not. Paragraph 4.02 of FTP 2023 anchors the authorisation to the norms in force on the date of issue. An AA issued before 08 July 2025 on the basis of a self-declared or ad hoc norm does not automatically convert to A-3687, A-3688 or A-3689. You may continue to import under the original authorisation terms, but only to the extent the goods and quantities remain within the original description and value limits.

The trap arises when you attempt to import additional quantities, or a slightly different input, after the SION fixation, relying on the old AA. Customs may take the position that the newly fixed SION now governs the product, and that the old self-declared norm is no longer available for fresh imports. You then face a demand for duty on the differential, or a request to amend the AA through the Regional Authority under paragraph 4.37 before further imports.

A second trap is the drawback interaction. Inputs imported duty-free under an Advance Authorisation are not eligible for Duty Drawback, because no duty was paid to draw back. If you decide to pay duty on a particular consignment and then claim Drawback on the export, the two benefits cannot be stacked on the same inputs. You must choose one route per consignment and document that choice clearly.

A third trap is RoDTEP stacking. RoDTEP is an export-side rebate and is independent of the import-side AA exemption. You can claim RoDTEP on the export even where inputs were imported duty-free under AA. But RoDTEP and Drawback are mutually exclusive on the same shipping-bill inputs. Do not inadvertently claim Drawback on an AA-based export and then also claim RoDTEP on the same bill.

What to verify before filing

• Pull the original AA file and note the date of issue and the basis of norms: SION, self-declaration, or ad hoc.
• Compare the input-output ratio and wastage allowance in your AA against the newly fixed SION text for A-3687, A-3688 or A-3689.
• Confirm the HS code alignment between the AA, the shipping bill, and the newly fixed SION to avoid a mismatch at the port.
• If the existing AA remains within its original terms, proceed, and keep a short internal note recording that the AA predates the 08 July 2025 fixation and that paragraph 4.02 of FTP 2023 anchors the authorisation to the norms in force on the date of issue.
• If any enhancement or change is needed, route it through the Regional Authority under paragraph 4.37 before the goods arrive, rather than attempting to clear under a mismatched AA and inviting a post-clearance demand.

Primary sources

DGFT Public Notice No. 14/2025-26 dated 08 July 2025, Foreign Trade Policy 2023, Chapter 4, paragraphs 4.02, 4.03(a), 4.03(b), 4.37, Handbook of Procedures 2023, paragraph 4.07

Confidence

Verified: Public Notice No. 14/2025-26 dated 08 July 2025 fixes SIONs A-3687 to A-3689 under Chemical and Allied Products. Verified: paragraph 4.02 of FTP 2023 anchors an AA to the norms in force on the date of issue. Needs confirmation: exact product descriptions, input-output ratios and wastage percentages for A-3687 to A-3689 against your specific chemical product and input mix. DGFT, Advance Authorisation, SION fixation, duty exemption, chemical exports.