The registrations required for an export business in India follow a natural order: the IEC from DGFT first, then the product registration or RCMC, the Customs set-up (ICEGATE and AD code) and a GST Letter of Undertaking before the first invoice. A goods exporter shipping through a port needs at least four of them, and more for food, seafood or spices; APEDA registration, which costs ₹5,900 for 5 years, doubles as the RCMC for agricultural and processed food. This guide sets out the sequence, how APEDA and RCMC registration work, a worked example and what must be renewed each year.
In what order should a new exporter get registrations?
Start with the business itself, then the IEC, because the product and Customs registrations ask for it. APEDA, for example, issues its registration only after the exporter has an IEC from DGFT. Customs registrations and the LUT come last, just before the first shipment.
- Set up the entity with its own PAN, a bank account in its name and a valid business address. DGFT asks for all three before it issues an IEC.
- Register for GST if you have not. An LUT can be filed only by a registered person.
- Apply for the IEC on dgft.gov.in in form ANF-2A. Check the format of any IEC you receive with the IEC Code Lookup.
- Get the product registration or RCMC. APEDA and the export promotion councils issue it through DGFT's e-RCMC system (form ANF-2C); MPEDA and the Spices Board register exporters under their own rules.
- Food exporters: get a Central FSSAI licence.
- Get a digital signature for the authorised person and register on ICEGATE.
- Register your AD code and refund bank account with Customs on ICEGATE, once, at any one port.
- File the LUT in form GST RFD-11 before you raise the first export invoice.
For step 7, Customs at Nhava Sheva describes the process in Public Notice 130/2020: the bank issues an authorisation letter, the exporter registers on ICEGATE, generates an IRN on e-Sanchit and submits the AD code and IFSC in the Bank Account Management module for approval. Since 14 June 2022 an AD code registered at one port works at every customs location, and changes are made at the port of registration (JNCH Public Notice 33/2022-23). Drawback and IGST refunds go to the refund account registered with its IFSC.
How APEDA registration works on the DGFT e-RCMC portal
Since 17 July 2023, APEDA issues its registration as an RCMC through DGFT's e-RCMC service, after the exporter has an IEC. The fee is ₹5,900 (₹5,000 plus 18% GST), the registration is valid for 5 years, renewal costs ₹5,900 and amendments are free.
What you upload depends on how you export, per APEDA's registration procedure:
| Type of exporter | Documents |
|---|---|
| Merchant exporter | Signed and sealed copy of the IEC |
| Manufacturer, or manufacturer and merchant | IEC copy plus proof of manufacturing for the product |
The proof of manufacturing also varies by product: an FSSAI licence or Udyam certificate for most processed foods, cereals, pulses, dairy, meat and honey; the Department of Horticulture for floriculture and seeds; and the Excise Commissioner for alcoholic beverages. APEDA covers scheduled products such as fruits, vegetables, basmati and non-basmati rice, pulses, dairy, meat, poultry, honey, bakery, confectionery and beverages. Seafood goes to MPEDA and spices to the Spices Board instead.
When does an exporter need an RCMC, and when not?
An RCMC is needed to apply for an authorisation to import or export, other than for restricted items, or for any benefit or concession under the Foreign Trade Policy (para 2.57). It is not needed for a consignment whose FOB value is ₹10,000 or less. Outside products a commodity board registers, such as APEDA's, MPEDA's or the Spices Board's, an exporter claiming no FTP benefits can ship without one.
The rules on who issues it are in paras 2.79 to 2.84 of the Handbook of Procedures:
- You declare your main line of business, and the council for that product issues the RCMC.
- If no council or board covers your product, the RCMC comes from FIEO. A multi-product exporter with no settled main line may also choose FIEO.
- The Spices Board's CRES and the Coir Board's certificate of registration count as an RCMC (FTP para 2.57(b)).
- Report a change in ownership, constitution, name or address to the council within one month.
- A council can de-register a holder for breaking its conditions, after a show cause notice. An appeal lies to DGFT within 45 days.
