The Directorate General of Foreign Trade (DGFT) has issued a series of highly critical notifications in June 2026, fundamentally tightening silver import authorisation requirements, expanding Quality Control Order (QCO) exemptions for Special Economic Zone (SEZ) units, and aligning Remission of Duties and Taxes on Exported Products (RoDTEP) schedules with Finance Act 2026 tariff changes. Importers of precious metal items now face significantly stricter licensing conditions under Chapter 71, while exporters benefit from a new online Post Export EPCG scrip module and broader SEZ import procurement flexibility.

What are the Key Recent DGFT Export-Import Policy Changes?

⚠️ Don’t Miss: File your customs duty drawback claim within exactly 3 months of the export shipping bill date. Late claims face complete systematic rejection unless you have a valid, documented reason formally accepted by competent Customs authorities.

Pro Tip: Always secure an advance ruling for high-value imports where tariff classification is ambiguous. The upfront processing window and minor cost are far less than the compounding interest, severe penalties, and port operational delays caused by retrospective duty demands. Maintain a structured classification file for every product line your business handles regularly.

Silver imports under ITC(HS) Codes 71061000, 71069110, 71069120, and 71069190 now legally require a valid DGFT Import Authorisation, as per Notification No. 19/2026-27 dated 2 June 2026.
SEZ units and developers can import all permissible goods without QCO or BIS compliance at the import stage, subject to strict DTA clearance conditions, as per Notification No. 20/2026-27 dated 2 June 2026.
The RoDTEP Schedule (Appendices 4R and 4RE) was amended with effect from 1 May 2026 — 142 tariff lines added, 50 deleted, 2 modified — to perfectly align with Finance Act 2026 structural changes, as per Notification No. 15/2026-27.
Gold and silver articles under Chapter 71 shifted from Free to Restricted import status under Notification No. 03/2026-27 dated 2 April 2026, with an express denial of any transitional relief.
An entirely online Post Export EPCG module was launched via Trade Notice No. 02/2026-27 dated 21 April 2026 to resolve manual scrip utilisation bottlenecks and ICEGATE transmission failures.
Stakeholder consultation was officially invited on proposed export policy amendments aligning with the Finance Act 2026, via Trade Notice No. 07/2026-27 dated 3 June 2026.
The Reserve Bank of India (RBI) published Notification No. FEMA 23(R)/2026-RB, completely overhauling the Foreign Exchange Management (Export and Import) Regulations effective 1 October 2026.

What Changed in the Trade Policy for Silver and Precious Metal Imports?

India is quietly but aggressively reshaping its macroeconomic trade policy regarding precious metals, aiming to restrict unmonitored outflows of foreign exchange and close loopholes in bullion trading. The DGFT has fundamentally tightened the import framework for silver and precious metal items through two major notifications issued in April and June 2026.

As per Notification No. 03/2026-27 dated 2 April 2026, several critical items under Chapter 71 of ITC(HS) 2022 — including silver-plated base metals, unwrought platinum articles, goldsmith wares, and specific types of coin — have been abruptly shifted from Free to Restricted import status. A new Policy Condition No. 7 has been formally introduced into Chapter 71. This condition exempts only 100% Export Oriented Units (EOUs), SEZ units operating under Rule 27 of the SEZ Rules, 2006, and imports tied directly to export-linked gems and jewellery schemes under Chapter 4 of the Foreign Trade Policy (FTP) 2023. This exemption is strictly conditional on the premise that these goods are not diverted or sold into the Domestic Tariff Area (DTA).

Critically, the benefit of transitional arrangements under Para 1.05(b) of FTP 2023 has been expressly denied. In standard trade scenarios, if a policy changes, shipments already on the water or backed by an irrevocable Letter of Credit (LC) are grandfathered in. Not here. These precious metal restrictions apply immediately regardless of prior contracts, open letters of credit, or advance wire transfers. If the cargo hits the port after the notification date without a licence, it is treated as a restricted import violation.

