Regulatory Update. The Central Government, through DGFT Notification No. 27/2026-27-DGFT dated 5 August 2026 issued under Section 5 of the Foreign Trade (Development & Regulation) Act, 1992 and paragraph 1.02 of the Foreign Trade Policy 2023, introduced an Inventory-based Cross-border E-Commerce Facilitation Framework with immediate effect. The Framework defines Exporter-on-Record (EOR), Seller-on-Record (SOR), Export Inventory, Domestic Inventory and Export Rebates and Refunds (ERR), and enables export-only inventory operations through registered EORs in accordance with the Consolidated FDI Policy. It prescribes eligibility conditions, including export of only Indian-origin goods, transfer of title only against confirmed export orders, and prohibition on speculative inventory build-up. The Framework requires EORs to maintain segregated, traceable export inventory and a digital repository, make payment to SORs within seven days of acceptance or deemed acceptance of goods, claim and distribute eligible Export Rebates and Refunds in proportion to FOB value after permissible administrative charges, manage reverse logistics at their own cost, prohibit sale of returned consignments in the domestic market, and, where practicable, utilise notified E-Commerce Export Hubs for operations.
Government of India
Ministry of Commerce & Industry
Department of Commerce
Directorate General of Foreign Trade
Vanijya Bhawan, New Delhi
Notification No. 27/2026-27-DGFT | Dated: 5th August 2026
Subject: Introduction of Inventory-based Cross-border E-Commerce Export Framework under FTP -regarding
5.0.(E) – In exercise of powers conferred under Section 5 of the Foreign Trade (Development & Regulation) Act, 1992, read with paragraph 1.02 of the Foreign Trade Policy 2023, as amended from time to time, the Central Government hereby makes the following amendments in the Foreign Trade Policy 2023 with immediate effect:
D. Inventory-based Cross-border E-Commerce Facilitation Framework
9.13 Definitions
For the purposes of the Inventory-based Cross-border E-Commerce Facilitation Framework, unless the context otherwise requires, the following expressions shall have the meanings assigned to them:
i. ‘Exporter-on-Record (EOR)’ means an entity holding a valid IEC and GSTIN, registered with DGFT under the Inventory-based Cross-border E-Commerce Facilitation Framework, exporting and selling goods procured from one or more Sellers-on-Record to buyers located outside India. Where an e-commerce entity proposes to undertake export operations under Para 5.2.15.2.5 of Consolidated FDI Policy as amended vide Press Note No. 3 (2026 Series) dated 23.07.2026, such operations shall be carried out through a separate legal entity incorporated for this purpose. At the time of registration or amendment as the Exporter-on-Record, such entity shall disclose its shareholding pattern and the nature of its ownership or control relationship with the e-commerce entity.
ii. ‘Seller-on-Record (SOR)’ means an entity registered in India under the applicable Goods and Services Tax law, supplying goods produced in India to the Exporter-on-Record against the Exporter-on-Record’s confirmed export orders, for the purpose of export to buyers located outside India.
iii. ‘Export Inventory’ means goods procured by the Exporter-on-Record from a Seller-on-Record against a confirmed export order and held exclusively for export, which are designated, recorded, and traceable in the Exporter-on-Record’s records as export-designated stock.
iv. ‘Domestic Inventory’ means goods held by the Seller-on-Record for supply in the Domestic Tariff Area (DTA).
v. ‘Export Rebates and Refunds’ (ERR) means cash or cash-equivalent export incentives, rebates, refunds or remissions received by the Exporter-on-Record upon export of goods, including Duty Drawback, RoDTEP, RoSCTL or any other notified scheme involving direct monetary or transferable financial benefit. Export Rebates and Refunds shall not include non-transferrable duty remission instruments such as Advance Authorisation or EPCG Authorisation. Refund of taxes to Exporter-on-Record under the Central Goods and Services Tax Act, shall be an Exporter-on-Record entitlement and is not part of Seller-attributable Export Rebates and Refunds.
9.14 Objective of the Framework
The objective of this Framework is to enable e-commerce exports through an inventory model under which the Exporter-on-Record holds inventory for export, undertakes export-related processes, exports goods, and assists and enables Sellers-on-Record to access global markets.