An RCMC is valid from 1 April of the licensing year in which it is issued, for five years ending 31 March, unless otherwise specified. An RCMC issued on 15 November 2026 therefore counts from 1 April 2026 and runs to 31 March 2031.
Worked example: registrations for a basmati rice exporter
A GST-registered rice exporter shipping by sea needs six registrations, or seven if it has no digital signature, and pays ₹13,900 in government fees in the first year, plus GST on the FSSAI fee.
Example. Greenfield Grains LLP (a made-up firm) in Pune will export basmati rice by sea from Nhava Sheva, is GST-registered and wants Foreign Trade Policy benefits. The finder lists the IEC, the LUT, the AD code, ICEGATE, a DSC if it has none, APEDA registration and a Central FSSAI licence. No separate RCMC is needed: the APEDA registration is the RCMC. The government fees are ₹500 for the IEC, ₹5,900 for APEDA (once for 5 years) and ₹7,500 a year for the FSSAI licence, plus GST as applicable: ₹13,900 in the first year. ICEGATE has no government fee.
If the same firm also exported curry powder, the finder would add the Spices Board's CRES, since spices fall outside APEDA.
What changes for service and software exporters?
A service exporter needs an IEC only when it claims benefits under the Foreign Trade Policy (FTP para 2.05(a)). Services leave no shipping bill, so the AD code and ICEGATE steps drop out. A GST-registered service exporter still needs an LUT to export without paying IGST.
Rule 96A of the CGST Rules adds a condition for services exported under an LUT: if the payment is not received in convertible foreign exchange, or in Indian rupees where RBI permits, within one year of the invoice (or a longer period allowed under FEMA), the IGST is payable with interest within 15 days after that period. Check whether you need GST registration at all with the GST Registration Checker. An RCMC for services comes from the council for your service in DGFT's Appendix 2T.
Which export registrations must be renewed or updated?
Three need attention every year: the IEC must be updated or confirmed on DGFT between April and June, the LUT expires on 31 March and must be filed again for the new financial year, and the Central FSSAI fee is paid every year. RCMC and APEDA registration run for 5 years.
| Registration | What to do | When |
|---|---|---|
| IEC | Update or confirm on DGFT, even with no changes | Every year, April to June |
| LUT (GST RFD-11) | File for the new financial year | Before the first export after 1 April |
| Central FSSAI licence | Pay the annual fee (no expiry for licences granted from 1 April 2026) | Every year |
| RCMC or APEDA | Renew; APEDA renewal is ₹5,900 | After 5 years |
| Spices Board CRES | Renew for the next 3-year block | End of each block |
The GST portal treats an LUT as accepted if the officer does not act on it within 3 working days, per the GST portal user guide, so filing a few days before the first shipment is enough.
Common mistakes when starting an export business
The costliest mistakes are about timing: raising an export invoice before the LUT is filed, letting the LUT lapse on 31 March, or filing a shipping bill before the AD code is registered on ICEGATE. Each one can hold up a refund or mean IGST has to be paid on the export.
- Filing the LUT after the export. It must be furnished before the supply.
- Missing the three-month rule. Goods supplied under an LUT must be exported within three months of the invoice, or the IGST plus interest is payable within 15 days after that, unless the Commissioner allows more time. Goods invoiced on 10 November 2026 must leave by 10 February 2027, or the tax falls due by 25 February 2027.
- Taking the RCMC from the wrong council. It must match your main line of business.
- Treating the FSSAI State licence as enough for food exports. Exporters need a Central licence whatever the turnover; the FSSAI Licence Type Finder shows why.
- Forgetting the April to June IEC update, which DGFT enforces by deactivating the IEC.
How Ofin can help with export registrations
Ofin handles the main export registrations as fixed-fee services: IEC registration from ₹2,499, APEDA registration from ₹11,999, MPEDA registration from ₹10,899 and AD code registration from ₹7,499. The finder above adds up Ofin's fees for the registrations your product needs.
