PARA 2.58 OF FTP

Policy Relaxation Committee (PRC) Representation

Has your application been rejected by the Regional Authority due to a procedural lapse? We represent your case at DGFT Headquarters to condone delays and relax policy provisions.

Case Assessment

Tell us why your case was rejected.

What is the Policy Relaxation Committee?

The DGFT (Directorate General of Foreign Trade) operates strictly according to the Foreign Trade Policy (FTP). Regional Authorities (RAs) have limited powers and cannot deviate from the policy text.

However, Para 2.58 of the FTP empowers the DGFT to relax any provision of the policy in cases of "Genuine Hardship" or "Public Interest". The Policy Relaxation Committee (PRC), chaired by the DGFT in New Delhi, is the body authorized to consider such requests. It is often the last resort for exporters to save their licenses from cancellation or heavy penalties.

Common Disputes

When Should You Approach PRC?

Clubbing of Licenses

Request to club two or more Advance Authorisations or EPCG licenses that do not strictly meet the clubbing criteria (e.g., different ports of registration or issued under different policy periods).

Excess Import

Regularization of excess inputs imported duty-free by mistake, or imports made after the validity of the license has expired.

EODC Rejection

If the RA rejects your redemption application due to technical mismatch in Shipping Bills (e.g., Description mismatch or unit quantity code errors).

Late Document Submission

Condonation of delay in submitting the Installation Certificate for EPCG or export documents for Advance Authorisation beyond the prescribed time limit.

Pre-Import Condition

Issues related to the violation of "Pre-import" conditions in Advance Authorisation where inputs were used replenishment basis instead of actual user.

Roadmap to Relief

The Representation Process

Success in PRC depends entirely on how well "Genuine Hardship" is proven. A simple letter is not enough.

1

Analysis

Review of the Rejection Letter from RA and identifying the lapse.

2

Drafting

Preparation of ANF-2D and a detailed petition proving hardship.

3

Filing

Online submission to DGFT HQ with application fee (₹ 2,000).

4

Meeting

Personal Hearing at Udyog Bhawan (if required) to argue the case.

Order

PRC issues minutes. RA implements the decision.

Professional Fees

Drafting & Filing

Petition Preparation

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Depends on complexity

  • Legal Analysis of Rejection
  • Drafting ANF-2D
  • Hardship Justification
  • Online Filing Support
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Personal Representation

Hearing at DGFT HQ

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Per Visit / Hearing

  • Appointment Management
  • Physical Representation
  • Verbal Arguments
  • Liaison with Section Officer
Book Consultant

*Government Fee for PRC Appeal is ₹ 2,000.

Why CloudDesk for Policy Relaxation ?

The PRC is a discretionary committee. You don't win on 'requests'; you win on 'Justification' and 'Public Interest'.

1. Drafting the "Genuine Hardship" Narrative

The committee only acts if you prove that following the policy would cause "Genuine Hardship" due to reasons beyond your control (e.g., pandemic, war, sudden policy change, or massive system glitches). CloudDesk drafts a high-impact Statement of Facts that connects your struggle to the broader "Public Interest."

2. ANF-2D Precision Filing

The application is filed via Ayaat Niryaat Form 2D. We ensure every Shipping Bill, e-BRC, and previous rejection letter is mapped. In 2026, the portal allows up to 10 attachments; we prioritize the most "lethal" evidence to ensure the committee sees the core issue first.

3. Personal Hearing (PH) Representation

If the case is complex, we request a Personal Hearing. In 2026, these are mostly conducted via video conferencing. We prepare your technical representative to answer the "Why should we break the rule for you?" question from the Director General.

4. Liaison with the "Policy-Z" Section

Once the PRC minutes are published and your case is "Recommended," the battle isn't over. We follow up with the Policy-Z section at DGFT HQ to ensure the formal "Policy Relaxation Order" is sent to your Regional RA so they can finally issue your license or EODC.

Frequently Asked Questions

Is the PRC decision final?

Generally, yes. The decision of the Policy Relaxation Committee is communicated to the RA for implementation. If rejected, further legal recourse may involve filing a Writ Petition in the High Court, but administrative remedies within DGFT are usually exhausted at this stage.

What constitutes "Genuine Hardship"?

It refers to situations beyond the control of the exporter, such as natural calamities, sudden policy changes by foreign governments, or financial insolvency of the buyer. Mere negligence or ignorance of law is usually not considered genuine hardship.

How long does it take for a decision?

The PRC typically meets once a month. Once the application is complete and filed, it may take 1–3 months to get listed for a meeting and receive the minutes.

What kind of cases does the PRC handle?

Common cases include:
Extension of Export Obligation (EO) period after all regular extensions are exhausted.
Revalidation of expired Duty Credit Scrips (MEIS/SEIS/RoDTEP).
• Acceptance of Shipping Bills where the "Intent to claim benefits" was marked "No" by mistake.
Clubbing of licenses that don't meet the standard "same HSN" criteria.

What is "Public Interest" in a PRC context?

If your failure to export causes massive job losses, or if a government system (like ICEGATE) was down during your deadline, the PRC considers relaxation to be in the "Public Interest."

Can I apply to the PRC if I just forgot the deadline?

No. Mere negligence is not "Genuine Hardship." You must show a reason that a "reasonable person" could not have avoided.

What is the fee for a PRC application in 2026?

Fresh Application: ₹2,000.
Review Application (if rejected once): ₹5,000.

How long does a PRC decision take?

The committee usually meets once or twice a month. From filing to the publication of Minutes of the Meeting (MoM), it typically takes 45 to 90 days.

Can I track my PRC case online?

Yes. Under "Submitted Applications" on the DGFT portal, you can see the "Life Cycle" of your PRC file.

My case was "Deferred." What does that mean?

It means the committee wants more data or a clarification. You will receive a Deficiency Letter. You must respond within the stipulated time, or the case will be "Rejected" in the next meeting.

If the PRC rejects my case, is it over?

You can file a Review Application (with the ₹5,000 fee) if you have new evidence that wasn't presented the first time. If the Review is also rejected, your only remaining option is a Writ Petition in the High Court.