DGFT Notification 04/2026-27: Wood Pellet and Briquette Exporters Now Need Restricted Authorization

On the morning of April 7, 2026, a Gujarat-based wood briquette manufacturer received a WhatsApp message from his freight forwarder: the export consignment scheduled to leave Mundra Port that afternoon was on hold. No formal stop-order had arrived. The forwarder had simply seen a DGFT notification dated the day before and, out of caution, halted the truck. By the time the exporter pulled up the notification on the DGFT portal, a week's worth of production, already palletised and shrink-wrapped for a South Korean buyer, sat in a CFS yard attracting detention charges.

What that exporter did not yet know was that his situation was one of two distinct policy changes compressed into a single three-page document. DGFT Notification No. 04/2026-27, signed by Lav Agarwal, Director General of Foreign Trade, and dated April 6, 2026, amended Chapter 44 of ITC (HS) 2022, Schedule-II (Export Policy) with immediate effect. The notification reclassified wood pellets (HS 44013100) from 'Prohibited' to 'Restricted', and wood briquettes (HS 44013200) from 'Free' to 'Restricted'. In the language of Indian trade policy, these are not minor administrative adjustments. They are structural category changes that alter the fundamental legal basis on which goods can be dispatched.

The notification did not emerge in a vacuum. By early April 2026, India was managing its most serious domestic energy disruption in decades. The conflict in West Asia, escalating from late February 2026, had effectively closed the Strait of Hormuz to commercial shipping. India imports roughly 60 to 65 percent of its LPG through that corridor. With 330 million households dependent on LPG cylinders and the Union Ministry of Environment, Forest and Climate Change permitting restaurants and hotels to temporarily use biomass fuels as a substitute, the demand signal for wood-based combustibles inside India shifted dramatically. The government's calculation was clear: in a supply emergency, biomass that might have left the country as a premium export commodity was worth more as domestic fuel.

The practical consequences for India's biomass export industry are not simple. Wood pellet producers, who had operated under a blanket prohibition since the category was placed on the restricted list years ago, now face a paradoxical situation: they have received permission to export, but only under a licensing regime they have never had to navigate. Wood briquette exporters, many of them MSME-scale operators who built supply chains on the back of a free-export status, must now pause, apply, wait for authorization, and only then ship. Contracts with buyers in Japan, South Korea, the United Kingdom, and the Netherlands cannot be fulfilled on the old assumption that briquettes carry no export restriction.

This article maps both policy changes in full, explains the authorization mechanism exporters must use, traces the energy-security reasoning that drove the decision, and places the notification in the context of a global wood pellet and briquette market that remains one of the fastest-growing segments of the renewable energy supply chain.

What Changed, and What It Means in Legal Terms

The formal authority for Notification No. 04/2026-27 rests with Section 3 of the Foreign Trade (Development and Regulation) Act, 1992 (FTDR Act), read alongside the Foreign Trade Policy (FTP) 2023. Under this framework, the Central Government holds the power to prohibit, restrict, or regulate the export of any goods by notification. The DGFT, acting as the designated authority under the Ministry of Commerce and Industry, issues such notifications routinely, but reclassifications of the kind announced on April 6, 2026, are consequential events rather than housekeeping amendments.

The ITC (HS) 2022 Schedule-II is the master document governing India's export policy. Goods are classified under four categories: Free (no restriction beyond standard documentation), Restricted (requires DGFT authorization), Canalized (permitted only through specified state trading enterprises), and Prohibited (not permitted under any circumstances). A move from Prohibited to Restricted, as occurred for wood pellets, represents a liberalization, since goods that could not be exported at all may now be exported under license. A move from Free to Restricted, as occurred for wood briquettes, represents a tightening, since goods that required no license now require one.

The notification specifies that both changes take effect 'with immediate effect.' This phrase carries precise legal weight. It means the reclassification applied from the moment of notification, without any transition period or grandfather clause for existing contracts, invoices already raised, or goods already at port. The TaxCorp analysis of the notification, published April 7, 2026, states explicitly: 'Once a DGFT notification specifies that amendments take effect immediately, exporters cannot rely on earlier policy status for any new export contracts.' Goods arriving at customs after April 6, 2026 without a Restricted Export Authorization are in breach of the revised policy, regardless of when the contract was signed or the invoice was raised.

