1. © Confederation of Indian Industry Task Force on Transaction Cost Airports: Mumbai, Delhi & Chennai Seaport: Chennai

2. © Confederation of Indian Industry Some observations Better management of loading and unloading at the port/terminal. Let Export trucks be allowed 24X7 as it would even out the cargo clearance at the cargo facility. As of now, extreme rush after 3 PM. Have one unique identification number for each export consignment instead of many numbers ( could be shipping bill number ) like AWB, MAWB, Carting application etc Integrate the network systems of the custodian, CFA, DGFT as all these systems should be talking to each other. This will reduce duplication of data feeding. Have one single comprehensive form with the information being filled up as and when it comes in. This will remove the repetition of data filling by the PO (Preventive officer), EO, ( Examination Officer ), Appraiser Let it be assembly line seating arrangement for cargo clearance. mainly at Mumbai and Chennai facility. In Delhi seating is better

3. © Confederation of Indian Industry Contd…. About 30 % of the export consignments undergo examination at port. This figure needs to come down which might happen with RMS. Non availability of containers/vessel at the right time and Freight consolidation by the forwarders takes a lot of time. Thus reduce the storage free time at the Cargo facility from 72 hours to 24 hours. Introduce the Shipping Trade Practices Act. It is still at the Bill stage.

4. © Confederation of Indian Industry Some issues: The insurance agent needs to be informed within 24 hours of shipment leaving the factory, otherwise Agent will not pay premium. Billing breakup generated should be used for insurance purpose. At times, the shipping lines give premium to exporters for using their shipping lines, but the system does not accept 0 value and the shipping bill is not generated. System should accept a 0 value if not negative value. In classification, advance ruling of customs should be there. Classification of goods should be done before and not left at the discretion of the officer. For repeat products there should be self-declaration. After physical examination, repacking the consignment an issue.Also the Shipping bill shows that, not opened for physical examination by customs. The buyer claims damages. Suggestion : the official doing physical examination can have a sealing tape with opened by customs written.

5. © Confederation of Indian Industry Some other issues Contd… Sample testing--look into number of consignments, sample size, from factory for sample testing, goes to lab outside the Airport for testing, clarity of testing authority ( eg wildlife ) Allied Acts add to Transaction cost big time. Need to look into it Once credentials of exporters established, like Status holder exporter then ease the process If the exporter is taking no incentives then for factory stuffed cargo no examination should be required. Also pelletisation should be allowed at offsite facility. Also fragile cargo, like fish, flowers should be handled at an offsite facility.

6. © Confederation of Indian Industry Some other issues Contd… At the time of applying for waiver and transferability redemption, a certificate by CA is required, even if it is SION based. CA Certificate should be dispensed with as license is issued by SION basis. For all Reward Schemes and Export Obligation of Advance Authorisation and EPCG Schemes, EDI should be established with customs for shipping bills. The requirement of hard copy of Shipping bills should be done away with. When applying for FPS scheme, copy of IE Code has to be attached. Should be done away with as it is available online

7. © Confederation of Indian Industry Specific Case of Leather Exports: When the cargo reaches the Cargo facility, checked by Cargo agent along with custodian for weight and measurement. If it does not tally then amendment required to be made. If it is OK then following documents are required in 6 sets: 1. Invoice 2. Packing list 3. Shipping bill Following Self Declarations Required which can be done away with Leather declarationDispense with as it is eligible for drawback for all leather and leather products whether it is imported leather used or indigenous finished leather use. Cenvat declarationDispense with as leather garments and finished leathers are non cenvatable. SDF Declarationfor foreign exchange

8. © Confederation of Indian Industry Cont.. Leather exporters need CLRI report. The Air customs accepts while the sea cargo does not accept the CLRI report. Also finished leather products are held by the customs for 3-4 days for examination particularly at Sea customs. ( though the EXIM Policy says that any Export consignment cannot be held for more than 24 hours )

