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NASSCOM Submission on Proposed Amendments related to export of Drones
NASSCOM Submission on Proposed Amendments related to export of Drones

September 26, 2022

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In September 2022, NASSCOM submitted feedback and suggestions on the proposed amendments to Category 5B of the SCOMET List related to export of Drones/Unmanned Aircraft Vehicles (UAVs) and the proposed General Authorisation for Export of Drones (GAED) published by the Directorate General of Foreign Trade (DGFT).

Our submission acknowledged that the proposed changes (1) have been made with the objective of simplifying the policy for export of drones and (2) are a step forward towards supporting the industry in complying with their export control obligations. Thereafter, our submission highlighted the following concerns with respect to the proposed amendments to the SCOMET List and the GAED:

  1. Inclusion of delivery drones and surveillance drones with greater than 10x zoom to the SCOMET list will result in inclusion of even commercial and toy-grade drones. This will add to the compliance burden of the drone industry, which comprises majorly of start-ups. 
  2. The Note to Category 5B is written in a manner that even if an item is not covered in the SCOMET list, the GAED will need to be applied for. We believe that it is not the intention of the DGFT to mandate the industry to apply for a general export authorisation, even in situations where the item to be exported is not covered under the SCOMET list. 
  3. The 5kg payload and 5km range proposed to be added is nowadays deployed even in toy drones and are beign tested for commercial use cases. This is also not aligned with the Missile Technology Control Regime (MTCR), of which India is a party.  
  4. The GAED application would be reviewed/examined for the issuance of GAED by Inter-Ministerial Working Group, which meets only once a month, thereby causing the industry to face delays of as much as over 6 months in the approval of their applications.

Overall, we have suggested that Category 5B should be amended to bring it in line with the relevant category of MTCR. The text of the Note to Category 5B should be amended to mean that only those drones that require a SCOMET licence, will be eligible to apply for a GAED.

Our detailed submission can be downloaded from below. 

For more information, kindly write to garima@nasscom.in


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Download Attachment

20220915_Drones_DGFT_NASSCOM.pdf

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Garima Prakash
Manager, Public Policy and Government Affairs

Reach out to me for all things policy about e-commerce, international trade, export controls, start-ups and fintech

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