Episode 12: Export Controls, SCOMET and US Re-Export Rules for Indian Exporters
Former VP & Head of Import Export and Customs - Siemens
Dr. Pramod Sant is a seasoned international trade, customs, and supply chain leader with more than four decades of experience across logistics, import-export operations, export controls, and regulatory compliance. He currently serves as Director General of the Federation of Freight Forwarders’ Associations in India (FFFAI) and previously spent over 32 years at Siemens, rising to Vice President and Head of Import, Export, and Customs. A certified independent director, he actively shares expertise on Indian customs valuation, HS classification, BIS compliance, and trade policy, helping businesses strengthen compliance and streamline cross-border operations.
Dr. Pramod Sant spent more than 32 years at Siemens, rising to Head of Import, Export and Customs, and is now Director General of the Federation of Freight Forwarders' Associations in India. He discusses how sanctions keep changing shape, why Indian exporters must follow US re-export rules alongside SCOMET, what a mid-size exporter should invest in, where importers get penalized, how trade compliance shapes company strategy, and why AI answers still need checking.
5 Key Findings
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Sanctions change form but never leave
Dr. Sant has watched export controls since the 1998 US sanctions on Indian companies, through the JCPOA, Russia and the Middle East conflicts. Restrictions shift with geopolitics and technology, so compliance teams must keep learning.
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US content keeps its US controls in India
Goods made in an Indian industrial estate with US technology or encryption can still need a US re-export license. Exporters must check SCOMET and the US Commerce Control List, and, depending on content, European, Japanese and now Chinese rules.
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Read the end-user declarations you sign
Indian importers of technology often sign supplier declarations promising to follow US re-export rules as a routine formality. Many do not realize those promises bind them when the goods or products built from them are exported.
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Importers fail on the three customs pillars
Most penalties trace back to classification, valuation and origin, followed by poor documentation. A shipment held two or three days at origin for correct papers costs less than ten days stuck in a customs query.
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Trade compliance shapes business strategy
The function can steer sourcing toward lower-duty FTA partners, help choose factory sites, and weigh SEZ, EOU or FTWZ options. It can also choose between EPCG, Advance Authorisation, drawback and RoDTEP to improve the bottom line.
Advice to the Professional
From Dr. Pramod Sant
Even a company with a turnover of ₹100 to 200 crore should have one person who understands international trade end to end: export controls, customs, logistics and free trade agreements. Treat that hire as an investment. Use help from government guidance and associations such as FICCI, and admit openly when you do not know something.
Explain rules simply instead of guarding knowledge. Young professionals can learn through courses, conferences and trade publications. Use AI to build alerts for classification queries, value changes and FTA duty phasing, but read the law yourself before acting on any answer.
Conclusion
Dr. Sant sees trade compliance as a function that touches every department and adds to profit. With growing exports and new FTAs, Indian companies that invest in compliance knowledge will be better placed in global value chains.