Key Terms & Concepts — UPSC Mains
Exporter-on-Record (EOR) Framework
"A 2026 DGFT framework creating a legally recognised intermediary, the Exporter-on-Record, that carries customs and export compliance on behalf of Indian manufacturers (Sellers-on-Record) for cross-border e-commerce, while passing seller-attributable rebates back to them by FOB value."
The Exporter-on-Record (EOR) framework, operationalised through DGFT Public Notice No. 25/2026-27 and Notification No. 27/2026-27 (both dated 5 August 2026) under the Foreign Trade Policy 2023, creates an inventory-based structure for cross-border e-commerce exports designed to solve a specific problem: small Indian manufacturers can make export-quality products but very few can independently manage the customs clearance, shipping documentation, GST refund claims and duty drawback processes that exporting requires. Under the framework, an Exporter-on-Record, an entity holding a valid Importer Exporter Code (IEC) and GSTIN and registered with the DGFT, receives confirmed overseas orders, procures goods from Indian manufacturers designated as Sellers-on-Record, classifies the goods as export inventory, and handles all customs clearance, shipping and regulatory documentation. The Seller-on-Record, the actual manufacturer, need not file anything itself. The framework's key design feature is that seller-attributable export rebates, Duty Drawback, RoDTEP and RoSCTL, are apportioned to the Sellers-on-Record in proportion to their FOB (Free on Board) value, ensuring the incentive reaches the manufacturer rather than being captured entirely by the intermediary EOR. The refund of taxes under the CGST Act, by contrast, is expressly an EOR entitlement and is not apportioned. Speculative stocking is prohibited: exports must correspond to confirmed overseas orders. The framework exists as an export-only carve-out because India's FDI policy prohibits inventory-based e-commerce for foreign-funded entities in the domestic market; since export inventory is by definition not sold domestically, that prohibition does not apply to it.
A currently examinable GS3 trade-policy and MSME-export concept, testing both the FDI marketplace-versus-inventory distinction and the mechanics of India's export incentive apportionment.
- 1 Operationalised via DGFT Public Notice No. 25/2026-27 and Notification No. 27/2026-27, both dated 5 August 2026, under Foreign Trade Policy 2023.
- 2 Exporter-on-Record (EOR): holds valid IEC and GSTIN, DGFT-registered; handles customs, shipping and documentation for confirmed export orders.
- 3 Seller-on-Record (SOR): the actual Indian manufacturer supplying goods; does not need to file anything itself.
- 4 Seller-attributable rebates (Duty Drawback, RoDTEP, RoSCTL) apportioned to SORs by FOB value; the CGST refund is an EOR-only entitlement.
- 5 Speculative stocking prohibited: exports must correspond to confirmed overseas orders, preventing the model from becoming a tax-deferral device.
- 6 Exists as an export-only carve-out from India's FDI prohibition on inventory-based B2C e-commerce for the domestic market.
- 7 FDI in inventory-based e-commerce for the domestic market remains prohibited; only the export lane is opened.
A Moradabad brassware unit that cannot independently manage export documentation can now sell through an Exporter-on-Record, which handles customs and logistics while duty drawback and RoDTEP incentives flow back to the manufacturer in proportion to its FOB value.
