Examine how the Department of Commerce and the Department of Revenue coordinate in implementing India's trade agreements. Suggest institutional reforms.

The Department of Commerce negotiates India's trade agreements, but the Department of Revenue (CBIC) applies them at the border. The India–UK CETA came into force on 15 July 2026 [3]. Within four months it ran into a classification dispute over bulk Scotch whisky [1]. The case shows that a concession is worth only as much as its customs administration.

How the two Departments coordinate

• Division of roles: Commerce negotiates the tariff schedules. Revenue notifies the concessional rates and applies them through the Customs Tariff.
• Commitments tied to HS lines: Annex 2A lists each concession by HS tariff line, with a staging category for the duty cuts [2]. Customs must reflect each line exactly.
• Origin checks: CETA certificates of origin are issued digitally through eCoO 2.0 on a self-certification basis [3]. This puts more of the checking on customs at the port.
• Facilitation: faceless, paperless clearance is now the default way customs works [4].

Gaps exposed

• Classification mismatch: bulk Scotch could fall under Heading 2208 (spirits) or the residual Heading 2106 (food preparations n.e.s.). The three possible lines carry "very different" duties, so the promised cut from 150% to 75% could be lost [1].
• Reactive fixing: Revenue began working with stakeholders on the issue only after entry into force [1].
• Layered levies: Budget 2025–26 removed the 150% basic customs duty slab [5]. Headline rates are now made up of several levies, which makes them harder to match against FTA schedules.
• Dispute risk: in DS360, the US challenged India's extra duties on alcohol at the WTO [6]. Unclear duty structures invite this kind of challenge.

Institutional reforms

• Pre-entry concordance audit: a joint Commerce–CBIC cell should map every scheduled line to 8-digit tariff codes before a deal comes into force [2].
• Binding circulars for sensitive lines, issued on day one, naming the applicable rate and staging category.
• FTA implementation committee with time-bound redress of importer complaints.
• Integrated digital platform linking eCoO origin data with customs clearance [3].
• Apply the lessons to ongoing negotiations, such as the EU deal, where spirits are sensitive.

Commerce and Revenue do coordinate, but mostly after problems arise. India has assured that it will honour the Scotch concessions [1]. Turning that assurance into a standing, rules-based link between the two Departments would make India a more credible FTA partner. It would also support SDG 17's goal of open, rules-based trade.