Phased Implementation of SCMTR, 2018 by End Jan 2027; Old Export Messages to Be Discontinued by 31 January 2027

Ø SCMTR Faces Resistance, Over Regulation and Reliance Online Pre-arrival not Feasible, Blind Adoption of WCO SAFE Procedures Alleged

[Circular No. 47/2026-Customs dated 1 November 2026]

1. Background

o CBIC has issued instructions for implementing the Sea Cargo Manifest and Transhipment Regulations (SCMTR), 2018.

o DG Systems has deployed all import and export leg messages under the SCMTR framework.

o However, export-side SCMTR filing is still limited to certain ports.

2. Reason for Transition Extension

o Custodians, terminal operators and trans-shippers have not fully migrated to SCMTR-based filing.

o Delays are mainly due to:

§ Dependence on third-party software.

§ Time required for system integration.

§ Lack of operational readiness.

§ Adoption of SCMTR-compliant software and message formats.

3. Phased Discontinuation of Existing Export Messages

o CBIC has decided to discontinue erstwhile export messages in a phased manner.

o The transition will be completed by 31 January 2027.

o CIM messages under SCMTR, 2018 will become mandatory according to the prescribed zone-wise schedule.

4. Zone-wise Implementation Schedule

Customs Zone	Date of Implementation
Thiruvananthapuram	16.11.2026
Bengaluru	23.11.2026
Visakhapatnam & Hyderabad	27.11.2026
Bhubaneswar	01.12.2026
Trichy Preventive	07.12.2026
Chennai	07.12.2026
Kolkata & Guwahati	14.12.2026
Patna & Bhopal	14.12.2026
Delhi & Delhi Preventive, Meerut	06.01.2027
Ahmedabad	06.01.2027
Mumbai Zones I & II, Nagpur & Pune	06.01.2027

5. Instructions to Stakeholders

o All stakeholders must adopt SCMTR-compliant software and message formats during the transition period.

o Customs field formations may issue Public Notices and conduct outreach programmes to familiarise trade with SCMTR requirements.

o System-related issues will be resolved in coordination with DG Systems.

o Policy-related issues should be referred to CBIC.

6. Relaxation from Penal Action

o No penal action shall be taken during the implementation phase.

o Difficulties in implementation may be brought to the notice of the Board.

Effect of this Circular:

· Existing export message filing will be discontinued zone-wise and replaced by mandatory CIM messages under SCMTR, 2018.

· The transition provides additional time for custodians, terminal operators, trans-shippers and other stakeholders to complete system integration.

· No penal action will be initiated during the implementation phase.

The trade (shipping lines, agents, freight forwarders/NVOCCs, consolidators, custodians, terminal operators, and transhippers) is not fundamentally opposed to the goals of SCMTR 2018, but has raised strong concerns and resistance due to practical, operational, technical, and cost-related difficulties during its long, phased rollout.

CBIC itself has repeatedly acknowledged these issues by extending transition periods (most recently into early 2027 in some zones), directing no penal action during implementation phases, and allowing phased discontinuation of old messages to avoid disrupting cargo clearance.

Main reasons for trade resistance and difficulties

Heavy dependence on third-party software and slow system integration

Many stakeholders (especially custodians, terminal operators, and transhippers) rely on external IT vendors. Updating systems to handle the new structured electronic messages (JSON formats for SAM, SDM, CSN/SCX, stuffing reports, inland movement messages, etc.) takes time, testing, and money. Export-side filings in particular have lagged at many ports for this reason.

Technical defects, system glitches, and data mismatches in the Customs/ICEGATE platform

Early and ongoing trials revealed problems such as:

Issues generating or handling Vessel Call Numbers (VCN) and rotation numbers (especially at minor ports or for coastal/foreign trade distinctions).

Requirements that force incorrect data entry (e.g., forcing a foreign port of call when not applicable).

Difficulties uploading certain vessel/crew-related documents.

Validation errors, rejection codes, and mismatches between master/house bills, HS codes, addresses, PANs, PCINs, etc.

Dual filing (old IGM/EGM + new SCMTR) creating redundancy and data integrity problems until legacy systems are fully switched off.

Stricter and earlier data requirements + tighter cut-offs

Information that was previously assembled closer to arrival must now be complete and accurate much earlier (e.g., before the vessel leaves the last foreign port for SAM). Carriers often demand data 72–96 hours in advance. Incomplete or inconsistent details (addresses, HS codes, consignee info, etc.) lead to rejections, amendments, or cargo holds. Amending filings after acceptance is procedural and can be costly/time-consuming.

Additional compliance burden, registration, and potential costs

Mandatory registration on ICEGATE for specific roles (Authorised Sea Carrier, Agent, Transhipper, Custodian, etc.), often with bonds/guarantees.

Need for Digital Signature Certificates (DSC), accurate multi-party coordination (line files master; forwarder files CSN), and consistent data across documents.

Risk of processing delays, demurrage, or (once fully enforced) penalties if filings are late, incomplete, or mismatched.

Extra operational effort and possible charges for amendments (carriers may bill clients for corrections).

Operational disruption risk and uneven readiness

Not all ports, parties, or software providers were ready at the same pace. Low filing rates for certain messages (especially export-related) led to repeated extensions. Stakeholders feared cargo clearance delays or holds if the switch happened too abruptly, which is why CBIC has emphasised phased implementation and outreach.

In short, the trade supports modernisation and digitalisation in principle (as it aligns with global standards and can eventually speed clearance), but objects to the execution challenges: software readiness gaps, system bugs, earlier/stricter data demands, coordination complexity across multiple parties, and the risk of operational hiccups during the transition. CBIC’s repeated extensions and “no penalty during implementation” directives are direct responses to these industry concerns.