DGFT NOTIFICATION 04/2026-27: KEY PARAMETERS
Notification No.	04/2026-27-DGFT
Date of Issue	April 6, 2026
Issuing Authority	Lav Agarwal, DGFT & Ex-Officio Addl. Secretary, MoCI
File No.	01/91/171/166/AM21/Part-I/E-45738
Legal Basis	FTDR Act, 1992 & Foreign Trade Policy, 2023
HS 44013100 (Wood Pellets)	Prohibited → Restricted (immediate effect)
HS 44013200 (Wood Briquettes)	Free → Restricted (immediate effect)
ITC (HS) Reference	Chapter 44, Schedule-II (Export Policy) 2022
Authorization Required	Restricted Export Authorization from DGFT
Prior Status (Pellets)	Blanket prohibition on all exports
Prior Status (Briquettes)	Free export; only standard documentation required

The distinction between the two products matters operationally. Wood pellets (HS 44013100) are cylindrical, compressed biomass fuel products manufactured to precise density and moisture specifications, typically exported to industrial power plants and district heating utilities in Europe and East Asia. Wood briquettes (HS 44013200) are denser, brick-shaped fuel blocks produced by compressing biomass under high pressure without binders, used across a wider range of end-uses including household cooking, hotel kitchens, and small industrial boilers. The export volumes and buyer profiles differ. The businesses disrupted by each part of the notification differ. The compliance burden each category now faces is, however, identical: a Restricted Export Authorization before goods can move.

 The Energy Crisis Behind the Policy: Hormuz, LPG, and the Domestic Biomass Pivot

To understand why April 6, 2026 was chosen as the date for this notification, one has to go back to late February. The conflict in West Asia, involving the United States, Israel, and Iran, escalated sharply in the last days of February 2026. By early March, Iran had effectively closed the Strait of Hormuz, the narrow maritime corridor that carries roughly 20 percent of the world's oil and liquefied natural gas. The International Energy Agency described the resulting supply disruption as 'the greatest threat to global energy security in history.' The head of the IEA's energy security division characterised it as the largest supply disruption in the history of the global oil market.

For India, the Strait closure had a specific structural impact that differed from the experience of most other large importers. India imports approximately 88 percent of its crude oil, with 40 percent of that transiting Hormuz. Its LPG import dependence is more acute: 60 to 65 percent of national consumption is imported, and 90 percent of those imports historically passed through the Strait. India's LPG secretary, Neeraj Mittal, told an industry event in early April 2026: 'In LPG, our import dependence comes roughly to about 90 percent on the Strait of Hormuz.' The scale of that single-corridor dependency meant that even a partial closure sent domestic LPG availability into crisis within weeks.

The situation in West Asia is concerning and worrisome. Any closure of the Strait of Hormuz is unacceptable. Despite the blocking of this route, we are ensuring that our needs are met.

Prime Minister Narendra Modi, addressing the Lok Sabha, March 2026

By mid-March 2026, the visible signs of the LPG shortage were widespread. Long queues formed at distribution points in Delhi, Mumbai, Bengaluru, Kolkata, and Prayagraj. Domestic 14.2-kg cylinders rose in price by approximately Rs. 60, reaching Rs. 913 to Rs. 928 in major cities. Commercial 19-kg cylinders increased by Rs. 114 to Rs. 115. The National Restaurant Association voiced operational concerns as hotels and restaurants could no longer maintain standard kitchen operations. The central government, on March 13, 2026, approved an additional 48,000 kilolitres of kerosene for public distribution to support low-income households. Refineries were directed to increase LPG output by diverting propane and butane streams, raising domestic production by an estimated 25 to 30 percent.

Critically for wood biomass exporters, the Union Ministry of Environment, Forest and Climate Change asked state pollution control boards to allow restaurants and hotels to temporarily use alternative fuels including biomass, fuel pellets, kerosene, and coal for a month, while LPG supplies were prioritised for households and essential services. This was not a marginal regulatory adjustment. It was a government signal that biomass combustibles, specifically pellets and briquettes, had been elevated to the status of emergency fuel substitutes.

