Eligible Manufacturer Importer scheme: how manufacturers can defer import customs duty to the next month

Normally an importer pays customs duty before the goods leave the port. The Eligible Manufacturer Importer scheme, EMI for short, lets approved manufacturers clear the goods first and pay the duty later. The duty is not waived. Only the date moves.

CBIC set out the scheme in Circular 08/2026-Customs of 28 February 2026. It rests on Notification 12/2026-Customs (N.T.) of 1 February 2026, which adds Eligible Manufacturer Importers to the importers allowed to defer duty under the proviso to section 47(1) of the Customs Act, 1962. The notification permits the deferral "up to the 31st March, 2028". The circular says the facility is available from 1 April 2026.

When the duty falls due#

The circular says the facility is governed by the Deferred Payment of Import Duty Rules, 2016, as amended. Notification 13/2026 rewrote the due dates in rule 4, from 1 March 2026. The circular repeats them:

• "For goods corresponding to Bill of Entry returned for payment from 1st day to the last day of any month other than March, the duty shall be paid by the 1st day of the following month."
• For Bills of Entry returned for payment from 1 to 31 March, "the duty shall be paid by 31st March."

In practice, a Bill of Entry returned for payment on 3 June is due on 1 July, and so is one returned on 28 June. The wait runs from a day to about a month, depending on the date. March is the exception: nothing carries past 31 March.

The PIB release describes the cash-flow point: approved manufacturers "will be able to clear imported goods without paying Customs duty at the time of clearance", and pay "on a monthly basis". You may also pay earlier. The circular lets an EMI select the challans in the deferred period and pay "anytime, even before the due date".

Who can apply#

Paragraph 3 of the circular lists fifteen conditions. The main ones:

• Manufacturer and importer. You must be an importer and a manufacturer as defined in the CGST Act. If you are not a manufacturer, you qualify only if you send inputs or capital goods, without paying tax, to a job worker under section 143 of the CGST Act. In that case you must have filed the last two half-yearly ITC-04 returns, and the job worker must be registered as a factory or manufacturing unit.
• Valid IEC and an active GST registration.
• Customs footprint. At least 25 Bills of Entry and Shipping Bills filed in the previous financial year. For an MSME the minimum is 10. Your export shipping bills count towards the number.
• Turnover. Annual aggregate turnover of all GSTINs under your PAN must exceed Rs 5 crore in the last financial year.
• Time in business. Business activity for at least two financial years before you apply.
• GST compliance. All pending GSTR-3B returns filed, and no GST collected but not deposited. The same test applies to central excise and service tax.
• Solvency. Financially solvent in the two financial years before the application, with a Chartered Accountant's certificate in the prescribed form.
• Clean record. Neither you nor your proprietor, partners or directors arrested or convicted, or facing pending prosecution, under the Customs Act, Central Excise Act, Chapter V of the Finance Act 1994, the CGST or SGST Act, or any other law. An earlier EMI application must not have been rejected, and an earlier EMI approval not suspended, for false information or forged documents.

The circular adds that existing AEO-T1 entities, MSMEs included, that meet these conditions can also apply. It expects approved EMIs to obtain AEO T2 or T3 accreditation before the facility ends in March 2028.

How to apply and how it works#

1. Apply online. Register at www.aeoindia.gov.in and use the "Eligible Manufacturer Importer" tab. Applications opened on 1 March 2026. You fill the form in Appendix-I of the circular and upload the documents in Appendices II and III.
2. Wait for approval. A designated officer of the Directorate of International Customs, CBIC, approves the application and updates the customs system. The circular says no further action is needed from you to use the facility.
3. Set up your nodal person. After approval, the person you authorise gets an ICEGATE login. This person confirms all customs transactions on your behalf.
4. Flag each Bill of Entry. Mark "D" in the Payment Method column. Your nodal person then confirms the intent with a one-time password sent to their registered email or phone, and can confirm several Bills of Entry at once. The circular says customs clearance is given "only on such authentication".

The circular also says the designated officer "may suspend/revoke" the approval if you stop meeting the eligibility conditions at any point. On a missed payment, the circular only says officers should watch for timely payment and may report non-payment to CBIC. It states no consequence. The 2016 Rules govern that, so read them or ask the helpdesk before you rely on a late payment. CBIC's EMI helpdesk is emihelpdesk-dic@gov.in.

What to do on Monday#

1. Check your turnover, years in business and GSTR-3B status against the list above, GSTIN by GSTIN.
2. Count your Bills of Entry and Shipping Bills for the last financial year.
3. Ask your Chartered Accountant for the solvency certificate in the prescribed form.
4. If you qualify, apply on the AEO portal. Do not build deferred duty into your cash plan until the approval arrives.
5. Once approved, work out the month-end dates for each Bill of Entry. Duty on a late-month import is due almost at once. A longer payment term to your own buyer then needs a plan for the gap between that date and the day you are paid.