Building on this architecture, Notification No. 19/2026-27 dated 2 June 2026 further amended the import policy specifically targeting high-volume silver commodities under ITC(HS) Codes 71061000 (silver powder), 71069110 (silver grains), 71069120 (silver containing 99.9% or more by weight), and 71069190 (other unwrought silver). Previously, these could be imported relatively easily by certain designated bodies. Now, imports by nominated agencies notified by the RBI (for scheduled banks), DGFT (for other trading agencies), and qualified jewellers notified by IFSCA (for India International Bullion Exchange / IIBX imports) are permitted only against a valid, pre-approved Import Authorisation issued centrally by the DGFT.

Critical Alert: If you hold any pending silver or precious metal shipments arriving at Indian ports without a valid DGFT Import Authorisation, those consignments will be detained by customs intelligence units. The absolute denial of transitional relief under Notification No. 03/2026-27 means there is zero grace period. Importers must verify their licensing status immediately, or risk heavy demurrage charges and potential confiscation proceedings.

How Has the SEZ Import Framework Been Expanded?

In a massive relief to industrial manufacturers and infrastructure developers operating inside economic enclaves, the DGFT has significantly broadened the Quality Control Order (QCO) exemption available to SEZ entities. As per Notification No. 20/2026-27 dated 2 June 2026, Para 2.03A(iii) of the Foreign Trade Policy (FTP) 2023 has been completely substituted.

The new framework allows SEZ units and SEZ developers to import all permissible goods — a definition that spans raw materials, heavy components, engineering consumables, manufacturing spares, and complete capital goods machinery — required for authorised SEZ operations entirely without QCO or Bureau of Indian Standards (BIS) compliance at the time of import.

Previously, the wording of this exemption was extremely narrow. It was limited exclusively to inputs required for physical export production, and explicitly stated that no DTA clearance would be permitted for such goods. This created a logistical nightmare for SEZ units that produced goods for both export and domestic markets, forcing them to run parallel inventory lines or clear complex BIS hurdles just to bring machinery into the zone. The revised provision removes these operational limitations at the port of entry, giving SEZ operators significantly greater procurement speed and flexibility.

However, the DGFT has built in a strict domestic safeguard. The exemption applies only while the goods are used within the physical boundaries of the SEZ for authorised operations. Any removal, transfer, or clearance of such goods — or the finished products manufactured from them — into the Domestic Tariff Area (DTA) must strictly comply with applicable QCOs, BIS requirements, and other safety/quality laws in force at the time of clearance. To enforce this, a legally binding undertaking to this effect must be furnished to the concerned Development Commissioner (DC) of the SEZ at the time of importation. The DC’s office will periodically audit these consumption metrics.

Practitioner Insight: SEZ units must immediately update their ERP and inventory management systems to maintain clear, distinct records differentiating QCO-exempt imports from DTA-clearable goods. The Development Commissioner’s undertaking is a formal legal liability. Non-compliance at the DTA clearance stage — such as selling an electronics item without a required BIS mark into the domestic market — will attract aggressive customs duty demands, confiscation, and penal action under the SEZ Act, 2005.

How Do the New Certificate of Origin Rules Affect Exporters?

The DGFT has restructured the Certificate of Origin (CoO) issuance framework through Notification No. 05/2026-27 dated 7 April 2026, amending Para 2.62 of FTP 2023 with immediate operational effect. This notification is designed to plug data leaks and prevent fraudulent preferential duty claims in international trade. Two significant compliance changes now apply to all Indian exporters.

First, CoOs for exports originating from India can now only be issued by designated agencies officially authorised by the DGFT and listed in Appendix 2B of the Aayat Niryat Forms. Unauthorised self-certification is no longer valid for standard shipments.

Second, and far more critical for daily customs clearance operations, all Importer-Exporter Code (IEC) holders availing CoOs must use **perfectly identical invoice numbers** in both the Certificate of Origin application and the corresponding Customs Shipping Bill. This mandatory identical numbering enables automated, real-time verification between the DGFT’s internal databases and the central ICEGATE customs portal. It drastically reduces the risk of preferential duty claims being rejected at the destination port due to documentation mismatches.

The notification also introduces the architecture for an “Approved Exporter Scheme” as an optional system allowing self-certification. Manufacturer-exporters who hold formal Status Holder recognition (ranging from One Star to Five Star Export Houses) are theoretically eligible to self-certify their origins, provided they comply with their Industrial Entrepreneur Memorandum (IEM), Industrial License, or Letter of Intent. However, this is a future-facing provision. The scheme will only become fully operational when the Government of India formally incorporates this specific self-certification clause into its bilateral trade agreements (FTAs/CEPAs) and the DGFT issues a subsequent notification outlining the specific operational conditions. Until that day arrives, even Five Star Export Houses must continue using the designated agencies listed in Appendix 2B.

