What Happens Under RBI Rules When a Foreign Buyer Returns Exported Goods?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
- Published:
- Last modified:
Short answer
When a foreign buyer returns exported goods, the export value is not realised, so the shipping bill stays open in EDPMS. Your AD bank can close it by allowing a reduction in export value on your request. Customs treats the returned goods as an import. Any GST export refund may need repaying if proceeds stay unrealised.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Exporters of goods whose shipment is rejected or sent back by the overseas buyer after the shipping bill has reached EDPMS | Regulations 4(2), 5, 6, 13 and 18(1)(g) of the FEMA (Export and Import of Goods and Services) Regulations, 2026; section 20 of the Customs Act, 1962; CGST Rule 96B | Resolve the EDPMS entry within the realisation period: 9 months from shipment, 12 months if invoiced or settled in rupees, or any AD bank extension | Proceeds unrealised for over a year past the due or extended date mean further exports only against full advance or an irrevocable LC; GST export refunds can be recovered with interest | 8 Oct 2026 |
What happens to an export transaction when the foreign buyer returns the goods?
A returned export shipment leaves an open shipping bill in EDPMS, because the export value it records will not reach India. The goods coming back are a fresh import for customs purposes. Three records then need fixing: the EDPMS entry with your AD bank, the customs entry for the re-import, and your GST export position.
- Open entry: Every goods export carries a declaration of its full export value. At an EDI port the shipping bill itself counts as the Export Declaration Form (Regulation 3(1)). The AD bank marks off the EDPMS entry only after the export value is realised (Regulation 18(1)(g)).
- Reduction: When the full value will not be received, the AD bank may allow a reduction in export value on your request with reasons. For a shipping bill of up to ₹10 lakh, the bank may allow it on your declaration (Regulation 6).
- Customs: Goods imported into India after being exported are liable to duty and to the same conditions as like goods being imported (section 20, Customs Act, 1962). Ask Customs or your customs broker whether any exemption applies to your re-import.
- GST: IGST on imported goods is levied with customs duty under the Customs Tariff Act (proviso to section 5(1), IGST Act). A refund already received on the export can be recovered if sale proceeds are not realised (CGST Rule 96B).
- Old rules: The Master Direction on export had a separate paragraph on refunding export proceeds for goods re-imported due to poor quality (para D.2). RBI superseded that Master Direction from 1 October 2026 (A.P. (DIR Series) Circular No. 20, para 4).
From 1 October 2026 the AD bank decides on reductions under Regulation 6 and handles adjustments under its own internal policy. Talk to the bank as soon as you know the goods are coming back.
Which exporters need to deal with returned goods under RBI and customs rules?
Any goods exporter whose shipment comes back, or will never be paid for, must resolve the open EDPMS entry. The customs and GST steps apply only when the goods physically return to India. Service exporters have no goods to re-import, so only the realisation and EDPMS rules matter for them.
| Situation | Applicable | Why | Best for |
|---|---|---|---|
| Buyer rejects the goods before paying and ships them back | Yes, EDPMS, customs and GST | No export value is realised, so the shipping bill needs a reduction or other closure (Regulation 6), and the goods are a fresh import (section 20) | Manufacturers and merchant exporters facing quality rejections |
| Buyer paid in full, then returns the goods and asks for a refund | Yes, EDPMS and customs; refund handled by the AD bank | The entry may already be closed. The 2026 Regulations have no separate refund rule, so ask the bank how its policy on adjusting export proceeds applies (Regulation 19(1)(c)) | Exporters with paid invoices and later returns |
| Buyer returns part of the shipment | Yes, for the unpaid portion | The AD bank can allow reduction for the under-realised part (Regulation 6) | Exporters with partial rejections |
| Goods destroyed or auctioned abroad and never return | Yes, EDPMS only | There is no re-import, but the export value is still unrealised and the entry needs closure | Perishable or regulated goods held at the destination port |
| Goods sent abroad for exhibition, repair or testing and brought back | Check with your AD bank | The old Master Direction had special paragraphs for these (paras C.3 and C.4). They were superseded on 1 October 2026 and the 2026 Regulations have no separate paragraph (Circular No. 20, para 4) | Exporters taking samples or equipment abroad temporarily |
| Service exporter whose client disputes the work | Partly | There is nothing to re-import. An unpaid service invoice follows the same reduction route (Regulation 6) | Freelancers and IT service firms |
How do you close the shipping bill in EDPMS when exported goods come back?
