Advocate R C Verma
Take note of CBEC’s Circular No. 26/2017 –Customs, dated 01.07.2017 and No. 36/2017-Customs, dated 28.08.2017 on regulating the procedure for export of goods under self-sealing of containers w.e.f. 01.10.2017
2. Vide aforesaid two circulars, the CBEC Board has laid down simplified procedure for stuffing and self- sealing of export goods in containers. By prescribing this procedure, the CBEC Board has done away with the sealing of containers of export goods by the departmental officers. Self sealing procedure would mitigate the difficulties of the exporters faced by them in arranging the visit of the departmental officials to seal their containers of export goods. But this facility would be available only to the existing GST registrants coupled with obligation of filing of GSTR-1 and GSTR-2 returns by them. In case, if the exporter is not registered with GST department, then he shall bring the export goods to the Container Freight Station(CFS)/ICD for stuffing and sealing of the container. However, non-GST registrants in the category of status holders recognized by DGFT under a valid status holder certificate can also avail the facility at their premises.
3(1). Condition for availing the self-sealing procedure:-
(a) Any exporter desirous of availing the self-sealing procedure under the new guidelines, needs to approach the jurisdictional Customs Commissionerate, for seeking the permission for self- sealing of containers;
(b) The exporters who were availing sealing at their factory premises under the system of supervised factory stuffing, will be automatically entitled for self-sealing procedure. All those exporters who are already operating under the self-sealing procedure need not approach the Customs Authorities for the permission of self-sealing.
(c) In case of change of premises for export of goods, a new permission will be sought for before commencement of self-sealing at the new premises.
3(2). Use of Electronic Seal
(a) The exporter shall be required to seal the container, with the tamper proof electronic-seal of standard specification. This seal is also called RFID seal.
(b) RFID seal should have a unique number which should be declared in the shipping bill. The container shall be sealed with the electronic seal before leaving the premises.
(c) The exporter is required to declare the physical serial number of the e-seal at the time of filing the online integrated shipping bill or in case of manual shipping bill before the container is dispatched for the port/ICD
(d) RFID (e-seal) shall conform to ISO 17712:2013(H) and ISO (ITC 18000-6 Class 1 Gen 2 which is globally accepted in industrial application and can be read with the use of UHF Readers-Scanners.
(e) The exporters shall directly procure RFID seal from vendors conforming to standard given above.
(f) The exporter shall be responsible for procuring the seals at their own cost for use in self-sealing.
(g) Each seal shall be one-time-bolt-seal bearing a unique serial number and brand of the vendor in the format ABCD xxxx xxxx, where ABCD stands for the brand of the vendor and X (8digits) is a numerical digit from 0-9
4. The exporter intending to clear export goods on self-clearance (without employing a Customs Broker) shall file the Shipping Bill under digital signature.
5. E-sealing will increase compliance cost of the exporters who will enjoy self-sealing. Normally,OTS Seal comes at a price of approximate Rs.20/- but price of e-Seal varies from Rs. 700/- to 900/-