The Directorate General of Foreign Trade has amended the Import Policy concerning certain iron and steel products by Notification No 17/2015-20 dated 05th September 2019. As per this Amendment Notification, the import policy condition under Chapters 72, 73 and 86 of the Indian Trade Classification (Harmonised System) ["ITC (HS)] has been amended from "free" to "free subject to compulsory registration under the Steel Import Management System" ("SIMS").

The Annex to the Amendment Notification covers 284 customs tariff items, the imports of which will be subject to registration. As per the Amendment Notification, an importer who intends to import any of these products is required to comply with the following provisions:

  1. Importers are required to submit advance information in an online system for import of items in the Annex and obtain an automatic Registration Number.
  2. A registration fee of Rs. 1 per thousand, subject to minimum of Rs.500/- and maximum of Rs. 1 lakh on the CIF value of the subject imports, has to be paid.
  3. The importer can apply for registration not earlier than the 60th day and not later than the 15th day before the expected date of arrival of import consignment.
  4. The Registration Number granted shall remain valid for a period of 75 days.
  5. Importer shall have to enter the Registration Number and expiry date of Registration in the concerned Bill of Entry for clearance of the consignment.
  6. The SIMS will be effective from 01.11.2019, i.e., Bill of Entry on or after 01.11.2019 for the items as listed in the Annex and shall be governed by the SIMS.
  7. The facility for online Registration will be available with effect from 16/09/2019.

The registration requirements described above are in addition to the requirements placed under the Steel and Steel Products (Quality Control) Order, 2019 ("Quality Control Order") dated July 2019, issued by the Ministry of Steel.

As per the Quality Control Order, the steel and steel products specified therein have to conform to the applicable standards framed by Bureau of Indian Standards ("BIS") from the date prescribed therein. The Quality Control Order however does not cover products meant for export which conform to any other specification required by a foreign buyer.

The BIS has been designated as the authority for certification and enforcement in respect of the steel and steel products specified in the Quality Control order. A comparison of the Quality Control Order and the Amendment Notification would show that a number of the customs tariff items specified by the Quality Control Order overlap with the customs tariff items specified by the Amendment Notification. Therefore, importers of such overlapping goods will have to conform to both the Quality Control Order and the SIMS.