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  Manufacturing in Bond Rules 1997

     

Until 1997, there were three kinds of Customs Manufacturing Bonds in operation which envisaged duty-free import of raw materials and accessories into bond for production of goods for exports. SRO-68(I)/70 dated 17.4.70 provided for a manufacturing bond partially for exports;
SRO-69(I)/70 dated 17.4.70 provided for manufacturing bond mainly for exports; and SRO-722(I)/89 dated 10.7.89 was the Open Bond Scheme for duty-free and tax-free import of all imported inputs.  In all the three kinds of bonds, duty drawbacks were allowed on the use of duty paid imported inputs for export production. On6th November 1997, the new Manufacturing in Bond Rules 1997 were notified as SRO-1140(I)/97 dated 6.11.1997 (App: 6.1) was issued that merged the three kinds of bonds into one.  It was provided that any manufacturing bond already licensed under the previous regime was automatically converted into a manufacturing bond under SRO-1140/97, without the necessity of issuance of a new bond license.  The main provisions in the Manufacturing in Bond Rules are summarised below.    

Duty/Tax-free Clearance 

These rules apply to clearance of dutiable imported goods, excisable goods and goods/supplies chargeable to Sales Tax, without payment of Customs duty, Central Excise duty and Sales Tax, for the manufacture of goods primarily for exports. These input goods include raw materials, accessories, sub-components, components, sub-assemblies, assemblies, unrecorded media for development of software and recorded software used as tools for development of software.  

Bond License 

Any person wishing to operate a manufacturing bond has to be registered as an exporter and importer with the Export Promotion Bureau and under the Sales Tax Act 1990.  An application for bond license is made to the Collector of Customs in the prescribed form (App: 6.2), along with the following required documents: 

  • Site plan indicating location of the bond premises, total area, covered area and manufacturing area.
  • Details of machinery installed.
  • Export performance, if any, for the previous financial or calendar year.
  • National tax number or certificate.
  • Bank certificate for financial transactions in the last two years.
  • Memorandum and Articles of Association, partnership deed, if and as applicable.
  • Copies of National Identity Cards of owners and directors.
  • Lease/Tenancy agreement with written permission of landlord to use the premises as manufacturing bond.
  • Certificate from supplier of fire fighting equipment installed in the premises regarding its validity date.
  • Comprehensive insurance policy by a company registered with the Controller of Insurance, for the sum of
  • Customs Duties, Central Excise and Sales Tax for the goods intended to be stored in the bond.
  • An undertaking by an approved insurance company about intimation of any change in the insurance policy
  • to the Collector of Customs, payment of full insurance premium, declaration of stock.

Validity of Bond License 

The bond license is issued by the Collector of customs, after verification as necessary; within seven days of verification which itself will be done within seven days.  The license can be cancelled or suspended for violation of any conditions. The license is valid for three years and will be revalidated automatically for a further period of three years.  No fee or establishment charges are payable by the licensee for issuance, revival or revalidation of the license.  The license is not transferable.

Bond Premises 

The licensee should own the bond premises or have a lease in his name for the period of the license.  There should be a clearly marked area for storage of imported or locally procured input goods, an area for manufacturing and separate areas for storage of finished goods and rejects and waste.  The premises should be on an independent area, with independent entry or exit from a public area and having no other entry/exit on it.

Analysis Certificate 

The consumption of bonded materials for the manufacture of export goods is accounted for on the basis of an Analysis Certificate. (App: 6.3/Appendix II to SRO-1140/97) showing the input and output ratio of input goods including wastage. The Analysis Certificate is not required in every case if the finished goods are the same for which Analysis Certificate has been issued already.  A new Analysis Certificate is required for every new finished goods. For the issuance of Analysis Certificate, the Customs may retain a sample of complete finished product but, in case of expensive items like leather garments, a piece of leather or lining material, button, zipper or thread may be retained by the Customs instead of the complete product. 

Procurement of Input Goods 

The input goods for production of finished goods meant for export, according to the approved specification as per Analysis Certificate, are procured by the bond licensee in the following manner: 
Input goods may be imported without payment of Customs duty under an In-bond Bill of Entry, with the declaration that the input goods are imported into manufacturing bond for production of export goods.  A record of the duty-free imports is kept in the prescribed format (Appendix III to SRO-1140/97) and a copy is provided to the Customs verified by the Customs officer incharge of the bond.  The input goods removed are debited to the import record and the export goods produced are credited in the record of export goods.  Factory rejects and wastages are accounted for separately.
Input goods procured locally from an excisable unit are procured under AR-3 procedure without payment of Central Excise duty.  A record of these input goods is also maintained in the prescribed format (Appendix IV to SRO-1140/97) and a copy is provided to the Customs verified by the Customs officer incharge of the manufacturing bond. The input goods removed are debited to the record and the export goods are credited in the record of export goods.  Factory rejects and wastages are accounted for separately.
Input goods subject to Sales Tax are procured against a tax invoice after payment of Sales Tax.  A record of Sales Taxable input goods is kept in the prescribed format (Appendix V to SRO-1140/97).  While the drawback of Customs duty and Central Excise duty, where actually paid, is allowed according to standard drawback rates, the Sales Tax is refunded on exports through the Input/Output Sales Tax Return submitted to the Sales Tax Department after exports.

