The EximLabh Brief

Can Your Wheat Flour Export Still Use the Old Allocation Route After DGFT's New Modalities?

DGFT replaces first-come-first-served with structured allocation for 5 lakh MT of wheat flour exports under Public Notice No. 48/2025-26

The question Can an exporter with a pending wheat flour shipment under HS 1101 still rely on the old first-come-first-served route, or must every pending and planned consignment now clear the new allocation mechanism under Public Notice No. 48/2025-26 dated 24 February 2026? ## What changed DGFT has replaced the earlier first-come-first-served window for wheat flour exports with a structured allocation process. Public Notice No. 48/2025-26, issued alongside Notification No. 61/2025-26 on 24 February 2026, authorises an additional 5 lakh metric tonnes of wheat flour and related products manufactured from domestic wheat. The operative shift is procedural: an exporter no longer secures quota by filing earliest on the online platform. The exporter must now satisfy eligibility thresholds, submit specified documentation, and receive a non-transferable Export Authorisation valid for six months. The notice operates under paragraphs 1.03 and 2.04 of the Foreign Trade Policy 2023 and Sections 3 and 5 of the Foreign Trade (Development and Regulation) Act, 1992. It follows the earlier window opened by Notification No. 55/2025-26 and Public Notice No. 44/2025-26 dated 16 January 2026. The transition between the January and February instruments is where compliance risk concentrates. ## Who this hits Three categories of exporters face immediate questions. First, holders of existing contracts or confirmed export orders who had not yet obtained an authorisation under the earlier regime. Their pending shipments must now be re-examined against the new allocation criteria. Second, exporters with in-transit or ready-to-ship consignments who assumed the old route would continue. If their application was not already approved, they cannot rely on prior practice. Third, smaller traders: the notice sets a minimum application quantity of 2,500 MT, which excludes low-volume exporters from the allocation window entirely. The self-declaration requirement that only domestic wheat, not imported wheat, is used also filters out processors who blend imported grain. ## The compliance trap that matters most The most significant trap is the interaction between the new allocation route and the self-declaration on domestic wheat sourcing. An exporter who previously exported wheat flour using imported wheat under an Advance Authorisation or duty-free import scheme may now find that history used against them. The notice requires past performance data on wheat exports for the three financial years prior to 2022-23, plus a Chartered Accountant certificate on overall export turnover for the preceding five years. If the CA certificate or past-performance disclosure reveals imported-wheat usage, the self-declaration for the new window becomes inconsistent. The notice states that misdeclaration bars the applicant from any allocation for the next three years. This is not a mere administrative penalty. It is a three-year disqualification from the entire wheat flour quota mechanism. A second trap concerns the minimum quantity threshold. Applications for less than 2,500 MT "shall not be considered for allocation." Exporters with smaller confirmed orders cannot simply aggregate multiple buyers to reach the threshold unless the application structure permits it. The notice does not clarify whether aggregation across consignees is permissible. Confirm against the primary instrument before advising a client to combine orders. Third, the non-transferability clause is absolute: authorisations must be used by the allottee IEC holder only. This blocks the practice of transferring quota to a group company or trading partner. Exporters who structured their supply chain around transferable authorisations under the earlier regime must now restructure before the six-month validity lapses. ## Open confirmations before you commit Several points require verification against the primary instrument before any client communication. First, the exact date of the Public Notice. The DGFT website listing shows 24 February 2026, and the corpus extract header reads "February 24, 2026." Confirm the gazette publication date, as the effective date for pending applications may turn on it. Second, whether the 5 LMT additional quantity is a fresh allocation or includes quantities already authorised under the January 2026 notice (No. 44/2025-26). Third, the treatment of applications filed but not yet approved under the earlier first-come-first-served window. The notice does not state whether they are automatically carried forward or must be re-filed. Fourth, the precise documentation format for the CA certificate and self-declaration. The notice lists requirements but the prescribed forms may be in an annexure not reproduced in the corpus. Fifth, whether the six-month validity runs from authorisation issuance or from the date of application approval. ## Action list for exporters with pending wheat flour shipments, Pull IEC-level export history for HS 1101 and HS 1001 (wheat) for FY 2019-20 through FY 2021-22, and reconcile it against the CA certificate you intend to submit.