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Short answer: CBIC has circulated a draft — the Draft Warehousing Operations Regulations, 2026 — for public comment under letter F. No. 473/12/2026-LC dated 21 September 2026. Two of its definitions are hardware sentences: "electronic records" means records kept through a digital warehouse management system, and a "one-time-lock" may be mechanical or electronic, with an electronic seal where so specified by the Board. Nothing in the draft mandates RFID, but if you hold a section 57 or 58 licence, those two lines are yours to cost.
Status as on 25 September 2026: this is a draft out for consultation. It is not notified and not in force. The letter invites comments within 15 days of issuance — approximately 6 October 2026, computed from that 15-day window and not a gazetted deadline. As on 25 September 2026 that window is still open. This post will be updated if and when final regulations are notified.
What did CBIC circulate on 21 September 2026, and when do comments close?
CBIC letter F. No. 473/12/2026-LC, dated 21 September 2026, directs that the Draft Warehousing Operations Regulations, 2026 be uploaded for public consultation. The letter invites comments within 15 days of issuance, which computes to approximately 6 October 2026 — a calculated date, not a gazetted one — and as on 25 September 2026 that window is still open. Comments are accepted by email at the addresses specified in the notification. Nothing in the draft is enforceable today.
Who does it apply to, and who does it leave out?
The draft covers warehouses licensed under sections 57 and 58 of the Customs Act — public and private bonded warehouses. Warehouses permitted to carry out a manufacturing process or other operations under section 65 are excluded from its scope. So a unit manufacturing in bond is not the audience. A 3PL operating bonded space, or an importer holding duty-deferred stock, is.
It is framed around sections 57, 58, 59, 60, 61, 64, 67, 68, 69, 72 and sub-section (2) of section 73A. Read as an operations document, it describes a stock ledger you have to be able to produce and defend on demand.
Which two lines in the draft describe hardware?
The legal summaries cover the procedure. The definitions decide your purchase order. The draft defines a one-time-lock as a "locking device, whether mechanical or electronic, used for securing goods during transport", and brings in an electronic seal where the Board so specifies. It defines electronic records as "records maintained through a digital warehouse management system". In practice that ledger has to carry receipt, storage, transfer, removal and balance — that framing is ours, not the draft's wording. Both definitions are as reported by TaxGuru on 23 September 2026; the draft text published by CBIC governs, so read it before you comment.
What does "electronic records through a digital warehouse management system" mean on the floor?
Bonded accountal is stricter than commercial accountal in one way. In practice it turns on being able to tie stock back to the bill of entry it was warehoused against and to where it physically sits. A WMS holds those fields; the gap is rarely the software but the accuracy of the event that populates it.
A UHF label applied at receipt and bound to the bill of entry turns "which cartons came in under this BoE" into a query rather than an investigation. Pallet tags turn location changes into reads. Where stock sits in steel cages or racking, on-metal tags survive the detuning that kills an ordinary adhesive inlay. Specify readers for the Indian UHF band rather than importing a US-band unit by accident — our WPC, ETA and BIS certification guide covers the band and the approvals.
| Accountal event | Register practice | What a physical read changes |
|---|---|---|
| Receipt into bond | Manual count against the bill of entry | Every carton and pallet bound to the BoE at the gate |
| Storage and location | Bin card, updated when someone remembers | Captured as an event, not a memory |
| Transfer under section 67 | Documented quantity; contents assumed | Read manifest of what left, plus the lock event |
| Balance on hand | Periodic full count, usually a shutdown | Cycle counts while receipts continue |
General tagging and cycle-count mechanics are in our RFID warehouse inventory management guide.
How do Forms WH-1 and WH-2 change the monthly count?
The draft provides for two returns. Form WH-1 covers the complete monthly warehouse activity. Form WH-2 carries the bills of entry whose warehousing period expires the following month. Both are submitted electronically through the Common Customs Electronic Portal.
WH-2 is the forward-looking one. It forces you to know, every month, which bonded lots are about to age out — then to find those cartons. In a register-driven warehouse that is a hunt. In a tagged warehouse it is a filtered read: query the bills of entry on the WH-2 list, walk the aisles with a handheld, confirm location.
WH-1 is the reconciliation, and a monthly return is only as good as the count behind it. Assembled from read events already in the system, the close becomes an export rather than a reconstruction.
Section 67 transfers: mechanical seal, electronic seal or RFID lock?
The draft covers inter-warehouse transfers under section 67, and electronic submission through the Common Customs Electronic Portal is mandatory across the regulations. Separately, it defines the one-time-lock used to secure goods during transport — and that definition permits mechanical or electronic, with an electronic seal "where so specified by the Board". That clause is the honest limit: an electronic seal is not blanket-compulsory for every move.
| Option | What it evidences | Honest limitation |
|---|---|---|
| Mechanical bolt or cable seal | Seal number matches the document; seal intact on arrival | No time, location or tamper trail; a swapped seal relies on human comparison |
| Electronic seal or RFID lock | Seal identity read without transcription; timestamped lock and unlock events | Evidences the door, not the goods; contents still need a read manifest |
| RFID lock plus a tagged load | Seal event and a read-level manifest at both bonded gates | Needs a reader at each end and real tag discipline |
If transfers run onward to a port or ICD, note the split: our post on RFID e-seals for export containers covers export-container e-seals at ports and ICDs; this one is the warehouse side of the gate. Transit lock hardware is specified case by case rather than picked off a shelf — tell us your transfer volume and route and we will come back with an option.