You close the shipping bill by asking your AD bank to approve a reduction in export value, with reasons and evidence of the return. Up to ₹10 lakh per shipping bill, the bank may accept your declaration. Above that, the bank decides after checking the reasons. File the customs import entry and settle any GST effect alongside.
- Tell your AD bank early. The bank must monitor open entries and follow up with you (Regulation 5(2)), so explain the return before the realisation period ends.
- Collect proof of the return: the buyer's rejection message, the return transport document and, once the goods land, the customs import entry.
- If the goods are re-imported, file the import entry and pay any duty and IGST that Customs assesses (section 20, Customs Act). Ask Customs whether export benefits claimed on the original shipment affect the re-import.
- Submit a reduction request to the AD bank citing the reasons for non-realisation (Regulation 6). For a shipping bill of ₹10 lakh or less, the bank may permit the reduction on your declaration (proviso to Regulation 6).
- For entries of ₹10 lakh or less, you can also declare that payment was realised "in full or otherwise" and ask for closure, singly or in a quarterly bulk declaration (first proviso to Regulation 4(2)). See EDPMS closure.
- If you still expect to resell the goods to another buyer and receive payment, ask for an extension of the realisation period instead (second proviso to Regulation 5(1)). See extension of export realisation period.
- Check your GST position. If you received an IGST or input tax credit refund on the export and proceeds stay unrealised, deposit the refund to that extent, with interest, within 30 days of the end of the FEMA period or extension (CGST Rule 96B(1)).
- Ask the bank to confirm in writing that the EDPMS entry is closed, and keep it in your export file.
How does customs treat exported goods that are re-imported into India?
Customs treats re-imported goods like any other import. Section 20 of the Customs Act says goods imported after export are liable to duty and to the conditions that apply to like goods (section 20). IGST is collected at the same point as customs duty (IGST Act, section 5(1) proviso).
- Ask your customs broker or the port whether any customs exemption applies to your re-import, and on what conditions.
- Where export duty was paid, section 26 of the Customs Act allows a refund if the goods are returned otherwise than by resale, re-imported within one year of export, and the claim is made within six months of clearance (section 26).
- Keep the import entry. It is your main evidence for the AD bank that the goods physically came back.
How is a buyer's advance or payment refunded when exported goods are returned?
Refunding a buyer who already paid is handled through your AD bank, because money that was export proceeds is going back out of India. The 2026 Regulations have no separate refund paragraph. Each AD bank must cover adjustment of under-, over- and non-realised export proceeds in its internal policy (Regulation 19(1)(c)).
- Before 1 October 2026, banks followed para D.2 of the Master Direction, which needed proof that export incentives were surrendered and, in most cases, an undertaking to re-import the goods within three months of the refund (para D.2).
- That paragraph lapsed with the Master Direction, and the 2007 circular on refund of export proceeds is also listed as superseded (Circular No. 20, Annex A item 40). Ask your bank which documents its current policy needs.
- If the export never happened and only an advance was received, see refund of advance export payment.
How do partial returns and replacement shipments affect EDPMS?
A partial return leaves part of the shipping bill unrealised. The AD bank can allow a reduction for the returned portion (Regulation 6). A replacement shipment is a new export with its own shipping bill and its own EDPMS entry, so it does not close the original entry.
- Quote the original shipping bill number in correspondence so the bank links the reduction to the right entry.
- If the buyer pays for the replacement, quote the new shipping bill number with that remittance.
What documents and deadlines apply when exported goods are returned?
