DGFT's Inventory-Based E-Commerce Framework: Key Changes for Export Sellers

Understanding pre-positioned inventory exports and bonded warehouse operations under new rules

DGFT's New Inventory-Based E-Commerce Framework: What Changes on the Ground

On August 5, 2026, DGFT introduced an alternative to parcel-by-parcel courier exports for e-commerce sellers. Goods can now be pre-positioned in bonded warehouses and export hubs before sale. If your clients use marketplace channels and have been weighing whether to set up a hub, this framework answers that question directly.

What actually happened

DGFT issued Notification No. 27/2026-27, amending the Foreign Trade Policy 2023, and paired it with Public Notice No. 25/2026-27 to operationalize the change under the Handbook of Procedures, 2023. Together, these introduce an Inventory-based Cross-border E-Commerce Facilitation Framework.

The core change: goods can be pre-positioned in a bonded warehouse or export hub ahead of actual sales, then exported against confirmed orders as they arrive. Under the old courier and postal model, each parcel moved only after a specific buyer transaction was booked.

The framework also permits foreign capital participation in export-oriented inventory-based e-commerce operations. This is a separate point worth noting. It does not affect the FDI restrictions already in place for inventory-based import and domestic retail models. Exporters and their legal advisors should treat these two regimes separately.

The Exporter-on-Record concept

This definition will be your clients' first question, and rightly so. The Notification assigns responsibility and liability through an "Exporter-on-Record" designation. Once goods sit in a hub before sale, someone must own the customs declaration, GST liability, and return or refund exposure. That party may differ from the individual seller who held these obligations under the courier model, where each shipment typically had its own exporter of record.

Any platform agreement your client has signed needs review against this definition. If the platform intends to act as Exporter-on-Record for hub-based inventory, your supplier or MSME client must know precisely where its own liability ends.

Practitioner checklist

Eligibility and scope

• Read the full text of Notification 27/2026-27 and PN 25/2026-27 before advising on client eligibility. Secondary sources outline the framework structure but not the detail on thresholds or excluded categories.
• Confirm whether your client's product lines face any category caps or exclusions.

Exporter-on-Record and contracts

• Map the Exporter-on-Record definition against your client's existing marketplace agreement. Clarify who bears customs liability, GST liability, and refund or return exposure once stock is warehoused pre-sale.
• Identify any gap between what the platform's standard contract currently says and what the Notification now assigns by default.

Warehouse and customs interface

• Determine whether an existing private bonded warehouse licence is sufficient, or whether a fresh DGFT or customs authorization is required for hub-based export inventory.
• Confirm IEC, GST registration, and AD Code linkages for the hub location itself, not just the seller's principal place of business. Sellers often miss this by assuming their existing registrations apply automatically.

Foreign capital angle

• If the platform holds FDI, check the export-only carve-out against existing FDI e-commerce conditions before assuming it changes anything for that entity.

Working capital

• Inventory held in a bonded hub ties up capital differently than parcel-by-parcel courier exports. Cross-reference this against Trade Notice No. 31/2025-26 (Credit Assistance for E-Commerce Exporters under EPM-Niryat Protsahan) for MSME clients who will feel the impact first.

Transition SOP

• Develop a written transition plan from courier/postal mode, covering revised shipping bill processes for hub consolidation, reverse logistics for returns, and clear handover points between seller and platform for customs documentation.

Where the sector already sends volume

The US, UAE, and China remain the largest destination markets for Indian exports by value. E-commerce sellers moving to hub-based fulfilment will likely concentrate early pilots on these corridors, where logistics infrastructure is already developed.

Open items to confirm before client advice

Several specifics have not yet been settled in secondary reporting and require verification against the primary texts: exact eligibility thresholds, permitted and excluded product categories, the authority responsible for hub and warehouse licensing, the precise conditions attached to foreign capital access, and whether any transition timeline exists for exporters currently using courier-mode operations who wish to shift.

What to do this week

• Obtain the full text of Notification 27/2026-27 and Public Notice 25/2026-27 directly from DGFT before responding to any client query.
• Review at least one live marketplace agreement against the Exporter-on-Record definition and note where liability allocation differs from current contract language.
• Ask MSME clients using courier-mode export today whether they are considering a hub model. If so, start the warehouse licensing conversation now, before they commit inventory.
• Check FDI structure for any platform client before advising on the foreign capital opening. Do not assume it overrides existing domestic retail restrictions.
• Flag Trade Notice 31/2025-26 to clients as a funding option to offset inventory holding costs under the new model.

Keywords: DGFT, cross-border e-commerce, Foreign Trade Policy 2023, bonded warehouse export, Exporter-on-Record, e-commerce export compliance