INDIA'S ENERGY EXPOSURE: STRAIT OF HORMUZ DEPENDENCY (APRIL 2026)
Crude Oil Import Dependence	~88% of requirements imported; ~40% via Hormuz
LPG Import Volume	~60-65% of 31-32 MT annual consumption is imported
LPG Hormuz Dependency	~90% of LPG imports transited Strait of Hormuz
LNG Import Exposure	~50-55% of LNG imports via Hormuz corridor
Global Hormuz Disruption	~20% of global oil; ~20% of global LNG trade affected
IEA Characterisation	Largest supply disruption in history of global oil market
Brent Crude Spike (March 2026)	10-13% surge to ~USD 80-95 per barrel
India LPG Cylinder Price Rise	Rs. 60 increase to Rs. 913-928 per 14.2-kg domestic cylinder
LPG Storage Capacity	Only 2 underground LPG caverns (0.16 MT) = ~2 days' consumption
Strategic Petroleum Reserve	Caverns at Mangaluru and Visakhapatnam; enhanced since 2016

The connection between the Hormuz crisis and Notification 04/2026-27 is direct. One Indian news analysis, published by The Print on April 7, 2026, noted that the government 'eased export curbs on sawdust and wood waste and scrap' (moving them from Prohibited to Restricted) while simultaneously tightening briquette exports, describing the overall move as part of 'a series of measures taken by the government to manage the emerging energy situation.' An independent energy analysis published on TMV on April 7, 2026 stated that 'demand for biomass-based alternatives such as wood briquettes has surged sharply within the country' and placed industry estimates of biomass fuel exports, including briquettes and pellets, at approximately Rs. 2,000 crore annually.

 Understanding the Restricted Export Authorization: The Compliance Mechanism Exporters Must Navigate

The Restricted Export Authorization (REA) is not a new instrument in Indian trade law. It has existed under successive foreign trade policies as the primary mechanism for controlling exports of sensitive or strategically important goods. What has changed for wood pellet and briquette exporters as of April 6, 2026, is that a category they either could not export at all, or could export without a license, now sits within a licensing architecture that requires advance government approval for every consignment.

The application process runs entirely through the DGFT's digital platform at dgft.gov.in. Exporters with an active Importer Exporter Code (IEC) must log in to the DGFT dashboard, navigate to the eCOM Applications section, and select 'Restricted Item Import/Export.' The application form requires a Digital Signature Certificate (DSC), which must be obtained from an authorized Certifying Authority such as e-Mudhra or NIC before the application can be submitted. The application must specify the HS code of the goods, the quantity and unit of measurement, the destination country, the end-user details, and the export justification.

The applicable form for non-SCOMET restricted exports is ANF 2B. All applications are processed at DGFT Headquarters, Udyog Bhawan, New Delhi. Regional Authority offices do not issue Restricted Export Authorizations. The application fee is 0.1 percent of the Free On Board (FOB) value of the goods, subject to a minimum of Rs. 500 and a maximum of Rs. 1,00,000. Payment must be made online at the time of application. If an application is incomplete, DGFT will reject it with stated reasons and give the applicant 90 days to rectify and resubmit before the application is deemed withdrawn.

The following table maps the complete step-by-step authorization workflow for wood pellet and briquette exporters applying for the first time under the revised policy.

Step	Action	Portal / Authority	Key Requirement
1	Obtain/verify Digital Signature Certificate (DSC)	Certifying Authority (e-Mudhra, NIC)	DSC on USB token; valid for 2 years
2	Confirm IEC is active and updated on DGFT portal	dgft.gov.in	IEC must reflect current business address and directors
3	Classify goods correctly: HS 44013100 or HS 44013200	ITC (HS) 2022 Schedule-II	Misclassification can result in rejection or customs dispute
4	Prepare export justification and end-user details	Internal; to be uploaded with application	Include buyer details, end-use certificate if available
5	Apply online via eCOM Applications module	DGFT portal (dgft.gov.in)	Select 'Restricted Item Export'; complete ANF 2B form
6	Pay application fee (0.1% of FOB, min Rs.500, max Rs.1L)	Online payment on DGFT portal	Fee receipt auto-generated; must be retained
7	DGFT scrutiny at HQ (EXIM Facilitation Committee)	DGFT HQ, Udyog Bhawan, New Delhi	Incomplete applications rejected with 90-day rectification window
8	Authorization letter issued by DGFT HQ	DGFT HQ	Authorization is for specific quantity and value; cannot be exceeded
9	Present Authorization to Customs at port of export	Customs (CBIC)	Original must accompany shipping bill; verify endorsement
10	Revalidation if unused within validity period	DGFT HQ	Revalidation allowed for 6 months at a time, up to 12 months maximum

