DAY 17 │ E-COMMERCE EXPORTS PLAYBOOK 2025

0 │ Why these matters

The Foreign Trade Policy 2023 dedicates an entire sub-chapter to “Cross-Border E-Commerce” and targets USD 200-300 billion of on-line exports by 2030. CBIC has now hard-wired duty refund schemes and faster clearance into the courier workflow (Circular 15/2024-Cus., 12 Sept 2024), while Circular 28/2023-Cus. allows advance assessment of Courier Shipping Bills (CSB-V) to cut dwell time to minutes. Put together, these measures finally give small sellers the same benefits that large exporters have long enjoyed in cargo mode.

1 │ Regulatory frame in one view

2 │ Which declaration, which limit?

3 │ Step-by-step playbook

1. On-board essentials – IEC, Goods and Services Tax Letter of Undertaking, Authorised Dealer (AD) Code, and e-commerce platform registration.
2. Choose route – Courier (CSB-V) if consignment ≤ ₹10 lakh; else cargo SB.
3. File declaration – authorised courier files CSB-V via ECCS; advance assessment possible (Circular 28/2023-Cus.).
4. Map AD Code – ensures automatic feed to RBI-EDPMS and later e-BRC generation.
5. Collect payment – via platform collection account; funds credited to seller’s account within seven days of NOSTRO receipt.
6. Realise within nine months – FEMA rule; variance ≤ 25 percent, else AD-Bank approval required.
7. Claim refunds
   • Drawback / RoDTEP / RoSCTL scroll auto-generates on ICES after Let-Export Order (Courier or Cargo).
   • GST: file RFD-01 on single-click LUT route; attach CSB-V or Shipping Bill number.
8. Reverse logistics – re-imports duty-free if identity proven and export benefits repaid (Notf. 45/2017 & 46/2017).

4 │ Forms & Codes cheat-sheet

5 │ Three pain-points solved by the 2024 circular

6 │ Inter-link to FEMA and banking

• Collection model – export proceeds land first in an offshore NOSTRO account of an AD-Category I bank, then in the platform’s domestic collection account, and finally in the seller’s bank within seven days.
• Realisation window – nine-month rule continues; reduction up to 25 percent needs AD-bank nod.
• EDPMS closure fee – currently ₹1500–₹3000 per shipping bill; industry seeks waiver or ad-valorem model.

7 │ Comparison with China (for context)

8 │ Action checklist for small sellers

1. Register IEC and obtain AD-Code.
2. Sign up on marketplace and map bank account for NOSTRO ⇒ collection transfer.
3. Always mention “E-COM” flag on CSB-V/SB to auto-trigger refund scroll.
4. Reconcile each shipping bill in EDPMS; download e-BRC immediately.
5. Keep LUT valid for GST zero-rating; file refund within two years.
6. Maintain order-ID, payment-ID and product photo archive for returns identification.

Process Flowchart – Launching a Cross-Border E-Commerce Export Channel

Start
↓

1. Product & Market Scan
   └─ identify HS code, SCOMET status,
   target country duties, platform fee
   ↓
2. Compliance Foundation
   ├─ Obtain Importer-Exporter Code (IEC)
   ├─ File GST Letter of Undertaking for zero-rated sales
   └─ Map Authorised-Dealer (AD) Code on ICEGATE & RBI-EDPMS
   ↓
3. Platform & Payments On-Boarding
   ├─ Sign marketplace agreement (Amazon Global, Etsy, etc.)
   ├─ Open NOSTRO-linked collection account with AD bank
   └─ Integrate order API → warehouse WMS
   ↓
4. Customs & Logistics Configuration
   ├─ Choose Courier (CSB-V ≤ ₹ 10 lakh) or Cargo SB
   ├─ Pre-assess CSB-V (Circular 28/2023) for instant LEO
   └─ Set up automated SKU ↔ HS ↔ Duty-refund mapping
   ↓
5. First-Mile Execution
   ├─ Print data-rich shipping label (order-ID, CSB-V no.)
   ├─ Hand over to authorised courier at Export Hub
   └─ Receive Let Export Order (LEO) + ICES scroll
   ↓
6. Post-Shipment & Finance
   ├─ Payment hits platform NOSTRO → domestic account ≤ 7 days
   ├─ e-BRC auto-generated on EDPMS
   ├─ Drawback / RoDTEP scroll credited to exporter bank
   └─ File GST RFD-01 refund (if ITC surplus)
   ↓
7. Scale & Optimise
   ├─ Use repeat-pick lists, HS auto-classification AI
   └─ Enrol in Dak Niryat Kendra for rural fulfilment
   End

Case Study – How TaxTru Business Advisors LLP Built “ZenHerbal’s” Global E-Store

Disclaimer
The information shared in this post (and throughout the 30-Day Customs Series) is provided solely for general, educational purposes. It is not intended to be—and should not be relied on as—legal advice or a substitute for professional guidance tailored to your specific facts and jurisdiction.

1. No attorney-client relationship is created by reading, commenting on, or sharing these materials.
2. Customs statutes, regulations, circulars and court rulings are subject to change, and their application can vary with minute factual differences.
3. While every effort is made to quote current law and landmark judgments accurately, no warranty express or implied—is given as to completeness, timeliness or fitness for a particular purpose.
4. You should consult a qualified customs or trade lawyer, or other licensed professional adviser, before acting (or refraining from acting) on any information herein.
5. The authors, contributors and publishers disclaim all liability for any loss, damage or penalty arising from reliance on this content, whether in contract, tort (including negligence) or otherwise.
6. By continuing to read or share this material, you acknowledge and accept the above terms.

About the Author & Office Locations

CA Navjot Singh is a seasoned indirect-tax specialist with deep expertise in Customs, Foreign Trade Policy and GST. He delivers strategic advisory and hands-on execution to conglomerates, Fortune 500 companies and high-growth enterprises.

• Key architect of long-term retainership models that pre-empt audit objections and mitigate litigation risk.
• Designs India-wide GST frameworks that optimise tax and cash-flow while dovetailing cross-border VAT regimes (EU VAT, GCC VAT).
• Advises clients through assessment proceedings, prepares robust submissions and representations, and drafts precise replies to show-cause notices, audit objections and spot memos.
• Represents taxpayers before adjudicating authorities, the Tribunal, the Sales-Tax Revisionary Board and the West Bengal Taxation Tribunal.
• Conducts comprehensive GST-impact assessments, incentive-scheme evaluations and cash-flow modelling; recommends mitigation strategies as benefits phase out.
• Prepares advance-ruling applications and engages with GST-Council committees to shape interpretative guidance.
• Develops end-to-end dispute-resolution roadmaps, from pre-litigation negotiation to appellate and judicial forums.

TaxTru Business Advisors LLP
Primary Office (Delhi-NCR)
Unit No. 702, Plot No. 29, Sector 142, NOIDA, Uttar Pradesh 201305
Branch Offices
Gurugram: 313A, 3rd Floor, Iris Tech Park, Sector 48, Gurugram, Haryana 122018
Mumbai: C-20, G-Block Road, Bandra Kurla Complex, Bandra (East), Mumbai 400051
Associate offices across other key metros enable pan-India support