Policy Context: The strict invoice matching requirement under Notification No. 05/2026-27 applies across all preferential trade treaties — PTAs, FTAs, CECAs, and CEPAs. If your export documentation team generates a CoO where the invoice string reads “INV/2026/001” but the ICEGATE Shipping Bill reads “INV-2026-001” (even a hyphen vs slash difference), the automated handshake will fail. The importing country’s customs authority will likely deny preferential duty treatment, resulting in higher tariff costs for your overseas buyer and a potential loss of contract competitiveness.

What Is the Compliance Impact of Gold and Silver Import Restrictions?

The sudden shift of multiple precious metal items from Free to Restricted categories under Notification No. 03/2026-27 has created a complex compliance matrix for the jewellery, electronics, and industrial sectors. The table below summarises the revised import policy conditions for key Chapter 71 items that companies must now navigate.

ITC(HS) Code	Item Description	Revised Import Policy	Key Condition & Restrictions
71090000	Base metals or silver, clad with gold, not further worked than semi-manufactured	Restricted	Subject strictly to Policy Condition No. 7 of Chapter 71
71101119	Platinum, unwrought form, other industrial variants	Free (Conditional)	Platinum alloy containing gold of more than 1% by weight defaults to Restricted
71141110	Articles of silver, whether or not plated or clad	Restricted	Subject strictly to Policy Condition No. 7 of Chapter 71
71141920	Finished articles of platinum	Restricted	Subject strictly to Policy Condition No. 7 of Chapter 71
71159090	Other articles of precious metal or metal clad with precious metal	Restricted	Subject strictly to Policy Condition No. 7 of Chapter 71
71181000	Coin (other than gold coin), not being active legal tender	Restricted	Subject strictly to Policy Condition No. 7 of Chapter 71

Policy Condition No. 7 is the sole lifeline for manufacturers relying on these inputs. It exempts imports routed by 100% EOUs and SEZ units operating under Para 6.01(d) of FTP 2023 and Rule 27 of the SEZ Rules, 2006, strictly provided the goods are not sold or diverted into the domestic DTA market. Furthermore, imports tied to the specialised gems and jewellery export schemes managed under Chapter 4 of the FTP 2023 are also allowed to bypass the restricted status, ensuring that bona-fide export manufacturing is not strangled by the new regulations.

Does This Affect My HS Code Classification? (The Finance Act 2026 Changes)

Yes, directly and comprehensively. The Finance Act (No. 3 of 2026) has introduced massive structural changes to the First Schedule of the Customs Tariff Act, 1975. This is not merely a tax rate change; it is an overhaul of HS Codes, Product Descriptions, and Chapter Notes to align India’s domestic logistics configurations with the latest World Customs Organization (WCO) international tracking baselines.

These revisions span essential industrial lines, chemical compounds, agricultural groups, and technological equipment fields. For instance, specific electronics and machinery parts have been broken out into highly granular 8-digit tariff lines to prevent misclassification and duty evasion. Exporters and importers can no longer rely on legacy HS code databases. If you classify your product using a deleted or modified 8-digit code, the ICEGATE system will instantly reject the Bill of Entry or Shipping Bill. Companies must conduct a complete tariff audit of their master product catalogues to map their goods to the newly mandated 2026 HS structures.

How Do the RoDTEP Amendments Affect Export Duty Credit Calculations?

Because the Finance Act 2026 altered the underlying HS codes, the DGFT had to update the Remission of Duties and Taxes on Exported Products (RoDTEP) Schedule. The RoDTEP scheme refunds embedded central, state, and local duties to exporters. This technical amendment was pushed through Notification No. 15/2026-27 dated 30 April 2026, taking effect from 1 May 2026. A total of 194 tariff lines have been actively revised in Appendices 4R and 4RE — exactly 142 new tariff lines were added, 50 obsolete lines were deleted, and 2 lines were structurally modified at the 8-digit level.

