The RoDTEP Annual Return: Who Has to File It, and What Missing It Stops
Most RoDTEP problems are about one shipping bill. This one is not. Above a claim threshold, an exporter owes DGFT a return every year, and the price of missing it is not a fine on a screen: it is that no further scrolls come out at the port of export. Here is who owes it, by when, what it costs late, and what stops until it is filed.
What the return is, and the instrument behind it
The Annual RoDTEP Return, usually shortened to ARR, is a yearly account of the duties and taxes you actually bore on what you exported. It is not a claim and it does not pay you anything. It is the evidence base DGFT uses to check that the rates it notified bear some relation to what exporters really incur.
The obligation lives in Para 4.94 of the Handbook of Procedures 2023, which was not in the Handbook as originally notified. It was inserted by Public Notice No. 27/2024-25 dated 23 October 2024, issued under Paras 1.03 and 2.04 of the Foreign Trade Policy 2023. Para 4.94(1) requires an exporter claiming RoDTEP benefits to file an annual return "as per the format given under Appendix-4RR of Handbook of Procedures, 2023", and provides that the return for claims filed in a particular financial year "shall be filed on DGFT portal by 31st March of the next financial year".
Who actually has to file
Para 4.94(1) sets the gate at the exporter rather than at the shipment: the requirement is "to begin with the exporters (IECs) whose total RoDTEP claim exceeds Rs. 1 crore in a financial year across all 8-digit HS Codes". Three things follow from the wording, and each one catches somebody out.
- It is measured per IEC, not per shipment or per buyer. An exporter running many small consignments reaches the threshold the same way as one running a few large ones.
- It is measured across all 8-digit codes together. You do not get to look at your largest product line and stop there. The test is the total claim for the year.
- It is measured on the claim, not on turnover. Export turnover is the number most exporters have to hand, and it is not the number in the paragraph.
DGFT's own ARR Help Manual and FAQs adds a second tier that Para 4.94 does not contain. Once the Rs 1 crore gate is crossed, the manual directs that if no single 8-digit ITC-HS code exceeds Rs 50 lakh you file only for the highest-claim code, and that if any codes do exceed Rs 50 lakh you file a return for each of them. It also treats Domestic Tariff Area exports and Advance Authorisation, Export Oriented Unit and Special Economic Zone exports as separate returns. That guidance sits in a help document rather than in a public notice, which means DGFT can revise it without issuing anything, so read the current version before you file rather than working from a copy.
The date, and the two clocks that run after it
The return is due by 31 March of the financial year following the one the claims were filed in. What most write-ups omit is that the consequence does not land on that date. Para 4.94(2) attaches it to the end of a grace period instead, and Para 4.94(3) prices the delay in two steps.
- Up to 30 June. The return can still be filed late on payment of a composition fee of Rs 10,000.
- After 30 June. The composition fee rises to Rs 20,000, and this is also the point at which the scroll consequence below begins to bite.
A figure of Rs 15,000 circulates widely as though it were a third tier. It is not. It is a one-off fee attached to a specific extension of one particular year's return, covered further down, and quoting it as the general late fee will understate what an exporter past the grace period actually owes.
What non-filing actually stops
This is the part worth reading twice, because the consequence is not administrative. Para 4.94(2) provides that non-reporting of the return leads to denial of benefits under the scheme, and that no further scroll-out of the claims on the shipping bills will be permitted "at the Customs Port of Export after the grace period of three (3) months i.e. after 30th June".
Read where that lands. It is not a block on the DGFT portal that you notice next time you log in. It is a stop at the customs port of export on the scroll-out of your RoDTEP claims, on shipping bills that are otherwise perfectly in order. The claims keep being filed and nothing keeps coming out of them.
The route back is in Para 4.94(3): "Subsequent to the payment of the applicable composition fee, the RoDTEP scrolls will be resumed within 45 days", and that resumption "shall also cover the Shipping Bills that were not scrolled out earlier on account of non-compliance of ARR". So nothing is forfeited, but the exporter carries the gap: the credit that would have become a scrip sits unissued for the period the return was outstanding plus up to another forty-five days after the fee is paid.
Why this is a cash-flow event and not a paperwork one
A RoDTEP credit only becomes something you can sell once the scroll matures at the port and the scrip issues into the ledger. Stop the scroll-out and you have stopped the supply at its source: there is no scrip in the ledger, so there is nothing to price and nothing to sell, however many shipping bills you filed in the meantime.
That makes an unfiled return an unusually expensive piece of paperwork for an exporter who was relying on scrip sales as a working-capital line. The composition fee is the small number in this story. The large one is the credit sitting outside the ledger for months. If your scrolls have gone quiet and you are looking for a cause, this is worth eliminating before the usual suspects: RoDTEP scroll not generated covers the others.
There is also a second clock to keep in view. A scrip's own validity runs from its creation in the ledger rather than from the export, so a delayed issue does not shorten the scrip once it arrives, but it does compress the window in which the whole year's credit has to be turned into cash. When a scrip expires sets out that clock.