9.15 Eligibility and Conditions for Holding of Export Inventory
i. An e-commerce entity, other than a marketplace e-commerce entity, as defined under the Consolidated FDI Policy, may undertake export-only inventory operations through an Exporter-on-Record registered under this Framework. Such Exporter-on-Record may hold inventory of goods exclusively for export through e-commerce and undertake all export-related activities, subject to this Framework and the Consolidated FDI Policy, as in force from time to time.
ii. Only goods of Indian origin shall be eligible under this Framework. The Seller-on-Record shall be responsible for ensuring and declaring the correct origin of goods in accordance with applicable laws and the relevant origin criteria.
iii. A list of ineligible goods may be notified by DGFT from time to time.
iv. Title to goods shall pass from the Seller-on-Record to the Exporter-on-Record only against a confirmed export order received by the Exporter-on-Record from a buyer located outside India. Speculative transfer of title or inventory build-up without a confirmed export order is not permitted under this Framework.
9.16 Export Inventory Management and Segregation
The Exporter-on-Record shall be responsible for distinctly identifying, segregating and maintaining Export Inventory, and for maintaining a digital repository enabling identification, tracking and traceability of all Export Inventory, including records relating to procurement from Seller-on-Record, inventory status, and linkage with export documentation. The manner, form and standards for identification, segregation and maintenance of Export Inventory, and for the digital repository referred to above, shall be as prescribed under the Handbook of Procedures.
9.17 Payment to the Seller-on-Record and Export Rebates and Refunds (ERR)
i. The Exporter-on-Record shall make payment to the Seller-on-Record promptly upon acceptance or deemed acceptance of the goods, and in any event no later than 7 days from the date of acceptance or deemed acceptance of the goods by the Exporter-on-Record. Payment to the Seller-on-Record shall not be contingent upon or delayed on account of receipt of payment from the buyer outside India, return of goods by the buyer outside India, or any other event outside the control of the Seller-on-Record.
ii. The Exporter-on-Record shall be entitled to claim Export Rebates and Refunds in accordance with provisions of the FTP and relevant notifications.
iii. The Exporter-on-Record shall apportion and disburse the Export Rebates and Refunds among the Sellers-on-Record whose goods form part of the Export Consignment, in proportion to the Free-on-Board (FOB) value attributable to the goods of each such Seller-on-Record as declared in the Shipping Bill for that Export Consignment.
iv. The Exporter-on-Record may retain an administrative charge from the Export Rebates and Refunds. The balance amount, after deduction of such administrative charge, shall constitute the Seller-attributable Export Benefits and shall be disbursed to the Seller-on-Record.
v. The pass-through obligation under sub-para (iii) above shall become operative in respect of an Export Consignment only upon the Exporter-on-Record having claimed Export Rebates and Refunds in respect of that consignment.
9.18 Reverse Logistics and Returned Consignments
i. The Exporter-on-Record shall own and manage all reverse logistics processes for returned or rejected consignments.
ii. Returned or rejected consignments shall not, under any circumstances, be sold or supplied in the domestic market by the Exporter-on-Record, whether directly or through any other person or entity.
iii. The costs associated with the reverse logistics shall be borne by the Exporter-on-Record.
9.19 Utilisation of E-Commerce Export Hubs (ECEHs)
The Exporter-on-Record shall, to the extent practicable, utilise notified E-Commerce Export Hub (ECEH) infrastructure for operations under this Framework, subject to the operational readiness and available capacity of such facilities.
Effect of this Notification: This Notification introduces an Inventory-based Cross-border E-Commerce Facilitation Framework enabling export-only inventory operations through registered Exporters-on-Record in accordance with the Consolidated FDI Policy. The Framework prescribes the eligibility conditions, operational obligations, inventory management requirements and other operational requirements.
This is issued with the approval of the Ministry of Commerce & Industry.
(Lay Agarwal)
Director General of Foreign Trade
& ex-officio Additional Secretary to the Govt. of India
Email: dgft@nic.in
[Issued from F. No. 01/89/180/23/AM-25/PC-9-Part-(2)]