CAUTION: Common Misunderstandings About the Authorization

•      An authorization is issued for a specific quantity and value. Exceeding either limit requires a fresh application, not an amendment. Exporters must match the authorization exactly to the shipment Bill of Lading.

•      The authorization is not transferable between IEC holders. A group company cannot use an authorization issued to its subsidiary or associate entity.

•      Goods already at a Container Freight Station or Inland Container Depot on April 6, 2026, without a completed authorization are subject to the revised policy. There is no retrospective grace period.

•      Revalidation is granted 'on merits'; it is not automatic. Exporters who cannot utilize an authorization within its validity period should apply for revalidation at least 30 days before expiry.

•      ITC (HS) Chapter 44 covers a broad range of wood products. Exporters handling other Chapter 44 items should recheck their export policy status, as the notification amends multiple entries.

 The Separate Trajectories of Wood Pellets and Wood Briquettes

Wood Pellets (HS 44013100): From Prohibition to Controlled Export

The reclassification of wood pellets from Prohibited to Restricted marks a significant shift in how India treats this product category. A Prohibited status means that no export can take place under any circumstances, regardless of end-use, buyer, or quantity. By moving pellets to Restricted, the government has opened a legal pathway for export that did not previously exist, while retaining control over which shipments are actually authorized. For pellet producers who had given up on export markets, this is a structural opportunity, though one hedged by authorization requirements.

The word 'prohibited' in the ITC (HS) export policy has always sat uneasily with the commercial reality of the Indian wood pellet industry. India has significant biomass surplus, estimated at approximately 230 million tonnes of surplus availability per year against a total annual biomass output of around 750 million tonnes. The country has invested in pelletisation capacity under the SAMARTH mandate, which requires five percent biomass co-firing at thermal power plants from FY 2025-26. Production capacity had been built partly on the expectation of eventual export. Under the Prohibited category, none of that capacity could serve global buyers. The Restricted reclassification removes that ceiling, replacing it with a case-by-case authorization filter.

The SAMARTH mandate of 5 percent co-firing from FY 2025-26 has created a strong and assured demand signal. The biomass sector now faces both domestic policy pull and, for the first time, a legal export pathway via Restricted Authorization.

Indian Federation of Green Energy, analysis published in Daily Pioneer, April 2026

Wood Briquettes (HS 44013200): From Free Export to License-Based Control

The briquette change is more commercially disruptive. Under the Free category, a briquette exporter needed only standard documentation: a Shipping Bill, a commercial invoice, a packing list, and a valid IEC. No advance government approval was required. Export transactions could proceed at commercial speed. The shift to Restricted inserts a mandatory DGFT approval step before any goods can move, regardless of shipment size or buyer relationship.

India's wood briquette export industry has grown on the back of free-export status. The sector supplies buyers in South Korea, Japan, the Netherlands, Germany, and the United Kingdom, markets where biomass-based heating and power generation have expanded under EU renewable energy directives and Asian co-firing mandates. India's biomass briquette market was valued at USD 83.73 million in 2023 and is projected to reach USD 153.55 million by 2032 (Introspective Market Research, April 2025), growing at a 7.05 percent CAGR. A significant share of that growth was predicated on unrestricted export access. That assumption must now be revised.

The domestic context for briquette tightening is the same energy security logic that applies to pellets. With wood briquettes now cleared for use as an authorized substitute for LPG in commercial kitchens and hospitality under the March 2026 MoEF&CC advisory, the government has an immediate policy reason to ensure that briquette supply is not diverted to export markets when domestic demand has surged.