Admissibility of duty drawbacks 

In case duty-paid input goods are procured from the local market and used in the manufacture of finished goods, the amount of duty drawbacks, calculated on the standard drawback rates, is reduced by the proportionate duty amount on the quantity of such input imported goods that have been imported without duty and are listed as raw materials in the relevant standard drawback notification.  This has been further explained in the Customs General Order NO: 02/99 dated 19.2.99 (App: 6.4).  This CGO is applicable to input goods imported on and after 23.7.98 when the original Rule-13 of SRO-1140/97, about admissibility of duty drawbacks on exports, was amended by SRO-845(I)/98 dated 23.7.98.  It provides as follows: 
In case only duty-paid inputs are used, the drawbacks are admissible on the export of finished products according to the relevant standard drawback notification. In case only duty-free input goods are used, no duty drawback is admissible. In case the input goods used are partly duty-free and partly duty-paid procured from the local market, the amount of duty drawback is reduced proportionately by the amount of Customs Duty applicable at current rates, on the quantity of duty-free input goods used out of the items listed in the raw materials column of the relevant standard duty drawback notification.

Bond to Bond Transfer 

Bond to bond transfer of input goods is allowed by the Customs on application in the prescribed form (App: 6.5/Appendix VI to SRO-1140/97). The Customs may also allow transfer of input goods for getting these processed in another bond or in the Export Processing Zone, against an Indemnity Bond(App:6.6/Appendix VII to SRO-1140/97) equal to applicable Customs duty, Central Excise duty and  Sales Tax involved.  Input goods can also be sold by one bond licensee to another, but within the validity period of the license and subject to consumption within the validity period.

Manufacture and export of Finished Goods 

The bond licensee has to maintain a record of the finished goods manufactured, in the prescribed form (Appendix VIII to SRO-1140/97), and provide a copy as a quarterly return to the Customs verified by the Customs officer incharge of the bond.
The licensee also has to keep a record of the goods exported, in the prescribed form (Appendix XI to SRO-1140/97) and provide a copy in the form of a monthly return to the Customs verified by the Customs officer incharge of the bond.
Export is made against a Bill of Export which should be endorsed as “Export of Manufacturing Bond”.  At the option of the licensee, the export goods may be examined at the exit port or in the manufacturing bond.

Clearance for Home Consumption 

Removal of finished goods for home consumption, on Bill of Entry, is allowed up to 40% of the annual production of the manufacturing bond; in case of engineering goods and leather footwear upto 75% in the first three years and 40% in subsequent years.
Removal for home consumption is subject to the provisions of the current Import Policy and on payment of applicable duties and taxes, on the sum total of the value of input goods
The licensee may remove input goods or semi-finished goods from the bond premises for partial manufacture or processing or packing by the vendors, and return to the bond, subject to intimation to the Customs in the prescribed form (Appendix X to SRO-1140/97). If the vendor is located near the Customs port of exit, the finished goods may be removed from the vendor directly to the Customs port of exit for export.

Re-export of Imported Input Goods 

Re-export of imported input goods, in their original and unprocessed form, is allowed within three years of their import subject to the current Import and Export Regulations.  Application for re-export is made in the prescribed form (Appendix XI to SRO-1140/97).

Retention Period of Input Goods 

The input goods imported or procured locally should be consumed within a maximum period of five years. The period can be extended by CBR in deserving cases. There is no surcharge on over-stayed goods.

Wastages 

Wastages of input goods in terms of quantity, volume, weight or number are allowed only as determined in the Analysis Certificate and no duties and taxes are charged on such wastages of the input goods.  Such wastages are to be destroyed in the presence of a Customs officer not below the rank of Assistant Collector or the applicable duties and taxes are paid on such wastages before removal.  Destruction of wastages is applied for in the prescribed form (Appendix XII to SRO-1140/97).

Factory Rejects 

The factory rejects or goods not upto export standards are allowed disposal in the local market subject to the current import regulations, on a Bill of Entry for home consumption and on payment of duties and taxes on the appraised value as if the goods had been imported into Pakistan in that condition.

Unaccounted Input Goods

If the input goods or finished goods are not properly accounted for, the bond licensee has to pay the duties and taxes as if they were imported and used for home consumption besides penalties under the relevant Acts. The duties and taxes can be remitted fully or in part in the cases when the goods are damaged or destroyed for causes beyond the control of the licensee or when the wastage of the goods is destroyed or when the goods are bonafide samples.


 
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