Can your deemed export claim still use old Chapter 7 documents after DGFT's amendment?

DGFT's Public Notice No. 35/2025-26 changes what you must file, how the online module validates claims, and which legacy documents still work.

The question

Can a deemed export beneficiary still file a claim using the documentation set prepared under the old Chapter 7 of the Handbook of Procedures 2023, or does every pending and future claim now need revalidation against the amended text?

What changed

DGFT has amended Chapter 7 of the Handbook of Procedures 2023 through Public Notice No. 35/2025-26 dated December 2025. The amendment takes effect immediately.

Claims filed after the Public Notice date must conform to the revised Chapter 7, even if the underlying supply transaction predates the amendment.

The DGFT has also released the Deemed Export Module User Help File Version 4.0 in February 2026, which operationalises the revised ANF-7A online process.

The amendment is not a cosmetic renumbering. It changes what a beneficiary must submit, how the online module validates claims, and which legacy documents remain acceptable.

A supplier who has already executed a deemed export supply but has not yet filed the claim, or who filed under the old documentation set and now faces a Regional Authority query, should treat the amendment as a cut-off event.

Who this hits

The full chain of deemed export beneficiaries under Paragraph 7.02 of FTP 2023 is affected:

• Manufacturers supplying against Advance Authorisation, Advance Authorisation for Annual Requirement, or DFIA
• Manufacturers supplying to EOUs, STPs, EHTPs, or BTPs
• Manufacturers supplying capital goods against EPCG authorisations
• Main contractors and sub-contractors supplying to specified projects
• Intermediate suppliers operating through invalidation letters under Paragraph 4.13 of HBP

The practical burden falls most heavily on suppliers who have executed supplies but not yet filed claims, or who filed under the old documentation set and now face queries. The amendments do not grandfather pending claims automatically.

The three documentation traps

Invalidation letter pathway. Under Paragraph 7.02(a)(i) of HBP, a supplier of intermediate goods to an Advance Authorisation or DFIA holder against an invalidation letter must now demonstrate that the invalidation letter was issued in terms of Paragraph 4.13 of HBP and that the TED refund claim is consistent with Paragraph 7.03(c) of FTP. The amendment appears to require a clearer nexus between the invalidation letter, the underlying authorisation, and the specific supply. A supplier who previously relied on a copy of the invalidation letter alone may now need to produce the authorisation details, the invalidation endorsement, and proof that the goods were actually used in the export production of the authorisation holder.

Online ANF-7A module. The Version 4.0 help file indicates that the online process now captures additional fields and validations. Claims filed on the old paper ANF-7A format, or on an earlier online version, may be rejected or returned for resubmission. The practical risk is not that the old documentation is substantively invalid, but that it is procedurally non-conforming under the new module's validation logic.

Benefit stacking. RoDTEP and Duty Drawback are mutually exclusive on the same shipping-bill inputs. For deemed export beneficiaries, the relevant interaction is between TED refund under Chapter 7 and any other benefit claimed on the same supply. A supplier who has claimed TED refund on a deemed export supply cannot also claim RoDTEP or Drawback on the same transaction. The amended Chapter 7 does not change this, but the new documentation requirements may force a supplier to elect benefits earlier in the process, before all rates are confirmed.

What to do before filing

• Pull the claim file and compare the documentation set against the amended Chapter 7 text and the Version 4.0 help file
• For invalidation letter claims, assemble the authorisation details, the invalidation endorsement, and proof of use in export production
• Confirm the effective date of Public Notice No. 35/2025-26 and check for any transitional or savings language in the Public Notice text
• Verify whether the claim was filed before or after the Public Notice date, and whether the online module version matches the claim
• Confirm document retention periods: DGFT authorisation and export obligation records are typically retained for 8 years, Customs records for 5 years
• Do not assume CAROTAR 2020 or Customs origin-administration rules apply to deemed export claims under Chapter 7. They do not. Deemed export claims are administered by DGFT Regional Authorities, not Customs.

Open confirmations

The exact effective date of the amendment should be confirmed from Public Notice No. 35/2025-26 itself.

Whether the Public Notice contains any saving clause for claims filed before the amendment but pending adjudication is not clear from the available materials.

The precise list of documents added, removed, or modified under the amended Chapter 7 is not fully enumerated in the available materials. The Version 4.0 help file is the best available proxy, but the authoritative list is in the amended Chapter 7 text itself.

Primary sources

• Public Notice No. 35/2025-26, DGFT, December 2025
• Chapter 7, Handbook of Procedures 2023, as amended
• Chapter 7, Foreign Trade Policy 2023, Paragraphs 7.01 to 7.03
• Deemed Export Module User Help File Version 4.0, February 2026
• Paragraph 4.13, Handbook of Procedures 2023

Confidence

Verified: Public Notice No. 35/2025-26 amends Chapter 7 of HBP 2023 with immediate effect.

Verified: the Version 4.0 help file operationalises the revised ANF-7A process.

Interpretation: claims filed after the Public Notice date must conform to the revised Chapter 7, even if the supply predates the amendment.

Needs confirmation: the exact effective date, any transitional provisions, and the full list of documentation changes.

DGFT deemed export claims, HBP Chapter 7 amendment, ANF-7A documentation, TED refund revalidation, invalidation letter compliance.