The table below compares the pre-notification and post-notification status of both product categories across the key regulatory dimensions relevant to exporters.

Dimension	Wood Pellets (HS 44013100) BEFORE April 6, 2026	Wood Pellets (HS 44013100) AFTER April 6, 2026	Wood Briquettes (HS 44013200) BEFORE April 6, 2026	Wood Briquettes (HS 44013200) AFTER April 6, 2026
Export Policy Category	Prohibited	Restricted	Free	Restricted
Authorization Required?	No export permitted	Yes: Restricted Export Authorization from DGFT HQ	No authorization required	Yes: Restricted Export Authorization from DGFT HQ
Application Form	N/A	ANF 2B (non-SCOMET)	N/A	ANF 2B (non-SCOMET)
Processing Authority	N/A	DGFT HQ, Udyog Bhawan, New Delhi	N/A	DGFT HQ, Udyog Bhawan, New Delhi
Application Fee	N/A	0.1% of FOB value (min Rs.500, max Rs.1L)	None	0.1% of FOB value (min Rs.500, max Rs.1L)
Goods at Customs Without Auth.	Legal bar on export	Customs may detain shipment; IEC at risk	Permitted; no legal obstacle	Customs detention; potential penalty under FTDR Act
Export Contracts (status post-notification)	N/A (export not possible)	Must obtain authorization before contract fulfillment	Enforceable without restriction	Must be renegotiated or delayed pending authorization

 The Global Market These Exporters Are Trying to Reach

The notification arrives at a moment when global demand for wood pellets and briquettes is structurally strong. The global wood pellet market was valued at USD 14.8 billion in 2025 by the IMARC Group and is projected to reach USD 23.3 billion by 2034, growing at a CAGR of 5.20 percent. Europe remains the dominant consumer, holding approximately 47.9 percent of global market share in 2025. Within Europe, the United Kingdom is the single largest user of pellet-based energy, consuming more than 8 million tonnes per year, almost entirely through imports. Denmark and the Netherlands follow, with industrial and utility-scale power plants accounting for the bulk of demand.

The EU Renewable Energy Directive (RED II) targets require member states to derive a minimum of 42.5 percent of their final energy from renewable sources by 2030. Germany's Building Energy Act, effective July 2026, mandates that newly installed heating units in cities of more than 100,000 inhabitants use at least 65 percent renewable heat. The German Pellet Institute (DEPI) forecasted that pellet-based heating system installations in Germany would reach 760,000 units over the course of 2025. Austria, Poland, and the Czech Republic have active government subsidy programs for biomass heating replacement of fossil fuel systems. All of this creates a sustained and growing European import demand for wood pellets and briquettes.

GLOBAL WOOD PELLET AND BRIQUETTE MARKET: KEY FIGURES (2025-2026)
Global Wood Pellet Market (2025)	USD 14.8 billion (IMARC Group)
Projected Market Value (2034)	USD 23.3 billion; CAGR 5.20% (2026-2034)
Europe Market Share (2025)	47.9% of global market; valued at USD 12.01 billion
UK Annual Pellet Consumption	>8 million tonnes/year; >90% sourced from imports
EU Wood Pellet Consumption (2025 est.)	~23.45 million metric tonnes (USDA/EU report, 2025)
Global Biomass Briquette Market (2025)	USD 0.96-1.05 billion; CAGR ~8-9.79% to 2030-2034
India Biomass Pellets Market (2024)	USD 600 million; projected USD 1.2 billion by 2035
India Biomass Briquette Market (2023)	USD 83.73 million; projected USD 153.55 million by 2032
India Annual Biomass Availability	~750 million tonnes/year; ~230 MT surplus
India Biomass Export Value (est.)	~Rs. 2,000 crore annually (pellets and briquettes combined)

In Asia, Japan and South Korea have used domestic subsidy frameworks to build biomass-based power generation capacity that is structurally dependent on imports. Japan's renewable energy feed-in tariff system has driven industrial-scale co-firing of wood pellets with coal at major utilities. The Japan Biomass Energy Association has tracked a multi-year expansion of wood pellet import volumes. South Korea's Renewable Portfolio Standard mandates that utilities derive a specified percentage of generation from renewable sources, with wood biomass qualifying under certain conditions. India is geographically well-placed to serve both markets, with shorter shipping distances than competing exporters in North America.

