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DGFT seeks industry feedback on draft internal compliance programme for export of dual-use or SCOMET items
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Shardul Nautiyal, Mumbai
July 17 , 2025
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In a move aimed at strengthening export control mechanisms, the Directorate General of Foreign Trade (DGFT) has sought inputs from pharmaceutical exporters, the Pharmaceuticals Export Promotion Council of India (Pharmexcil), industry associations, and subject matter experts on a Draft Internal Compliance Programme (ICP) Document for the export of dual-use Special Chemicals, Organisms, Materials, Equipment and Technologies (SCOMET) items.
Dual-use items, classified under the SCOMET list, can have both civilian and military applications. As such, they are subject to stringent international export control norms.
The ICP framework is designed to help exporters establish a culture of compliance and mitigate the risk of unauthorized transfers or misuse of SCOMET items, in accordance with Indian laws and regulations on export controls.
This initiative aligns with the provisions under Chapter 10 of the Handbook of Procedures (HBP) 2023 and Para 1.07A of the Foreign Trade Policy (FTP) 2023, which mandates stakeholder consultation in policy formulation and amendments. The draft management system requirements for ICP for dual-use items has been prepared in collaboration with the Bureau of Indian Standards (BIS), aiming to standardize compliance protocols and ensure robust internal safeguards for exporters dealing with sensitive goods.
General Authorization Policies under Chapter 10 of the HBP 2023, also outlines provisions for submission of ICP document (signed and stamped by compliance manager of the company) under which the exporter is required to submit an ICP Checklist.
The DGFT has extended a 10-day window for stakeholders to review the draft and provide their views. All suggestions, comments, and feedback must be submitted via email to scometdgft@gov.in within the stipulated time frame.
This move is particularly relevant to the pharmaceutical sector, which often deals with dual-use biological materials and chemicals. With global scrutiny intensifying around sensitive exports, the introduction of a standardized ICP is expected to bolster India’s credibility as a responsible trading partner while minimizing the risk of trade disruptions.
India’s FTP governs the export and import of goods and services. Under the FTP, a list of items have been identified whose export is to be controlled. This because of the dual-use character of these items. Dual-use refers to the nature of an item, allowing it to be used in military applications or in weapons of mass destruction (WMD), as well as in civilian/industrial applications.
India is a member of three multilateral export control regimes: the Wassenaar Arrangement, Missile Technology Control Regime, and Australia Group, which have contributed to the goals of non-proliferation by issuing guidelines for export controls and lists of specific items whose exports are to be regulated.
As per national laws and regulations, export of technology related to items specified under the SCOMET list is also controlled and requires an authorisation from the licensing authority.
Having an effective ICP helps organisations integrate requirements from export controls with their business operations.
ICP is pre-requisite for obtaining the Global Authorisation for Inter-Company Transfers (GAICT) scheme of the Directorate General of Foreign Trade (DGFT) and Open General Export License (OGEL) schemes of the DDP.
GAICT schemes offers significant practical benefits to compliant exporters. It authorises the exporter to export a range of items to the exporter’s affiliated companies in several countries. Due to its scope, applicants must fulfil certain requirements to establish their credentials in export control compliance. The GAICT scheme requires the applicant to implement an ICP capable of ensuring that the global export licence is utilised responsibly.
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