Can Your Gem & Jewellery Export Still Claim Duty-Free Gold After the 100 kg Cap?
DGFT Public Notice 54/2025-2026 caps gold imports at 100 kg per Advance Authorisation, but Notification 73/2025-26 offers a one-time relaxation. What does it mean for your pending authorisation?
The question
Can a jewellery exporter still claim duty-free gold under an Advance Authorisation issued before 30 March 2026, when the authorisation specifies more than 100 kg?
What changed
DGFT Public Notice 54/2025-2026 dated 30 March 2026 introduces a 100 kg cap on gold imports per Advance Authorisation for the Gem & Jewellery sector under Chapter 4 of FTP 2023. The same package adds a monthly consolidated reporting obligation on regional authorities, who must now send DGFT headquarters details of every authorisation issued and the corresponding gold import-export transactions.
DGFT Notification 73/2025-26 dated 31 March 2026 amends Paragraph 4.43 of FTP 2023 to grant a one-time relaxation for the sector. Read the two instruments together: the Public Notice operationalises what the Notification relaxes.
The immediate question for an exporter holding an AA issued in, say, January 2026 for 250 kg of gold, with only 80 kg imported so far, is whether the remaining 170 kg entitlement survives. The Public Notice does not state on its face whether the cap applies retrospectively or only to authorisations issued on or after 30 March 2026.
Example check
An exporter holds Advance Authorisation AA-2026-0142 issued 15 January 2026 for 250 kg of gold under SION M1, with 80 kg imported and 60 kg exported against the obligation. The exporter now wants to import the remaining 170 kg.
| Item | Quantity | Status |
|---|---|---|
| --- | ---: | --- |
| AA gold entitlement | 250 kg | Issued 15 Jan 2026 |
| Gold imported to date | 80 kg | Cleared duty-free |
| Gold exported against AA | 60 kg | Shipping bills filed |
| Balance entitlement | 170 kg | Under question |
Eligibility
- Whether the 100 kg cap applies to authorisations issued before 30 March 2026, or only prospectively. The Public Notice language says "per authorisation" but does not specify the operative date for existing licences.
- Whether the cap is per authorisation or per IEC or per financial year. The Public Notice says "per authorisation," but confirm the operative paragraph.
- Whether the one-time relaxation under Notification 73/2025-26 interacts with the cap, i.e. whether relaxed Paragraph 4.43 conditions override or coexist with the 100 kg limit.
- The exact SION serial (M1 to M8) applicable to the specific jewellery product, and whether the SION note inserted below those entries alters the gold quantity entitlement.
- Whether the India-UAE CEPA TRQ authorisation, whose validity for FY 2025-26 has been extended to 30 June 2026, offers a parallel route for gold imports under Tariff Head 7108 once the AA entitlement is exhausted.
Decision
Needs verification. The exporter should not import the remaining 170 kg under the existing AA without written confirmation from the Regional Authority on whether the 100 kg cap applies to authorisations issued before 30 March 2026.
Why
- Verified: Public Notice 54/2025-2026 introduces a 100 kg cap on gold imports per Advance Authorisation. The notice does not state whether the cap is retrospective.
- Verified: The monthly consolidated reporting requirement means regional authorities will now scrutinise gold import-export reconciliation more closely. Exporters should keep the AA file, Bills of Entry, shipping bills, and SION working sheets in a single audit-ready folder.
- Needs confirmation: Whether the cap applies to unutilised balances on authorisations issued before 30 March 2026. The safer reading, pending DGFT clarification, is that the cap applies prospectively, but exporters should not rely on that assumption.
Compliance traps
- Do not assume the cap is retrospective. A written confirmation from the concerned Regional Authority, or a formal clarification from DGFT, is the only way to eliminate the risk of a duty demand on gold imported beyond 100 kg under a pre-existing AA.
- Do not stack Duty Drawback with AA imports. Inputs imported duty-free under Advance Authorisation are not eligible for Duty Drawback, since no duty was paid to draw back. Exporters who have claimed Drawback on the same shipping bills where AA gold was used face recovery.
- RoDTEP is not automatically barred by AA usage, but the exporter must confirm the specific RoDTEP rate for the jewellery item and ensure the shipping bill does not inadvertently claim both Drawback and RoDTEP on the same inputs.
- CEPA TRQ is a separate regime. The 100 kg AA cap does not automatically apply to TRQ imports under India-UAE CEPA, but stacking rules and export obligation tracking differ. Exporters holding both an AA and a CEPA TRQ authorisation must track the two regimes separately.
Primary sources
DGFT Public Notice 54/2025-2026 dated 30 March 2026, DGFT Notification 73/2025-26 dated 31 March 2026, Foreign Trade Policy 2023, Chapter 4, Handbook of Procedures 2023, SION entries M1 to M8
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Confidence
Verified: The 100 kg cap exists and is introduced by Public Notice 54/2025-2026.
Interpretation: The cap likely applies prospectively, but this is not stated in the instrument.
Needs confirmation: Retrospective application, per-IEC vs per-authorisation scope, and interaction with Notification 73/2025-26.
DGFT, Advance Authorisation, Gem & Jewellery, gold import cap, FTP 2023, SION, India-UAE CEPA TRQ.