What is RCMC?
A Registration Cum Membership Certificate (RCMC) is a certificate issued by the Federation of Indian Export Organizations (FIEO) and/or one of the various Export Promotion Councils (EPC) or Commodity Boards – primarily agencies and organizations that work towards the promotion and development of export businesses and are authorized to do so by the Government of India. It is a membership certificate issued for five years and signifies that the holder of the certificate is registered with FIEO/the concerned EPC or Commodity Board. Some of the popular EPCs include apeda, sepc, gjepc, tea board, eepc, and spices board. The applicant of the RCMC has to declare his or her primary line of business while applying for it, and possession of an RCMC entails an exporter to all the benefits and advantages of the respective parent organization.
Why is RCMC required?
As an exporter, you have to apply for an RCMC certificate if you are,
Seeking authorization to export (or import) any restricted item
Planning to claim various benefits under the Foreign Trade Policy
Looking for benefits offered by the Customs and Central excise authorities
Note that an RCMC is applicable even when you plan to export two or more products that fall under different categories and hence different EPCs.
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How to Apply for RCMC?
To apply for an RCMC certificate, you have to submit the duly filled application form ANF 2C to the EPC that pertains to your export product. For example, if you are a tea exporter, you will apply to the Tea Board, while if you are a readymade garments exporter, you will apply to the Apparel Export Promotion Council (AEPC). Broadly, there are two categories of exporters - merchant and manufacturer. To register as a manufacturing exporter, you have to provide proof of your existing manufacturing facility.
This is the general format of the ANF 2C form:
The information required in the form is quite simple:
You have to address the application to the concerned EPC and provide the name, registered address, branch and factory addresses (if any) of your business.
You have to mention your IEC Code and its details, details of your manufacturing unit like industrial license, factory registration, etc. Link with article titled: How to obtain an IE Code
You will also need your Export House/Trading House/Star Trading House/Super Star Trading House, etc. certificate number and your export status holder certificate number.
You will have to mention the product(s) for which the registration is sought and declare your main line of business.
To find out which EPC/Commodity Board/Authority your product falls under, you can refer to the updated Annexure 2T of the DGFT, which has the list of the EPCs/Boards/Authorities along with their contact details and details of products falling under their jurisdiction. At present, there are 37 such export promotion councils. However, it is possible that the product you choose to export doesn’t fall under a specific existing EPC. In such a case, you have to apply directly to FIEO. In cases where you have multiple products or your stream of business is not yet decided, FIEO can issue the RCMC under its multi-product group category. However, you also have to additionally register with the respective EPCs declaring your lines of business.
For example, APEDA provides facility for exporters to apply online for its RCMC as a part of Ease of doing Business initiative. Members can go on its home page, and click on "Register as Member", fill up a form and submit their documents. APEDA will verify their details and issue the certificate, which the exporter can then download from its website.
Documents required for RCMC
First and foremost, you have to submit the duly-filled and signed RCMC application form ANF 2C. Apart from the form, you have to furnish self-certified copies of the following documents,
IEC Number issued against the applying export entity.
Articles and Memorandum of Association (For Corporate/institutional/Private Limited/ Limited company), Partnership Deed (in case of Partnership firms and LLPs), or Trust Deed (in case of Trusts).
In the case of a company, the certificate issued by the Registrar of Companies regarding registered office change is needed.
GST registration certificate.
In the case of a service exporter already in business, three years’ services export data certified by the exporter’s Chartered Accountant has to be provided. Proof of payment of membership fee to the Services Export Promotion Council (SEPC) also has to be provided.
In case the name of the signing authority does not appear in the IEC/MOA/Partnership Deed/Trust Deed, etc., a self-certified copy of the Board Resolution or Power of Attorney issued in favor of the signing authority has to be provided.
Other key things to remember
You will have to intimate your RCMC registering authority of any changes made in name, address, ownership or constitution within a month of such change.
As an exporter, you will be required to furnish quarterly returns providing the details of your exports to your registering authority.
In case of violation of the terms and conditions of registration, the registering authority can deregister your RCMC for a particular period. In all such cases, the authority serves a show-cause notice and provides a reasonable opportunity to the RCMC holder for explanations and rectifying the violation before proceeding with the deregistration process.
If you are aggrieved with the registering authority’s decision, you can go to the DGFT and the decision of the appellate authority is considered final.
An RCMC certificate is valid from the 1st of April of the year in which it is issued and remains so for five years, ending on 31st March of the fifth year.
Tips for new Importers & Exporters
EPCs have to fulfil specific criteria to become eligible as a Registering Authority. Check if your EPC meets these criteria.
To apply online, you will need a system with Windows 7 Professional or above as an operating system and the equivalent of Internet Explorer 11 or above as web browser.
EPCs may insist on a hard copy of documents uploaded, which then need to be sent to the nearest branch of the EPC.
Get well versed with RCMC terms and conditions; the penalty for violation is de-registration.
All exporters based out of Odisha have to apply for a RCMC from the local FIEO office instead of the respective EPC.
In case of requirement of a Digital Signature Certificate for foreign trade purposes, procure the same from DGFT, as with other providers, your IEC will not be embedded in the certificate.