What can an officer verify in an hour under risk-based scrutiny?
The draft provides for risk-based scrutiny and verification by officers. What that looks like on your floor is the part worth preparing for. With a register, verification is a sampling exercise: pick a bill of entry, ask for the cartons, and wait.
With tagged stock and a Bluetooth sled reader the hour looks different. Pick a bonded lot and see it read in place; sweep a zone and compare the read list against the system balance in front of everyone. That does not make you compliant — it makes your claim checkable, which is the difference between a short visit and a long one. Devices sit in our RFID handheld readers range.
What does a realistic bonded-warehouse layout look like?
Four installation points cover the lifecycle the draft describes.
| Where | What goes there | What it produces for the record |
|---|---|---|
| Bonded entry and exit doors | Fixed or gate reader, antennas framing the opening | Receipt and removal events, bound to bill of entry and vehicle |
| Cartons, shippers, pallets | UHF inlays and labels; on-metal tags for cages and steel racking | The identity layer the system balance is computed from |
| Aisles and racks | UHF handheld or Bluetooth sled reader | Cycle counts, WH-2 expiry checks, officer-led verification |
| Transfer vehicles under section 67 | A one-time-lock: mechanical seal, electronic seal or RFID lock, read at both bonded gates | Lock and unlock evidence alongside the transfer declaration |
Tags come from our UHF RFID inlays and labels range; gate geometry and read-zone control are in the RFID gate and portal reader guide. Identium Tech Solutions supplies and supports this hardware in India; instrument the gate and the transfer first.
What does RFID not do for a bonded warehouse?
- It does not file WH-1 or WH-2 — those remain your submissions through the Common Customs Electronic Portal.
- It does not create or validate a bond number, a bill of entry or a warehousing period.
- It does not substitute for electronic submission: a read history that never reaches the portal is not a filed return.
- It does not make a seal legally sufficient: the draft permits mechanical or electronic, with an electronic seal only where the Board so specifies.
- It does not fix a bad process: if receipts are recorded a day late, tags record them a day late, faster. No technology makes anyone compliant by itself.
What should you do during the consultation window?
- Read both definitions against what you run today; usually the gap is event capture, not software.
- Ask your WMS vendor one narrow question: can it export the WH-1 activity and the WH-2 expiry list without manual assembly?
- Check your section 67 sealing practice. If the one-time-lock definition would change your transfer process, that is what a comment is for.
- Comment before the window closes — approximately 6 October 2026, by email at the addresses specified in the notification.
- Budget, do not buy — our RFID project cost and ROI guide covers how to scope a gate reader, a tag specification and a handheld count, so a number is ready if final regulations are notified.
This is an operations-planning summary of a draft regulation, not legal advice. Verify the text, scope and timelines with the official CBIC source before you act.
Bring us your floor plan, not a spec sheet. Tell India RFID Store how many bonded doors you have, what your cartons and pallets are made of, and how many section 67 transfers you run monthly. We will come back with a tag, reader and lock specification, plus volume pricing — start at bulk RFID pricing for India.
Frequently asked questions
Is the Warehousing Operations Regulations, 2026 in force?
No. As on 25 September 2026 it is a draft circulated for public consultation under CBIC letter F. No. 473/12/2026-LC dated 21 September 2026. The letter invites comments within 15 days of issuance — approximately 6 October 2026 — so the window is still open, and nothing in the draft is enforceable until final regulations are notified.
Does CBIC require an electronic seal on inter-warehouse transfers?
Not as a blanket rule in this draft. It defines a one-time-lock as a locking device "whether mechanical or electronic", with an electronic seal "where so specified by the Board". An electronic seal or RFID lock is permitted, but not compulsory for every section 67 move.
Are MOOWR units under section 65 covered?
No. The draft covers warehouses licensed under sections 57 and 58, and excludes warehouses permitted to carry out a manufacturing process or other operations under section 65.
What are Forms WH-1 and WH-2?
WH-1 is the return covering the complete monthly warehouse activity. WH-2 carries the bills of entry whose warehousing period expires the following month. Both are submitted electronically through the Common Customs Electronic Portal.
Does the draft mandate RFID in a bonded warehouse?
No. It requires electronic records maintained through a digital warehouse management system and permits a mechanical or electronic transit lock. It names no technology and no vendor. RFID is one practical way to generate accurate receipt, transfer and removal events.
Which RFID frequency should an Indian bonded warehouse specify?
UHF at 865-867 MHz, the band allotted for RFID in India under WPC. Specify tags and readers for that band rather than US-band equipment, and confirm the approvals for any reader you deploy.
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