The EU Deforestation Regulation (EUDR), whose amended version was published in the EU Official Journal on December 23, 2024, postpones mandatory application to December 30, 2025 for most operators and June 30, 2026 for small and medium enterprises. Exporters into EU markets must now supply geolocation data and due-diligence documentation covering the full supply chain. This adds a compliance layer above and beyond the DGFT Restricted Authorization, but it does not make EU market access impossible. Indian producers with documented, certified biomass supply chains are in a structurally advantaged position to meet EUDR requirements compared to competitors sourcing from less traceable origins.

OPPORTUNITY: What the Restricted Category Actually Enables

•      Wood pellet exporters can now, for the first time, legally access international markets. Every long-term supply contract with European utilities that was impossible to execute under the Prohibited status is now accessible under a Restricted Authorization.

•      Producers with ENplus or equivalent quality certifications are immediately competitive in UK, Netherlands, and Danish utility markets, where import demand exceeds 8 million tonnes annually.

•      South Korea's Renewable Portfolio Standard and Japan's feed-in tariff system both support biomass imports. Indian exporters are geographically closer to these markets than competing North American or Baltic producers, giving a natural cost-of-freight advantage.

•      The SAMARTH domestic co-firing mandate (5% from FY 2025-26) is building biomass production capacity at scale. Exporters can run dual commercial strategies: supply thermal power plants under domestic mandates and apply for REA for incremental export volumes.

•      The EUDR compliance window for SME producers extends to June 30, 2026. Producers who begin supply chain documentation and geolocation mapping now can be ready for EU market entry by the second half of 2026.

 Compliance Failures: What Happens If You Export Without Authorization

The consequences of exporting Restricted goods without a valid authorization are not administrative inconveniences. They trigger enforcement mechanisms under the FTDR Act, 1992, and the Customs Act, 1962, that can result in detention of goods, cancellation of the exporter's IEC, financial penalties, and, in serious cases, prosecution.

At the port level, Customs officers examining shipping bills after April 6, 2026 have legal authority to detain any consignment of HS 44013100 or HS 44013200 goods that does not present a valid DGFT Restricted Export Authorization. Goods held at a Container Freight Station or port yard attract storage and detention charges from day one. These charges accumulate daily. Where the buyer has paid for the goods in advance, the detention also creates a breach of the export contract, potentially triggering bank guarantees or triggering dispute resolution clauses.

HIGH RISK: Compliance Failures and Their Consequences

•      Shipping goods under HS 44013100 or 44013200 without a valid REA after April 6, 2026 is a direct violation of the FTDR Act, 1992. Customs has legal authority to confiscate the consignment.

•      DGFT may issue a Show Cause Notice and, following an adjudication process, cancel or suspend the exporter's IEC. An IEC suspension effectively halts all export activity across all product categories, not just biomass.

•      Financial penalties under the FTDR Act can reach up to twice the value of the goods involved. For a consignment valued at Rs. 50 lakh, this means a maximum exposure of Rs. 1 crore in penalty, in addition to detention and storage charges.

•      Where goods are detained by Customs and the buyer cancels the order due to non-delivery, the exporter faces both the regulatory penalty and the commercial liability of a failed shipment, including potential letter-of-credit defaults.

•      Goods at a CFS or ICD on April 6, 2026 without an REA are exposed to the same risks as new shipments. 'Goods were packed before the notification' is not a recognized defense under the FTDR Act.

Exporters who had consignments in transit or at port on April 6, 2026 should seek legal advice immediately on whether goods that had already crossed the customs line under a valid Shipping Bill benefit from any protection. The general principle under Indian trade law is that goods cleared from Customs before the notification date retain their prior policy status. Goods not yet cleared as of the notification date are subject to the revised policy, regardless of the Shipping Bill date.

What Exporters Should Do Right Now: A Prioritised Action Sequence

The 'immediate effect' language in the notification leaves no time for a staged response. Exporters in this category need to run three parallel processes simultaneously: a legal and compliance review, a commercial review of existing and pending contracts, and a technical preparation for the DGFT authorization application. The following sequence is not sequential; it must run concurrently.

