Can Your India-ASEAN Shipment Still Claim Preference After the New Self-Certification Rules?

DGFT Public Notice No. 24/2025-26 shifts Certificates of Origin from agency-issued to self-issued under AIFTA. Here is what exporters must now verify.

The question

Can your India-ASEAN shipment still claim preferential tariff treatment now that DGFT has shifted Certificates of Origin from agency-issued to self-issued under the India-ASEAN Free Trade Agreement?

What changed

DGFT Public Notice No. 24/2025-26 dated 28 October 2025 enables exporters to self-issue Certificates of Origin under AIFTA. This is a structural shift from the long-standing model where preferential Certificates of Origin were issued only by designated agencies listed in Appendix 2B of the Foreign Trade Policy, 2023.

The same DGFT release cycle also carried Public Notice No. 30/2025-26, which amends Appendix 2B itself, signalling that the agency-issued route is being recalibrated even as self-certification is introduced.

The practical consequence is that the exporter now stands in the shoes of the issuing authority. The exporter must determine whether the goods satisfy the AIFTA product-specific rules of origin, complete the origin declaration in the prescribed format, and retain the underlying records that would previously have been examined by an agency before a certificate was stamped. The compliance burden has moved from a pre-shipment verification by a third party to a post-shipment audit of the exporter's own determination.

Who it hits

The immediate impact falls on Indian exporters shipping to ASEAN member states (Thailand, Vietnam, Indonesia, Malaysia, Singapore, Philippines, Myanmar, Cambodia, Laos, and Brunei) who currently claim or intend to claim preferential tariff treatment under AIFTA. It also affects their ASEAN importers, because the importing customs authority in the destination country will now scrutinise a self-issued certificate rather than one bearing an authorised agency's stamp. Freight forwarders, customs brokers, and in-house trade compliance teams that prepare AIFTA documentation on behalf of exporters are equally exposed, since the origin determination and record-keeping obligations now sit with the entity whose name appears on the self-certification.

The compliance trap

The most dangerous assumption is that self-certification simplifies the process. It does not. It removes the pre-shipment gatekeeper and replaces it with post-shipment liability. Under the agency-issued model, an exporter could argue that the designated agency had reviewed the origin determination. Under self-certification, that defence disappears. If the importing ASEAN customs authority rejects the self-issued certificate, for example because the product-specific rule was misapplied or the supporting cost statements do not substantiate the regional value content, the importer pays full MFN duty, and the exporter faces a commercial claim, potential investigation, and reputational damage with the buyer.

A second trap is the interaction with India's export-side schemes. RoDTEP and AIFTA preferential duty are independent and can both be claimed on the same shipment: RoDTEP is an Indian export rebate, while AIFTA preference is a destination-side tariff saving. But RoDTEP and Drawback are mutually exclusive on the same shipping-bill inputs. An exporter that switches documentation workflows to accommodate self-certification must not inadvertently alter the shipping-bill declarations that determine RoDTEP eligibility. The two regimes are administered by different authorities, DGFT for origin and CBIC for export incentives, and they are not automatically aligned.

A third trap is record retention. The exporter must now maintain the full origin file: supplier declarations, cost of production statements, bills of materials, and the working sheets behind the regional value content or change-in-tariff-heading analysis. DGFT authorisation records carry an eight-year retention expectation; customs records typically five years; GST records six years. A self-issued certificate is only as defensible as the file behind it, and that file must survive an audit that may come years after the shipment.

Open confirmations

Several points require confirmation against the primary instruments before advising clients.

• First, the exact scope of Public Notice No. 24/2025-26: does self-issuance apply to all AIFTA-eligible goods, or only to exporters who meet a designated "certified exporter" threshold under the ASEAN-Wide Self-Certification model?
• Second, the prescribed format of the self-issued certificate and whether it must be transmitted electronically through a DGFT portal or may be issued on the exporter's letterhead.
• Third, whether the ASEAN importing country has notified its customs administration to accept Indian self-issued certificates, since a bilateral FTA preference is only as good as the importing country's willingness to honour the document.
• Fourth, the transitional treatment of agency-issued certificates already in circulation for shipments in transit or awaiting clearance.
• Fifth, the precise product-specific rule for the exporter's HS code: the AIFTA rules of origin annex contains both change-in-tariff-heading and regional value content tests, and the applicable test varies by heading.

Action list

• Identify every AIFTA shipment currently in your pipeline and confirm which certificate type applies.
• Run the origin analysis twice: once against the AIFTA product-specific rule, once against the documentation the importing customs authority is likely to request in a verification.
• Have the origin file reviewed by someone who did not prepare it before the certificate is signed.
• Confirm the prescribed format and transmission channel for the self-issued certificate against Public Notice No. 24/2025-26.
• Verify that the ASEAN importing country has notified its customs administration to accept Indian self-issued certificates.
• Treat the first self-issued certificate as a pilot, not a routine filing.

Primary sources

• DGFT Public Notice No. 24/2025-26 dated 28 October 2025, DGFT Public Notice No. 30/2025-26 dated 28 October 2025 (amending Appendix 2B of Foreign Trade Policy, 2023)
• India-ASEAN Trade in Goods Agreement, rules of origin annex and product-specific rules, Handbook of Procedures, 2023, Chapter 2

Confidence

Verified: DGFT Public Notice No. 24/2025-26 dated 28 October 2025 enables self-issuance of Certificates of Origin under AIFTA. Interpretation: the compliance burden shifts from pre-shipment agency verification to post-shipment exporter liability. Needs confirmation: scope of self-issuance, certificate format, ASEAN customs acceptance, and transitional treatment of agency-issued certificates. DGFT, AIFTA, Certificate of Origin, self-certification, preferential tariff, rules of origin, RoDTEP, ASEAN.