Blitz India Business
NEW DELHI: The Directorate General of Foreign Trade operationalised the inventory-based cross-border e-commerce export framework on August 5, through Notification 27/2026-27 and Public Notice 25/2026-27. The registration form is new. The provision that will decide whether the framework is used is the one on reverse logistics.
Start with what “inventory-based” means, because the phrase carries the whole design. Until now, an Indian seller shipping to an overseas consumer through a marketplace exported one parcel at a time, each with its own customs paperwork, at courier rates and courier timelines. An inventory-based model lets goods be moved abroad in bulk first, held in a warehouse close to the customer, and shipped domestically once ordered. That is how every large global e-commerce seller operates, and it is the difference between a five-day delivery promise and a fifteen-day one — which, on a consumer platform, is the difference between a listing that ranks and a listing that does not.
Bulk out, singles back: the economics of consumer e-commerce exports have always broken on the return leg, where a low-value parcel costs more to repatriate and re-import than it is worth.
Nobody builds an export business on the outbound leg alone. The seller who cannot account for a returned parcel cannot close the books, and cannot claim the benefit.
At a Glance
• Instruments: Notification No. 27/2026-27 and Public Notice No. 25/2026-27, both dated August 5, 2026, under the Foreign Trade Policy 2023
• Covers: registration, inventory management, compliance, reverse logistics and dispute resolution
• New form: Aayaat Niryaat Form 9A, for registration of an Exporter-on-Record
• Scope: goods manufactured or produced in India
• Responsibilities defined: for e-commerce operators and for Indian suppliers, across the export lifecycle
• Stated objectives: wider participation by manufacturers, traders and MSMEs in global e-commerce supply chains, with transparency, timely payment and effective transfer of export benefits
Now the return leg, which is where every previous attempt at this has failed. Consumer e-commerce carries return rates that in some categories run to a quarter of orders. Under a per-parcel export model, a returned item is a customs problem in two countries: it has left India under an export declaration that must be reconciled, and it must re-enter India as an import, on which duty is prima facie payable, unless the paperwork establishes it as returned Indian-origin goods. Small exporters routinely abandoned such consignments rather than deal with it — and an abandoned consignment is not merely a lost sale, it is an unreconciled export entry that jeopardises the seller’s remittance record and any benefit claimed against it. A framework that codifies the return path is therefore not an administrative appendix. It is the clause that makes the rest of the model bankable.
The Exporter-on-Record construct in ANF 9A is the second piece of the same puzzle, and it answers a question that has quietly blocked this trade for years: when a thousand small suppliers’ goods sit in one overseas warehouse under one platform’s account, who is the exporter? Naming a single registered entity as the Exporter-on-Record gives customs, the banking channel and the tax authority one accountable party, while leaving the underlying supply base as wide as it needs to be. For an MSME in Tiruppur or Moradabad, the practical consequence is that it can sell into a foreign consumer market without itself becoming an exporter of record, and can still receive its payment through a documented channel. The work now shifts from the notification to the plumbing — how quickly registrations are processed, how the returns reconciliation actually behaves at a port, and whether the export benefits reach the supplier rather than stopping at the platform. Those are answerable questions, and the first data on them will be visible within a quarter.