Issues

Suggestions

Non-cancellation of bonds even after submission of  e-BRC

For bond cancellation, the Nominated agencies are now required to ensure both export obligation (i.e. submit EP Copy & Customs Invoice) as well as realization of proceeds (i.e submit E-BRC).

The list of documents should be issued as per the FTP at the time of transaction to the exporter, so that document compliance will be easy and hassle free.

Non payment of interest and non-acceptance of FDs for margin money deposited with the Banks/agencies

No time period for Bond cancellation.

Observations / queries related to bond cancellation should be communicated within 7 working days or the bond should be cancelled within 7 working days after receiving of e-BRC. 

Lack of clarity on Replenishment Scheme & Exhibition Scheme

Guidelines on Replenishment Scheme and Exhibition Scheme are not clear with customs officials dealing with bond cancellation.  As a result, Nominated Agencies do not supply gold under these schemes and small exporters suffer.

There should be a facilitator in every institution to resolve all procedural queries. Most of the exporters do not know the proper procedure. Therefore they unable to avail of existing schemes.

Absence of a structured mechanism for exchange of information and review of issues

There is no structured mechanism among Nominated Agencies, GJEPC and Customs for periodic exchange of information and review of issues concerning exporters. As a result, the requirement of the exporters is not known and the difficulties in servicing exporters are not removed.

A quarterly meeting of Nominated Agencies may be held by GJEPC where customs authorities will also be present to resolve all issues relating to the exporters.

Council should also be updated about the procedures and hurdles.

All Duty Free Gold Schemes are not Operational (as per the FTP and HBoP).  Schemes are being implemented as per their business convenience.

KYC procedure is made cumbersome

Banks/Nominated Agencies adopt a very cumbersome procedure for KYC of exporters. They also seek credit reports from D&B even for small exporters. The overall approach appears to be reluctance to make small exporters their customers, instead of facilitating their business.

Banks/Nominated Agencies should adopt a simple KYC procedure for exporters to ascertain proof of identity and proof of residence. They should furnish a list of documents

Non-issuance of gold to  smaller exporters

Banks/Nominated Agencies do not issue gold to the smaller exporters.

Non-issuance of gold in small denominations

Banks/Agencies do not issue gold to the exporters in denominations less than 1 kg. This deprives most of the small exporters from getting duty free gold. 

Banks/Agencies should import gold in a mix of denominations such that they are able to supply gold to the small exporters in small denominations as provided in HBP.

Trading Hours should be Extended