The financial math under RoDTEP is dictated by the allocated percentage rate and the absolute “value cap” per unit. Consider this detailed example:

Suppose an exporter ships a container of engineered goods under a newly added 8-digit HS code effective 1 May 2026. Under the revised Appendix 4R, this specific item now carries a RoDTEP reward rate of 2.8% alongside a strict value cap of ₹8 per unit of measure (UQC). If the exporter ships 50,000 units holding an FOB (Free on Board) value of ₹200 per unit, the baseline calculation measures as: 2.8% of ₹200 = ₹5.60 per unit. Since ₹5.60 sits safely below the ₹8 maximum cap, the exporter claims the full calculated value. The total electronic scrip reward values out to exactly ₹5.60 × 50,000 = ₹2,80,000.

However, if the FOB value was much higher, or if a different tariff line carried a 4.5% rate (which would evaluate to ₹9 per unit on a ₹200 FOB), the system hard-caps the reward at ₹8. In that scenario, the final payout is restricted to ₹8 × 50,000 = ₹4,00,000, regardless of the percentage math.

Updated HS codes, applicable RoDTEP rates, and strict value caps are available dynamically on the DGFT portal under the Regulations > RoDTEP section. Exporters must verify their specific tariff lines against this updated database before filing shipping bills to ensure accurate duty credit claims. Review our companion guide on parsing outward logistics declarations and tracking GSTR-1A outward supply amendments to keep your domestic commercial tax ledgers synchronized with your export volumes.

How Does the New Online Post Export EPCG Module Work?

The Export Promotion Capital Goods (EPCG) scheme allows the import of capital machinery at zero customs duty, subject to an export obligation. For businesses that opt to pay the duty upfront and claim a refund later, the “Post Export EPCG” route is used. However, manual processing of these duty credit scrips created severe operational delays.

To address persistent difficulties in utilising manually issued duty credit scrips, the DGFT launched a fully digital online Post Export EPCG module through Trade Notice No. 02/2026-27 dated 21 April 2026. The module enables the electronic generation of scrips and guarantees seamless, API-driven data exchange with ICEGATE. This completely eliminates the manual transmission failures that plagued the offline process. The module dictates workflows across three specific operational scenarios:

Scenario 1 (Open Authorisations): Where the Post Export EPCG Authorisation has not been formally closed in the system, the applicant can apply for closure online through the DGFT portal along with all supporting export documents. Once the Regional Authority (RA) approves the file, the scrip is generated automatically and transmitted electronically to ICEGATE for immediate use.
Scenario 2 (Expired Transmissions): Where the authorisation was closed and the scrip generated, but it was either not transmitted to ICEGATE due to server errors or expired pending transmission, the applicant must raise a Service Request Ticket online. They must provide details of the affected scrip. Upon RA approval, the existing scrip is retransmitted to Customs with a newly minted expiry date.
Scenario 3 (Legacy Manual Scrips): Where the authorisation is marked closed but no digital scrip was generated (or only a legacy manual paper scrip exists), the applicant raises a Service Request Ticket containing details of the closure application, the utilisation status of any manual scrip, and supporting documents. The RA then verifies the manual ledger and processes the request for full or part-amount electronic scrip generation on the digital portal.

Critical Alert: Do not attempt to manually use a paper-based EPCG scrip at ICEGATE if the online module is available for your authorisation. Manual scrips are no longer being processed or verified for new transmissions by customs officers on the floor — all Post Export EPCG scrips must now be generated, verified, and transmitted through the DGFT’s centralized online module.

How Should Importers Prepare for the FEMA 2026 Regulatory Changes?

Beyond the DGFT, the Reserve Bank of India (RBI) has issued its own massive update to the trade ecosystem. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026) will come into full legal force on 1 October 2026. These sweeping regulations completely supersede the legacy 2015 framework and introduce updated, highly rigid compliance requirements for both exporters and importers regarding foreign exchange realization.

For exports, the full export value must be realised and repatriated within the prescribed period. A significant relaxation has been provided to promote the internationalization of the Rupee: Where trade lines are invoiced and settled entirely in Indian Rupees (INR), the statutory realisation and repatriation period is extended to eighteen months from the date of shipment for physical goods (other than warehouse exports), from the date of invoice for software/services, and from the date of sale for goods exported to a warehouse outside India. For standard foreign currency invoicing (USD, EUR, GBP), the standard nine-month limits generally apply unless modified by specific AD bank approvals.