The deadline is the realisation period of the original shipping bill: 9 months from shipment, or 12 months if invoiced or settled in rupees, unless the AD bank extends it (Regulation 5(1)). Each AD bank sets its document list in its internal policy and must publish the main features on its website (Regulation 19(1)(a) and 19(4)).
| Item | What it shows | Time limit | Best for |
|---|---|---|---|
| Buyer's rejection or return notice | Reason the export value will not be received | Collect as soon as the buyer rejects | Supporting the reduction request |
| Return transport document | The goods physically left the buyer | When the goods are shipped back | Showing the return is genuine |
| Customs import entry for the re-import | The goods re-entered India and duty was assessed | At the time of re-import | EDPMS closure and GST records |
| Reduction request or ₹10 lakh declaration | Your formal request to reduce or close the entry (Regulations 4(2) and 6) | Within the realisation period or extension | Every returned shipment |
| Extension request | More time to resell and realise (Regulation 5(1)) | Before the realisation period ends | Exporters finding a new buyer |
| Rule 96B deposit of GST refund | Repayment of export refund for unrealised proceeds (CGST Rule 96B) | Within 30 days after the FEMA period or extension ends | Exporters who got an IGST or ITC refund |
What happens if a returned export shipment is left open in EDPMS?
An open shipping bill for returned goods counts as unrealised export proceeds. If it stays unrealised for over a year after the due or extended date, you can export only against full advance or an irrevocable letter of credit (Regulation 13). GST export refunds can also be recovered with interest.
- Export restriction: Further exports need full advance payment or an irrevocable LC once proceeds are unrealised for more than one year past the due date (Regulation 13).
- Caution list: Exporters already on RBI's caution list on 30 September 2026 stay governed by that order until removed (proviso to Regulation 13).
- GST refund: A refunded IGST or input tax credit must be deposited with interest within 30 days of the FEMA period ending, or it is recovered as an erroneous refund (CGST Rule 96B(1)).
- Refund later: If you realise proceeds after recovery and show evidence within three months of realisation, the recovered amount is refunded to that extent, provided proceeds were realised within any extended period RBI permits (CGST Rule 96B(2)).
- Bank charges: The AD bank may not levy charges or penalties on you for regulatory delays, and its charges must be reasonable (Regulation 19(3)).
Ask the AD bank to approve the reduction or close the entry on your declaration, then get written confirmation. If the bank refuses, use the escalation and appeal process its SOP must provide (Regulation 19(2)). For older open entries, see export proceeds not realised.
Which RBI rule covers exported goods that are returned by the buyer?
No single RBI paragraph covers returned goods from 1 October 2026. The FEMA (Export and Import of Goods and Services) Regulations, 2026 handle the situation through the general rules on realisation, reduction and EDPMS closure. The older Master Direction paragraphs were superseded by A.P. (DIR Series) Circular No. 20.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| FEMA 23(R)/2026-RB | Regulation 4(2) first proviso | In force 1 Oct 2026 | Entries up to ₹10 lakh close on your declaration that payment was realised in full or otherwise | Small shipments returned unpaid |
| FEMA 23(R)/2026-RB | Regulation 5(1) | Amended 22 Sep 2026 | Realise within 9 months, or 12 months for rupee trade; the bank may extend | Exporters reselling returned goods |
| FEMA 23(R)/2026-RB | Regulation 6 | In force 1 Oct 2026 | The AD bank may allow reduction for under- or non-realisation; declaration enough up to ₹10 lakh | Every returned shipment |
| FEMA 23(R)/2026-RB | Regulation 13 | Amended 22 Sep 2026 | Unrealised over a year past due date means full advance or LC for future exports | Exporters with old open entries |
| FEMA 23(R)/2026-RB | Regulation 18(1)(g) | In force 1 Oct 2026 | Bank marks off the entry after ensuring export value is realised | Understanding why the entry stays open |
| FEMA 23(R)/2026-RB | Regulation 19(1)(c) | In force 1 Oct 2026 | Bank's policy must cover adjustment of under-, over- and non-realisation | Refunds and adjustments |
| A.P. (DIR Series) Circular No. 20 | Para 4, Annex A item 40 | 16 Jan 2026, effective 1 Oct 2026 | Supersedes the export Master Direction and listed circulars, including the 2007 refund of export proceeds circular | Checking which old rules lapsed |
| Master Direction on Export of Goods and Services | Para D.2 | Superseded 1 Oct 2026 | Old refund route for goods re-imported due to poor quality | Transactions handled before 1 Oct 2026 |
What mistakes do exporters make when foreign buyers return goods?