9. © Confederation of Indian Industry DGFT Related issues: E-BRC to be accepted by Central excise and Customs also. RCMC not required SSI / IEM / Heavy Industries License – Manufacturing Item. The same need to incorporated in the licence. No need to be so specific As per Para. 4.7.1 of HBP Gives provision of Rs. 5 cr of import without Bank Guarantee, whereas customs is not accepting, but they follow Circular 58/2004-Cus 21.10.04. even in para 2.20 of HBP says that BG is as per Circular 58/2004-Cus 21.10.04 EPCG- Export Obligation – Block wise ( 4 & 6 yrs) to be re-looked FMS / FPS ( All types of Incentives) is not accepted by all central Excise against Excise Duty No TED - Benefits for who can avail Cenvat Credit. Unnecessary documents like duty paid certificate and Non availment of cenvat credit Certificate of Origin to be issued by Govt. department (JDGFT / Inspection Agencies) without fees

10. © Confederation of Indian Industry Port Trust At the time of export, Boat - note should not be required. (Tally clerk already there and Wharfage is paid to the porters)

11. © Confederation of Indian Industry Central Excise Export Bond should not mention Chapter Classification Export Bond Value to be irrespective of Excise Duty Clarification of tariff should be to the benefit of exporter or importer Time Bound at DGFT – 9.11 of HBP why not at Customs and central Excise Triplicate copy of ARE-1 to be signed by the range Superintendent. This leads to more paper work and delay in incentives and POE. Original and duplicate of A.R.E.1 to be stopped. The document should be sent online to all other related government departments

12. © Confederation of Indian Industry Customs Shipping Bill should go online to DGFT / JDGFT E.P Copy generation late in customs. Total incentive or Proof of Export Generation is stopped. This can happen at the time of release of Shipping Bill itself as in ICDs Insurance Certificate / Freight Certificates should not be required Excess Duty Any Commissionerate should accept Automatic process in section – 74, SVB- EDD Refund, & DBK (AIR). But not happening Daily duty allocation of customs officials (Exports & Imports)--The rostering can move to a system generated roster. Drawback section of Customs at times asks for same export documents again. Should be done away with as leads to delay in availing drawbacks.

13. © Confederation of Indian Industry Mumbai Airport Waiting Time of 3-4 hours plus (in truck que and ramp que), due to Manual Ramp Operations and Lack of IT Current Process: Presentation of physical Annexure C document, followed by manual entry of details into system, and assignment of Examining Officer (EO). This is followed by manual carting of export cargo into cargo terminal. Suggested Changes EDI submission of Annexure C information online with reference to HAWB and MAWB. RFID scan enabled entry registration process at terminal ramp. EO assigned automatically post-scan Export RMS allows segregation of shipments into those requiring physical examination and those not at the RFID scan stage. Carting into separate zones based on this segregation Mechanical Carting: Mandating Terminal Operator in Major Airports to use ramp-carts

14. © Confederation of Indian Industry Reduction of Transaction Cost in Exports 1. CENTRAL EXCISE 2. CUSTOMS3. PORT TRUST4. DGFT To Exempt from Excise Duty from Factory For Clearance of Goods To Load Cargo in Vessel To Collect Incentive/ Redemption S. No. Present Required Documents 1B1 - BondExport Invoice ANF 2IEC CopyPacking List Chartered Engineer and CA Certification 3RCMC CopyShipping BillShipping Bill CopyBRC 4PAN Copy(i) Exporter CopyBoat - NoteEP Copy of Shipping Bill 5IEM Copy(ii) Exchange Control Copy RCMC 6Export Order Copy(iii) Export Promotion Copy 7CT - 1Declaration 8ARE - 1Marine Insurance Certificate of Origin

15. © Confederation of Indian Industry Documents Sufficient to carry out Transaction 1. CENTRAL EXCISE 2. CUSTOMS3. PORT TRUST4. DGFT 1To be linked with EDI – Customs Shipping BillBoat Note not Required EC - to be Compulsory - Online 2 B1-Bond, Export Order Copy, ARE- 1 DeclarationTo be linked with EDI - Customs & DGFT E-BRC 3 All other documents to be scanned and sent to Customs from Central Excise Shipping Bill - To be linked with EDI - DGFT from Customs 4To be linked with EDI – Central Excise & DGFT RCMC - Not Required

16. © Confederation of Indian Industry Thank you