For imports, Authorised Dealer (AD) banks are now mandated to heavily monitor Import Data Processing and Monitoring System (IDPMS) entries. They must follow up continuously with importers to ensure foreign exchange payments are executed within the period specified in the underlying commercial contract (typically six months). If an importer remits an advance payment but is ultimately unable to complete the physical import within the contract period or any extended period permitted by the bank, that advance payment must be immediately repatriated back to India.

The regulations also formalize the set-off of export receivables against import payables. If you export goods to and import materials from the same overseas buyer/supplier or their group companies, you can set off the balances without routing cash both ways, provided the transaction concludes within the stipulated realisation period. Finally, advance payments for both exports and imports must be routed through the exact same Authorised Dealer bank. If an exporter receives an advance via Bank A, the final settlement cannot be routed through Bank B unless formal intimation of the change has been provided and cleared by both dealers.

Policy Context: The FEMA 2026 framework introduces a separate, comprehensive internal policy and Standard Operating Procedure (SOP) requirement for Authorised Dealers handling export-import transactions. Banks must document their internal procedures for transaction reporting and merchanting trade workflows. Importers and exporters should expect enhanced due diligence and documentary demands from their banking partners. It is highly advisable to verify your historical cross-border clearance logs on the RBI’s EDPMS and IDPMS trade monitoring portals to eliminate outstanding compliance flags before the strict guidelines take effect on 1 October 2026.

What Should You Do Next?

With multiple complex notifications taking effect across the DGFT, Customs, and RBI within weeks of each other, businesses need a highly structured action plan. Here are the immediate steps your trade compliance team should execute:

Verify Precious Metal Licensing: Audit your supply chain to verify whether your silver or precious metal imports fall under the newly restricted ITC(HS) codes in Chapter 71 — carefully cross-check Notification No. 03/2026-27 and Notification No. 19/2026-27 before placing any new international purchase orders.
Secure Authorisations for Nominated Imports: If you are a nominated agency or a qualified jeweller importing silver through RBI, DGFT, or IIBX channels, apply for a valid DGFT Import Authorisation immediately — legacy channel privileges have ended, and imports without this DGFT authorisation will be held indefinitely at customs.
Update SEZ Inventory Protocols: SEZ units and developers should review their procurement inventory and furnish the newly required undertaking to the Development Commissioner for all QCO-exempt imports. Ensure your ERP system is configured to document DTA clearance compliance separately to prevent heavy domestic penalties.
Align Documentation Invoice Numbers: Exporters using Certificates of Origin under any preferential trade agreement (FTA/PTA) must ensure that identical invoice numbers, down to the last hyphen and slash, are used in both the CoO and the corresponding Shipping Bill to avoid automated ICEGATE verification failures.
Digitize EPCG Workflows: Post Export EPCG authorisation holders facing manual scrip utilisation issues should halt physical processing attempts and submit closure requests or service tickets directly through the new online module on the DGFT portal, as mandated by Trade Notice No. 02/2026-27.
Recalibrate RoDTEP Financials: Check the updated RoDTEP Schedule on the DGFT portal under Regulations > RoDTEP to confirm whether your export products are among the 142 newly added tariff lines or the 50 deleted lines effective 1 May 2026. Adjust your export pricing margins to reflect your updated duty credit entitlements.
Participate in Policy Shaping: If your export products are affected by the proposed Schedule-II amendments under the Finance Act 2026, submit your detailed comments and industry representations to [email protected] within the short seven-day window from 3 June 2026, as requested in Trade Notice No. 07/2026-27.

Frequently Asked Questions

Does the silver import restriction apply to silver dore imports by refineries?

No. Silver dore imports by domestic refineries operating against a licence with an Actual User (AU) condition remain governed by their existing, independent policy conditions. They are not affected by the new blanket Import Authorisation requirement rolled out under Notification No. 19/2026-27. The AU condition licence framework continues to apply separately.

Can SEZ units sell QCO-exempt imported goods into the DTA without compliance?

