Government Notifies Inventory-based Cross-border E-Commerce Export Framework

The Government of India has operationalized the Inventory-based Cross-border E-Commerce Export Framework under the Foreign Trade Policy (FTP) 2023 through Notification No. 27/2026-27 and Public Notice No. 25/2026-27, both dated August 5, 2026. This framework provides a comprehensive policy and procedural architecture for facilitating inventory-based cross-border e-commerce exports of goods manufactured or produced in India, following the amendment to the FDI Policy through Press Note No. 3 (2026 Series) which permits inventory-based e-commerce operations exclusively for exports.

The framework enables eligible e-commerce entities to undertake export-only inventory operations through a registered Exporter-on-Record (EOR). The EOR procures goods from Indian Sellers-on-Record (SORs) against confirmed overseas orders, undertakes exports in its own name, and assumes responsibility for export operations as well as compliance with destination-country requirements. This allows Indian sellers to delegate export documentation, customs formalities, destination-country regulatory compliance, product testing and certification, packaging, labelling, fulfilment, logistics and reverse logistics to the EOR.

Key Safeguards and Compliance Requirements

The framework incorporates several robust safeguards to ensure benefits accrue to Indian manufacturers and MSMEs while maintaining regulatory oversight. Export inventory may be procured only against confirmed export orders, and speculative inventory build-up for export purposes is expressly prohibited. The export inventory must be distinctly identified, segregated and maintained through a digital repository to ensure complete traceability, and export inventory cannot be diverted for sale in the domestic market.

The framework mandates timely payments to Indian sellers within prescribed timelines, irrespective of receipt of payment from overseas buyers. Export rebates and refunds must be apportioned and passed through to the Sellers-on-Record in proportion to the FOB value attributable to their goods. Sellers are provided visibility regarding the final sale price, order status and shipment tracking of their products. Returned or rejected consignments must be re-exported, returned to the seller or disposed of according to prescribed procedures, with annual compliance certification and maintenance of digital records required for transparency and enforcement.

The framework is expected to facilitate greater participation of Indian manufacturers, traders and MSMEs in global e-commerce supply chains by providing access to organised fulfilment networks while ensuring transparency, timely payments, effective pass-through of export benefits and robust regulatory oversight.