What you actually file
The format is Appendix 4RR, annexed to Public Notice No. 27/2024-25 and titled "Format for submitting data under Annual RoDTEP Return (ARR)". It is furnished export-product-wise, with a separate sheet per product, and it asks for the embedded taxes that RoDTEP exists to remit rather than for anything from your GST returns. The field groups cover inbound and outbound transport VAT and excise on fuel, electricity duty, stamp duty on export documents, fuel used to generate captive power, embedded central and state GST paid on supplies from unregistered dealers, and the cumulative prior-stage taxes carried in your inputs.
Para 4.94(4) then requires the records substantiating the claim to be kept for five years. That is the part to plan for at the point of filing rather than at the point of being asked.
Where it is filed
On the DGFT portal, not on ICEGATE, and not with your customs broker. Trade Notice No. 27/2024-25 dated 29 January 2025 introduced the online module and records that it "can be accessed on the DGFT Portal- www.dgft.gov.in under the link 'Regulations>RoDTEP'". The public landing page for the service is the RoDTEP page on dgft.gov.in, which carries an "Application for Annual Return" card and a link to DGFT's own FAQs. Filing itself is behind a DGFT login against the IEC, so the filing service has no public URL to give.
The date has moved before, which is not a reason to plan for it moving again
The first return year is a fair guide to how DGFT has handled this so far, and it was extended more than once. Under Public Notice No. 27/2024-25 the return for claims filed in FY 2023-24 was due by 31 March 2025. Public Notice No. 24/2025-26 dated 3 October 2025 carried it to 30 November 2025 with a Rs 10,000 composition fee. Then Public Notice No. 46/2025-26 dated 5 February 2026 provided that "the period for filing Annual RoDTEP Returns for Financial Year 2023-24 is further extended till 31.03.2026 with payment of a composition fee of Rs 15,000/-", and warned that non-filing by that date attracts the Para 4.94 measures "including denial of RoDTEP benefits and scroll-out of scrips".
That is where the Rs 15,000 comes from, and it is why it is not a general fee: it was the price of the final window on one year's return. Reading the pattern as a promise that the next year will also be extended is the expensive version of this page. The standing rule in Para 4.94 has not been amended, and it is the rule an exporter is measured against on the day.
What we could not establish
- Whether any year after the first will be given the same treatment. Public Notice No. 46/2025-26 is the most recent public notice on the annual return that we could find on DGFT's public-notice list, and no later notice extends any subsequent year. On the standing Para 4.94 clock, a later year runs to 31 March of the following financial year with the three-month grace and the two fee tiers above. We are stating the rule rather than predicting a notice: if you are late, read the public-notice list before you assume either way.
- The current state of DGFT's own help material. The ARR Help Manual and FAQs is still written against the first return year throughout, down to a period-of-export field fixed to those dates. It remains the only official account of the Rs 50 lakh per-code rule, which is why that rule is attributed to it above rather than to the public notice, and it is not a reliable description of a later filing cycle.
- Any consolidated text of the paragraph. The Handbook of Procedures 2023 PDF that DGFT serves is the text as originally notified and does not contain Para 4.94, so the operative wording quoted here is taken from the public notice that inserted it.
Checked against the instruments named on this page: the notification register and the notification PDFs themselves, not anyone’s copy of them.
Frequently asked questions
Who has to file the Annual RoDTEP Return?
Para 4.94(1) of the Handbook of Procedures 2023, inserted by Public Notice No. 27/2024-25 dated 23 October 2024, applies the requirement to begin with to exporters whose total RoDTEP claim exceeds Rs 1 crore in a financial year across all 8-digit HS codes. The test is on the claim rather than on export turnover, and it is measured per IEC.
What is the due date for the Annual RoDTEP Return?
Para 4.94(1) requires the return for claims filed in a financial year to be filed on the DGFT portal by 31 March of the next financial year. A grace period runs for three months after that, to 30 June.
What is the composition fee for filing late?
Para 4.94(3) sets Rs 10,000 for a delayed filing up to 30 June and Rs 20,000 after 30 June. The Rs 15,000 figure often quoted is not a tier of the scheme: it was a one-off fee attached to the final extension of the first return year by Public Notice No. 46/2025-26 dated 5 February 2026.
What happens if I do not file the Annual RoDTEP Return?
Para 4.94(2) provides that non-reporting leads to denial of benefits under the scheme and that no further scroll-out of RoDTEP claims for your shipping bills will be permitted at the customs port of export after the three-month grace period. The claims keep being filed and nothing comes out of them.
Do the scrolls resume once I file?
Yes. Para 4.94(3) provides that after the applicable composition fee is paid the scrolls are resumed within 45 days, and that the resumption also covers the shipping bills that were not scrolled out earlier because the return was outstanding. Nothing is forfeited, but the credit sits unissued in the meantime.
Where is the Annual RoDTEP Return filed?
On the DGFT portal, under Regulations then RoDTEP, using the online module introduced by Trade Notice No. 27/2024-25 dated 29 January 2025. It is not filed on ICEGATE. The format is Appendix 4RR, annexed to Public Notice No. 27/2024-25.