Absolutely not. As per the amended Para 2.03A(iii) of FTP 2023 under Notification No. 20/2026-27, any removal, transfer, or clearance of QCO-exempt imported goods — or the finished products manufactured from them — from the SEZ boundaries into the DTA must fully comply with applicable QCOs, BIS quality markings, and other safety laws in force at the exact time of clearance. The QCO exemption applies strictly to goods used within the physical SEZ zone for authorised operations.

Does the invoice matching requirement for Certificates of Origin apply to all trade agreements?

Yes. As per Notification No. 05/2026-27 amending Para 2.62 of FTP 2023, all IEC holders availing Certificates of Origin must use identical invoice numbers in both the CoO document and the corresponding Shipping Bill. This mandate applies across all Preferential Trade Agreements, Free Trade Agreements, Comprehensive Economic Cooperation Agreements, and Comprehensive Economic Partnership Agreements to enable flawless automated verification within ICEGATE.

Is transitional relief available for shipments already in transit under the new precious metal restrictions?

No. Notification No. 03/2026-27 expressly denies the benefit of standard transitional arrangements outlined under Para 1.05(b) of FTP 2023. The restrictive import limits apply with immediate effect regardless of any prior contract, irrevocable letter of credit, advance bank payment, or active shipment status. Importers must ensure full compliance and secure necessary licenses before attempting customs clearance, even for cargo already on the water.

When do the new FEMA 2026 regulations on export and import of goods come into effect?

The comprehensive Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026) will come into full operational force on 1 October 2026. Exporters and importers should begin immediately updating their internal corporate policies and SOPs, including establishing tighter EDPMS and IDPMS monitoring procedures with their AD banks, before this effective date hits.

Does the new silver import authorisation requirement apply to all silver items under Chapter 71?

No. Notification No. 19/2026-27 specifically isolates and covers four highly traded ITC(HS) codes — 71061000 (silver powder), 71069110 (silver grains), 71069120 (silver containing 99.9% or more by weight), and 71069190 (other unwrought silver). Imports via nominated agencies notified by RBI, DGFT, and IFSCA-qualified jewellers for IIBX are permitted only against a valid DGFT Import Authorisation. Other varied silver items and articles under Chapter 71 are governed by the broader Notification No. 03/2026-27, which shifted several precious metal items to Restricted status under the strict parameters of Policy Condition No. 7.

Can SEZ developers also claim the QCO exemption, or is it limited solely to SEZ units?

The broad exemption granted under Notification No. 20/2026-27 applies to both SEZ Units and SEZ Developers. The carefully amended Para 2.03A(iii) of FTP 2023 explicitly covers imports of all permissible goods required for authorized operations within Special Economic Zones, explicitly including the heavy capital goods, construction materials, and spares needed by developers to build out zone infrastructure.

What happens if my existing EPCG scrip was issued manually and has not been transmitted to ICEGATE?

Under the guidelines of Trade Notice No. 02/2026-27 dated 21 April 2026, you should no longer attempt to use the physical paper. Instead, raise a Service Request Ticket online on the DGFT portal providing the exact details of the manual scrip, its current utilisation status, and scanned supporting documents. Once the concerned Regional Authority (RA) verifies and approves the request, a digital electronic scrip will be generated and transmitted cleanly to ICEGATE.

Will the RoDTEP schedule changes affect claims already filed for May 2026 exports?

Notification No. 15/2026-27 is legally effective from 1 May 2026. For shipping bills formally filed on or after that specific date, the revised RoDTEP rates and new tariff line structures apply. Claims attached to shipping bills filed before 1 May 2026 remain governed by the pre-amendment schedule. If your export product falls under one of the 142 newly added tariff lines, the financial benefit is available only for shipments exported from 1 May 2026 onward.

Sources

Article Information

Published: June 4, 2026

Last Reviewed: June 4, 2026

Category: Customs

Regulatory Body: CBIC (Central Board of Indirect Taxes and Customs)

Written by C.K. Gupta, M.Com & Tax Editor at TaxGST.in — assisting importers and exporters with customs duty, drawback claims, and DGFT compliance since 2009.

Official Resources

Disclaimer: This article is for informational purposes only. Customs duty rates and trade policies change frequently. Always refer to the official CBIC/DGFT notifications for authoritative information. Consult a licensed customs broker for specific import/export queries.

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DGFT Export-Import Policy 2026: Silver Import Rules, SEZ QCO Exemptions & FEMA Regulatory Guide

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