- Waiting: Raising the return with the AD bank only after the realisation period ends. Ask for a reduction or an extension while the period is still running.
- Replacement: Assuming a replacement shipment closes the original entry. The replacement has its own shipping bill and EDPMS entry.
- No import entry: Bringing goods back without a proper customs import entry. Section 20 of the Customs Act treats them as an import, and the entry is your evidence of return.
- Hidden benefits: Not telling Customs or the bank about export benefits claimed on the original shipment, such as an IGST refund.
- GST refund: Keeping a GST export refund for a shipment that was never paid for. Rule 96B requires repayment within 30 days after the FEMA period ends.
- Old rules: Quoting para D.2 or other Master Direction paragraphs for transactions handled from 1 October 2026. Those paragraphs are superseded.
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB dated 13 January 2026, amended up to 22 September 2026, Regulations 3(1), 4(2), 5, 6, 13, 18(1)(g), 19 (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20, RBI/2025-26/194: Export and Import of Goods and Services, 16 January 2026, Para 4; Annex A item 40 (Refund of Export Proceeds, A.P. DIR Circular No. 37 of 5 April 2007) (checked 8 Oct 2026)
- RBI Master Direction: Export of Goods and Services (superseded from 1 October 2026), Paras C.3, C.4 and D.2 (checked 8 Oct 2026)
- Customs Act, 1962 (CBIC Tax Information Portal), Sections 20 and 26 (checked 8 Oct 2026)
- Integrated Goods and Services Tax Act, 2017, section 5, Proviso to section 5(1) (checked 8 Oct 2026)
- CGST Rules, 2017, Rule 96B: Recovery of refund where export proceeds not realised, Sub-rules (1) and (2) and proviso (checked 8 Oct 2026)
Frequently asked questions
Can a shipping bill of up to ₹10 lakh for returned goods be closed in EDPMS on a declaration?
Yes. For a shipping bill of up to ₹10 lakh or its foreign currency equivalent, the AD bank may close the EDPMS entry based on your declaration that payment was realised in full or otherwise. You can submit it singly or quarterly in bulk. The bank may also permit a reduction up to the same limit on your declaration.
Is customs duty payable when exported goods are re-imported into India?
Section 20 of the Customs Act, 1962 makes re-imported goods liable to duty and conditions like any other import. IGST is collected with that duty. Ask your customs broker before the goods arrive whether any customs exemption applies and what conditions it carries.
Does CGST Rule 96B apply when exported goods are returned unpaid?
Rule 96B applies when you received a refund of IGST or input tax credit on exported goods and sale proceeds are not realised within the FEMA period. You must deposit the refund to that extent with interest within 30 days after that period ends. Otherwise it is recovered as an erroneous refund.
Does an AD bank reduction under Regulation 6 stop recovery under Rule 96B?
Rule 96B says the refund is not recovered where the Reserve Bank of India writes off the realisation requirement on merits. From 1 October 2026, AD banks allow reductions under Regulation 6. Neither text says whether a bank reduction counts for this proviso, so confirm with your GST officer.
Is para D.2 of the RBI export Master Direction still valid for refunds of returned goods?
No. Para D.2 covered refund of export proceeds for goods re-imported due to poor quality. RBI superseded the Master Direction on Export of Goods and Services from 1 October 2026 through A.P. (DIR Series) Circular No. 20. Refunds now follow each AD bank's internal policy on adjustments under Regulation 19.
Can returned export goods be resold to another foreign buyer instead of re-imported?
The 2026 Regulations do not set a separate rule for resale to a new buyer. If you expect payment from a new buyer, ask the AD bank to extend the realisation period under Regulation 5(1). Cite the reasons for the delay, such as the change of buyer. The bank decides whether it is satisfied with those reasons.
Does Regulation 13 apply to a returned shipment that is still open in EDPMS?
Yes, if the entry stays unrealised for more than one year after the due date or any extension. Regulation 13 then lets you export only against full advance or an irrevocable letter of credit. Getting the AD bank to approve a reduction for the returned goods avoids this outcome.