The first task is to establish the correct HS code for every biomass product in the export portfolio. Chapter 44 covers a wide range of wood and wood-derived products. Pellets and briquettes are specifically defined under HS 44013100 and HS 44013200 respectively. But biomass products derived from agricultural residue, or wood products that do not meet the technical definition of pellets or briquettes under the HS schedule, may fall under different subheadings with different policy statuses. A classification review conducted by a licensed customs broker or trade compliance specialist is not optional at this stage; it is the foundation on which everything else rests.

The table below provides a prioritised action checklist for exporters across the first four weeks following the notification. Timelines are approximations based on the DGFT standard processing cycle; actual authorization turnaround times may vary depending on application volume at DGFT HQ.

Timeline	Action	Owner	Output
Day 1-3	Confirm HS classification for all biomass export products via licensed customs broker	Compliance / Customs Broker	Written classification opinion with HS code mapping
Day 1-3	Audit all existing export contracts, LOCs, and LCs for wood pellets and briquettes post-April 6, 2026	Legal / Finance	List of affected contracts; exposure quantum
Day 1-5	Halt dispatch of goods at port/CFS without REA; apply Shipping Bill hold if possible	Logistics / Operations	No unauthorized goods cross customs line
Day 3-7	Inform buyers in UK, EU, Japan, Korea of regulatory change; request force majeure or shipment hold	Sales / Commercial	Written buyer acknowledgment; timeline renegotiation
Day 3-7	Obtain or verify Digital Signature Certificate (DSC) for authorized signatory	Compliance / IT	Valid DSC on USB token, registered on DGFT portal
Day 5-10	Prepare application file: IEC, IEC certificate, company GST, buyer details, end-user declaration, FOB value	Compliance	Complete document set uploaded on DGFT portal
Day 7-14	Submit ANF 2B application on DGFT portal; pay application fee online	Compliance	Application Reference Number from DGFT portal
Day 14-30	Monitor application status; respond to DGFT queries within 90-day rectification window if rejected	Compliance	Active monitoring; no lapse of rectification window
Day 30+	Upon REA receipt, present to Customs at port; re-confirm Shipping Bill details match REA exactly	Logistics / Compliance	Goods cleared against valid REA

REGULATORY REFERENCE: Key Documents and Sources for Exporters

•      Primary Notification: DGFT Notification No. 04/2026-27-DGFT, dated April 6, 2026 (available on dgft.gov.in under Notifications)

•      Legal Authority: Foreign Trade (Development and Regulation) Act, 1992, Section 3; Foreign Trade Policy, 2023

•      ITC Classification Reference: ITC (HS) 2022, Schedule-II (Export Policy), Chapter 44

•      Application Portal: dgft.gov.in > Services > eCOM Applications > Restricted Item Import/Export

•      Application Form: ANF 2B (for non-SCOMET Restricted Export Authorization)

•      Processing Authority: DGFT Headquarters, Udyog Bhawan, New Delhi (not Regional Authorities)

•      Application Fee: 0.1% of FOB value; minimum Rs. 500; maximum Rs. 1,00,000

•      EUDR Compliance (for EU exporters): Regulation 2024/3234; due diligence system operative from December 2025 (most operators) and June 2026 (SMEs)

•      Helpdesk: DGFT at dgft@nic.in for notification-specific queries

The Longer-Term Policy Signal: What This Notification Tells Exporters About India's Direction

Taken in isolation, Notification 04/2026-27 is a crisis-response measure. Taken as a data point in the larger arc of Indian trade policy, it tells a more complex story. India has, over the past five years, demonstrated a consistent pattern: when a domestic commodity or input becomes strategically important, the government shifts its export classification toward the Restricted or Prohibited end of the spectrum quickly and without grandfathering existing arrangements. Rice, wheat, sugar, onions, and several critical minerals have all been subject to abrupt export policy changes in FY23 through FY25. Wood biomass joins that list in FY26.

