Can Your SCOMET Repair Export Still Use the Old GAER Route After DGFT Public Notice 31?

Public Notice 31/2025-26 makes GAER the default bulk route for re-exporting imported SCOMET items after repair in India, with strict eligibility and post-reporting conditions

The question Can an exporter who imported a SCOMET item for repair still use the old case-by-case authorisation route, or does the new General Authorization for Export after Repair (GAER) under DGFT Public Notice 31/2025-26 now govern that export? ## What changed DGFT Public Notice 31/2025-26, dated 23 September 2025, operationalises the GAER for imported SCOMET items sent back abroad after repair in India. The GAER is a one-time, bulk authorisation issued by DGFT. It permits export of imported SCOMET items to the same foreign entity from which they were received, without a transaction-specific SCOMET export authorisation for each repair consignment. The old route, a case-by-case SCOMET export authorisation under Chapter 10 of the Foreign Trade Policy 2023 and the Handbook of Procedures 2023, remains available in principle. But for exporters who meet the GAER conditions, the old route is no longer the default or the most efficient option. The operative answer: yes, the GAER replaces the old authorisation route for the covered class of transactions, subject to strict eligibility and post-reporting conditions. ## Who the GAER covers The GAER route is available only to exporters who satisfy a narrow set of conditions: - The SCOMET items must have been imported into India for repair at a designated or authorised repair facility.

• The import must be under a contract agreement, Master Service Agreement (MSA), or a contract between the Indian exporter and the foreign entity.
• The export must be to the same entity abroad from which the items were imported. Not to a different affiliate, distributor, or end-user.
• The repair must be carried out in India, and the items must be re-exported after repair. Exporters who import SCOMET items for purposes other than repair, or who repair items for a different foreign entity, or who export repaired items to a third party, fall outside the GAER and must continue to use the old transaction-specific authorisation route. ## The compliance trap most exporters will miss The GAER is a general authorisation, not a no-authorisation route. Exporters must first obtain the GAER from DGFT. That one-time application requires submission of an Internal Compliance Programme (ICP) certificate, details of the repair facility, the contract or MSA, and the categories of SCOMET items covered. Once granted, the GAER is subject to quarterly post-reporting to DGFT in the prescribed format. Failure to file quarterly reports, or late filing, can jeopardise the authorisation and expose the exporter to enforcement action. A second trap is the same entity requirement. If the foreign entity that sent the item for repair is not the same legal entity to which the repaired item is exported, for example where a foreign parent sends the item but a foreign subsidiary receives it, the GAER does not apply. The exporter must revert to the old transaction-specific route. A third trap is the interaction with Customs. The GAER is a DGFT authorisation. The exporter must still file a shipping bill with the correct SCOMET declaration and ensure that the Customs system recognises the GAER reference. CBIC and DGFT instruments are not automatically aligned. Confirm that the shipping bill reflects the GAER authorisation number and that post-export reporting to DGFT is completed even if Customs clearance is smooth. ## What remains unconfirmed The full operative text of Public Notice 31/2025-26 as published in the Gazette is not yet available in the corpus. The draft Public Notice from 2022 and the web notes indicate the GAER framework, but the exact conditions, the prescribed quarterly reporting format, likely ANF-2O or a variant, and the list of SCOMET categories covered by GAER should be confirmed against the primary instrument. The corpus also does not specify whether the GAER covers all SCOMET categories or only certain ones. The draft text refers to imported SCOMET items generally, but the final notification may exclude Category 0, 1, or 2 items. Exporters should verify the exact scope against the notification and the updated Appendix-3. ## Action checklist, Assess whether the GAER covers the full range of your repair transactions before the next repair consignment.
• If you do not have a documented ICP, begin building one now. The GAER application requires an ICP certificate.
• Keep the contract or MSA, the import bill of entry, and the repair work order as a single evidentiary bundle for each GAER-covered export.
• Diarise the quarterly reporting deadline to DGFT.
• Confirm the exact SCOMET categories covered by GAER against Public Notice 31/2025-26 and the updated Appendix-3.
• Verify that your shipping bill reflects the GAER authorisation number and that post-export reporting is completed even if Customs clearance is smooth. ## Confidence Verified: DGFT Public Notice 31/2025-26 dated 23 September 2025 introduces GAER for export of imported SCOMET items to the same entity abroad after repair. Interpretation: GAER replaces the old transaction-specific route for covered repair exports, subject to eligibility and quarterly reporting. Needs confirmation: exact SCOMET categories covered, prescribed quarterly reporting format, and full operative text of the notification. SCOMET repair exports, GAER authorisation, DGFT Public Notice 31, ICP certificate, quarterly post-reporting.