CBIC Accepts Accredited Lab Reports for Export Samples, Cutting Duplicate CRCL Testing (Circular 28/2026)

The Central Board of Indirect Taxes and Customs (CBIC) has clarified, through Circular No. 28/2026-Customs (F. No. 401/24/2026-Cus.III, Customs Policy Wing), that for export consignments Customs officers may accept exporters' existing accredited laboratory test reports without mandatorily sending the sample to a Revenue (CRCL) laboratory, provided there is no risk-based intervention or intelligence involved. For exporters who already obtain destination-country compliance testing, this removes a recurring source of duplicate testing, delay and cost at the export gate.

What Happened

CBIC received representations that even when exporters held valid test reports from accredited laboratories, Customs procedure often still required samples to pass through Revenue Laboratories before clearance — resulting in duplicate testing of consignments that recognised accredited bodies had already certified. The Circular addresses this directly.

It clarifies that, for export consignments, exporters may continue to voluntarily obtain test reports from NABL-accredited laboratories, laboratories accredited or recognised by Export Promotion Councils (EPCs), or other recognised agencies, to meet the technical, sanitary/phytosanitary, product-standard and other requirements of the destination country. Where such a report is submitted for compliance purposes and there is no risk-based intervention or intelligence, the proper officer shall consider the accredited test report without mandatorily sending the sample to CRCL.

In effect, CBIC has extended a presumption of reliability to a defined set of accredited third-party laboratories in the absence of a specific risk signal — a shift from mandatory government re-verification toward conditional trust in recognised accreditation frameworks.

Why This Matters — Background

Export competitiveness is often decided less by tariff policy than by everyday procedural friction. For exporters on tight shipment schedules — especially in perishables, seasonal goods and time-sensitive contracts — every extra day in a testing queue is real commercial cost: missed vessel cut-offs, demurrage and lost competitiveness against faster jurisdictions.

The clarification builds on earlier CBIC circulars on testing outside CRCL — Circular 43/2017-Customs and Circular 11/2018-Customs (which identified items not testable at CRCL and alternative laboratories) and Circular 46/2020-Customs (guidelines for testing outside samples). Circular 28/2026 answers a more fundamental question: should exporters who already hold credible accredited testing for destination-country compliance face a second, duplicative round of government testing by default? The answer is no — subject to risk.

Who's Affected / Who Benefits

Exporters across agriculture and food products, chemicals, textiles, engineering goods and other sectors that routinely obtain accredited testing for destination markets stand to benefit most. CHAs and forwarders handling export clearances gain a faster, more predictable path. Revenue Laboratories should see reduced load from low-risk, already-certified export samples, freeing capacity for genuine risk cases.

Operational Detail — The Limits

The reform is deliberately bounded in two ways:

First, where risk-based intervention or intelligence is involved, the proper officer must continue to follow the existing procedure for withdrawal and testing of samples, including referral to CRCL or other accredited laboratories per extant instructions. The reform does not weaken enforcement where genuine risk indicators exist.

Second, the procedure for import consignments is unchanged. Import samples continue to be drawn and sent to CRCL or other accredited laboratories exactly as per current instructions. This is an export-side facilitation only.

On implementation, the Circular directs jurisdictional Principal Chief Commissioners, Chief Commissioners, Principal Commissioners and Commissioners of Customs to sensitise officers, and to issue suitable trade notices through field formations. Any implementation difficulties are to be reported to the Board.

What Exporters and CHAs Should Do Now

• Where you already obtain destination-country compliance testing, use NABL-accredited, EPC-recognised or other recognised laboratories so the report qualifies for acceptance.
• Submit the accredited test report clearly as part of the export documentation, flagged for compliance purposes, so the proper officer can consider it without a CRCL referral.
• Keep accreditation certificates and scope details ready in case the officer verifies the laboratory's recognised status.
• Understand that acceptance is not guaranteed in every case — if the consignment is picked for risk-based intervention or intelligence, CRCL testing can still apply.
• Watch for the trade notices your jurisdictional Customs formation is directed to issue, and align internal SOPs to them.

The Bigger Picture

Circular 28/2026 is a characteristic piece of trust-based, risk-calibrated trade facilitation: remove friction where credible third-party accreditation has already established reliability, while preserving full enforcement capability where risk warrants it. It complements India's broader push on faceless and technology-driven customs and its emphasis on reducing dwell time. The practical benefit, though, depends on consistent ground-level adoption — which is why the Board's instruction to sensitise officers and issue trade notices matters as much as the clarification itself.

Frequently Asked Questions

Does this mean my export samples will never go to CRCL? No. Where there is no risk-based intervention or intelligence, the accredited report should be accepted without a mandatory CRCL referral. If risk indicators are present, CRCL testing can still be required.

Which laboratories count? NABL-accredited laboratories, laboratories accredited or recognised by Export Promotion Councils, or other recognised agencies.

Does this change anything for imports? No. Import-sample drawal and testing procedures continue unchanged.

Is this automatic across all ports? The clarification applies nationally, but practical benefit depends on field-level implementation; CBIC has directed officers be sensitised and trade notices issued.

Conclusion

For exporters who already test to destination-country standards, Circular 28/2026 should mean fewer duplicate tests and faster clearance — provided the testing is done at recognised accredited laboratories and the consignment is not flagged for risk. Use qualifying labs, present the report clearly, and keep accreditation proof on hand.

This summary is for general guidance and does not guarantee exemption from CRCL testing in any specific case. Rely on the official text of Circular No. 28/2026-Customs and subsequent trade notices from your jurisdictional Customs formation, and consult a qualified customs professional for consignment-specific advice.