CBIC Clarifies Testing Procedure for Export Samples: NABL-Accredited Lab Reports Can Be Accepted Without Mandatory CRCL Referral
The Central Board of Indirect Taxes and Customs (CBIC) has issued an important clarification addressing concerns raised by exporters regarding the testing of export consignment samples.
Industry representations highlighted that even when exporters obtained test reports from accredited laboratories, customs authorities often insisted on forwarding samples to Revenue Laboratories such as the Central Revenue Control Laboratory (CRCL). This resulted in duplication of testing, increased costs, and delays in export shipments.
To address these concerns, CBIC has clarified the circumstances under which test reports issued by recognized laboratories may be accepted without mandatory referral to CRCL.
Existing Framework
CBIC had earlier issued several instructions governing laboratory testing and sample examination, including:
- Circular No. 43/2017-Customs dated 16.11.2017
- Circular No. 11/2018-Customs dated 17.05.2018
- Circular No. 46/2020-Customs dated 15.10.2020
These circulars identify categories of goods that cannot be tested by CRCL and prescribe procedures for forwarding samples to other accredited laboratories functioning under various Ministries, Departments, and recognized agencies.
Why This Clarification Matters
Many export markets require product testing and certification to comply with:
- Technical regulations
- Product standards
- Sanitary and phytosanitary requirements
- Quality certification norms
- Country-specific import regulations
As a result, exporters routinely obtain test reports from:
- NABL-accredited laboratories
- Laboratories recognized by Export Promotion Councils (EPCs)
- Other approved certification agencies
However, despite such reports being available, some export consignments continued to face additional laboratory referrals, leading to avoidable delays.
Key Clarification Issued by CBIC
CBIC has now clarified that exporters may continue to obtain test reports from:
- NABL-accredited laboratories
- Laboratories recognized by Export Promotion Councils (EPCs)
- Other recognized agencies
for meeting regulatory requirements of the importing country.
Where such reports are submitted and there is no risk-based intervention, intelligence input, or specific suspicion regarding the export consignment, the proper officer should consider these reports and need not mandatorily send samples to CRCL for testing.
Situations Where Existing Testing Procedures Will Continue
The relaxation does not apply in cases involving:
- Risk-based examination
- Intelligence-driven interventions
- Suspected misdeclaration
- Compliance verification requiring independent testing
In such situations, customs authorities may continue to follow the existing procedure, including referral of samples to CRCL or other accredited laboratories as prescribed.
No Change for Import Consignments
CBIC has specifically clarified that this relaxation applies only to export consignments.
The existing procedure for drawing and testing samples of imported goods remains unchanged. Import samples will continue to be referred to CRCL or other designated laboratories in accordance with prevailing customs instructions.
Impact on Exporters
The clarification is expected to:
- Reduce export clearance delays
- Eliminate duplicate testing in genuine cases
- Lower compliance costs
- Improve ease of doing business
- Facilitate faster shipment processing
- Provide greater certainty to exporters complying with foreign regulatory requirements
Preface Consulting's Perspective
This clarification reflects CBIC’s effort to streamline export procedures while maintaining risk-based customs controls. Exporters that routinely obtain testing and certification from NABL-accredited laboratories can benefit from faster customs processing where no compliance concerns exist.
Businesses should nevertheless maintain complete testing documentation, ensure laboratory accreditation validity, and retain supporting records to facilitate smooth customs examination whenever required.
Organizations engaged in international trade should review their export compliance procedures to ensure that laboratory certifications, product standards documentation, and destination-country regulatory requirements are properly aligned with customs expectations.