The Central Board of Indirect Taxes and Customs (CBIC) has announced a significant reduction in the compliance burden for trade stakeholders seeking deferred customs duty payments. Issued on September 3, 2026, Circular No. 39/2026-Customs amends the previous Circular No. 08/2026-Customs, drastically rationalizing the data and documentary requirements for the Eligible Manufacturer Importer (EMI) Scheme.
The EMI Scheme enables eligible manufacturer importers to defer the payment of Customs import duty under the proviso to sub-section (1) of section 47 of the Customs Act, 1962. The simplified application process will officially go live on September 15, 2026.
Key Relaxations in the EMI Application Process
Following representations from the trade sector regarding heavy compliance burdens, the CBIC has fundamentally streamlined the application data (Appendix-I) and required uploads (Appendix-II).
1. Reduction of Mandatory Data Elements (Appendix-I)
Applicants are no longer required to submit an exhaustive list of operational and financial data elements. The CBIC has formally dispensed with the submission of:
- Details pertaining to EXIM documents filed during the previous financial year.
- GST-related granular data, including GSTIN status, declaration of manufacturing activity in FORM GST REG-01, GSTR-3B filing status, aggregate turnover, and GST payments.
- Operational details such as the date of commencement of business, ITC-04 filing particulars, job worker details, and particulars of major raw materials and finished goods with HSN codes.
- Asset details, including factory premises information, property holding rights, and the book value of plant and machinery.
Note on Eligibility: The scheme also accommodates importers who are not strictly manufacturers under Section 2(72) of the CGST Act, provided they send imported inputs or capital goods to a registered job worker without payment of tax under Section 143 of the CGST Act.
2. Streamlined Document Uploads (Appendix-II)
The most substantial relief for EXIM compliance teams is the reduction in mandatory document uploads from ten to just three.
Documents Eliminated: The department will now utilize backend IT systems for verification instead of requiring physical uploads of the IEC, PAN, GST Registration Certificates, GSTR ITC-04 returns, GSTR-9C, audited financial statements for the preceding two years, and premises ownership/lease documents.
The Only 3 Required Documents:
- UDYAM Registration Certificate (Applicable only if MSME status is claimed).
- Chartered Accountant’s Certificate (Must be in the prescribed format and bear a UDIN).
- Authorization Letter (For the authorized signatory).
Updates to the Chartered Accountant Certificate (Appendix-III)
While financial documentation has been reduced, the structural requirements for the Chartered Accountant (CA) Certificate have been updated.
Under the revised Appendix-III, if an applicant presents a negative net worth or negative net current assets for the preceding two financial years, the CA is now explicitly required to furnish specific reasons justifying the financial position within a 100-word limit. This ensures that while front-end documentation is minimized, the financial solvency and capability of the importer remain professionally vetted.
The rationalization of the EMI Scheme presents an immediate cash-flow advantage for manufacturing importers, allowing for the strategic deferment of customs duties. However, securing the precise CA certification and ensuring your remaining legal declarations are perfectly aligned is critical for rapid approval without kickbacks.
At Mundhra Consulting Services, our specialized trade advisory team assists manufacturing exporters and trade compliance leaders across Delhi and pan-India in navigating CBIC schemes. We manage the end-to-end EMI enrollment process, ensuring your application is optimized for the September 15 rollout.
Ensure your import operations maximize their working capital by deferring your customs duties efficiently.
Expedite Your Deferred Duty Enrollment with Mundhra Consulting Services
Consult MCS ExpertsFrequently Asked Questions (FAQs)
The Eligible Manufacturer Importer (EMI) Scheme allows qualifying taxpayers to defer the payment of their Customs import duties, providing significant working capital relief and smoother supply chain operations for manufacturers.
As per Circular No. 39/2026-Customs, the requirement has been reduced to a maximum of three documents: an Authorization Letter, a CA Certificate (with UDIN), and a UDYAM Certificate (only if claiming MSME status).
No. The requirement to upload audited financial statements and GSTR-9C for the preceding two financial years has been completely dispensed with. Verification of these financial metrics will now be handled via appropriate backend IT systems by the CBIC.
Eligible importers can apply using the drastically reduced documentation framework starting September 15, 2026.
Read the Full Regulatory Update: Click here to view or download CBIC Circular No. 39/2026-Customs
Also Read: CBIC NAC Portal Launch: Circular 41/2026-Customs Trade Guide