The decision to move wood pellets from Prohibited to Restricted, rather than leaving them prohibited, is significant. It reflects a more nuanced approach: the government wants to retain domestic supply but is willing to allow controlled export where it does not compromise domestic availability. This is the logic of a strategic commodity, not a blocked one. Exporters who build their commercial strategies around this logic, obtaining and maintaining REA while demonstrating that their production does not come at the cost of domestic supply adequacy, are likely to find a more predictable operating environment than those who treat the authorization as an obstacle to be minimised.

The trajectory of Indian trade policy on strategic domestic commodities is consistent: when domestic supply is under pressure, export controls arrive fast and without transition periods. Wood biomass exporters should plan for this as a recurring regulatory environment, not a one-time disruption.

SpheraLink Ventures 360, Export Policy Analysis, April 2026

The parallel easing of export restrictions on sawdust and wood waste (also moved from Prohibited to Restricted under the same notification) is a deliberate policy complement. It signals that the government distinguishes between finished biomass fuel products, which have direct domestic energy substitution value, and raw or semi-processed wood waste, which serves a different supply chain. Exporters who process raw wood waste into finished pellets or briquettes are now subject to the full REA regime. Those trading in sawdust or unprocessed wood residue gain a new, if controlled, export pathway.

The global market backdrop does not diminish in importance because India has imposed a Restricted classification. The Strait of Hormuz disruption is not a permanent condition, and when shipping normalises and LPG supply recovers, the domestic emergency rationale for restricting biomass exports will weaken. The DGFT Restricted category, unlike the Prohibited category, can be administered with varying degrees of liberality. If the energy emergency eases and authorizations are issued promptly and broadly, the effective impact on trade volumes may be less than the classification change initially suggests. Exporters who maintain active IECs, current DSCs, and clean application records are positioned to benefit from any easing of the authorization standard.

What the notification does not address is the medium-term structural question: if India is serious about becoming a significant exporter of wood biomass to European and Asian renewable energy markets, a case-by-case licensing regime is not a scalable infrastructure. Export volumes at the scale that would matter for the global market, hundreds of thousands of tonnes per year, would require either a framework authorization covering multiple shipments, or a sector-specific export management system similar to the Import Management System the DGFT already runs for restricted IT hardware. That system, operational since 2021 and renewed for 2026 under Policy Circular No. 08/2025-26, allows importers to apply for annual allocations rather than per-shipment licenses. An analogous export system for wood biomass would transform the regulatory environment for the sector. Its absence, for now, means that each shipment requires its own authorization.

The Wood Stack in the Yard

There is a particular kind of commercial limbo that Indian exporters know well: goods ready to move, a buyer ready to receive, and a regulatory gap sitting between them. The Gujarat briquette exporter whose consignment sat in the Mundra CFS yard on April 7, 2026 was not in that position through carelessness. He was there because a policy change took effect at midnight the previous day and the information reached him through a freight forwarder's WhatsApp message before it reached him through an official compliance channel.

That is how Indian trade policy works, and the record shows it clearly. The FTDR Act gives the Central Government the authority to amend export classifications with immediate effect, and that authority is used. Exporters who treat the date of a DGFT notification as the beginning of their compliance planning are already behind. The more durable response is to treat any commodity with an active domestic strategic dimension, which wood biomass has had since the SAMARTH co-firing mandate, as a candidate for future export classification change, and to build compliance readiness, including active DSCs, current IECs, and legal familiarity with the ANF 2B process, before the notification arrives.

Notification 04/2026-27 is simultaneously a setback and a structural opening. For briquette exporters, it imposes a compliance cost and a shipment delay that cannot be avoided. For pellet producers, it ends a prohibition that had kept them out of a USD 14.8 billion global market. Both groups now operate under the same authorization framework. The ones who understand that framework, apply correctly, respond to DGFT queries within the 90-day window, and maintain their export documentation as a live compliance asset rather than a box-ticking exercise, will ship.

Biomass is not a marginal fuel. In 2025, the global wood pellet market surpassed USD 14 billion. The UK imported more than 8 million tonnes of pellets in a single year. Germany was preparing to mandate 65 percent renewable heat in new urban heating installations from July 2026. Japan and South Korea were running subsidy programs specifically designed to pull biomass imports from Asia. The demand exists, the infrastructure to serve it is being built, and India has more surplus biomass feedstock than almost any other country in the region.