19 Nov 2025
India has added a new Category 7 to the SCOMET list, bringing advanced semiconductors, quantum technologies, cryogenic systems, and related software and know-how under export-control licensing from 23 October 2025. Exporters must assess classification impacts, update compliance processes, and adjust contracts to manage licensing and ensure alignment with the export control regime.
Partner: Samsuddha Majumder, Senior Associate: Pranjal Srivastava
The SCOMET (Special Chemicals, Organisms, Materials, Equipment and Technologies) list governs the export of dual-use items, including goods, software and technologies, that can have both civil and military applications. These items or technologies are regulated and require an export authorisation (license) to ensure they are not diverted for unauthorised use. The list aligns with India’s obligations under multilateral export control regimes and its national export-control policy to prevent proliferation and misuse of the identified dual-use items and comprises eight categories.
The Directorate General of Foreign Trade (DGFT) regularly updates this list to reflect technological advancements. Recently, the list was updated to include, among others, ‘Category 7: Certain Emerging Technologies and related items’ which had so far been a reserved category and not provided for in the SCOMET list.1 The implications of this inclusion are outlined below.
The DGFT Notification of 23 September 2025 (Notification) seeks to introduce controls on specific emerging technologies, with a focus on:
Category 7, like other categories on the SCOMET list, is further divided into five sub-categories (7A to 7E), as follows:
| S. No. | Sub-Category | Scope | Items |
|---|---|---|---|
| 1. | Systems, Equipment and Components (7A) | These are advanced computing and quantum-related systems |
|
| 2. | Test, Inspection and Production Equipment (7B) | Covers semiconductor manufacturing, lithography, additive manufacturing, and testing tools |
|
| 3. | Materials (7C) | Special isotopically pure or advanced semiconductor materials |
|
| 4. | Software (7D) | Specialised software for semiconductor and quantum technology |
|
| 5. | Technology (7E) | Know-how, design kits, and process technology |
|
India’s decision to apply export controls to Category 7 follows a growing international trend to regulate emerging and dual-use technologies. Notable international developments include:
Other advanced economies including Switzerland and United Kingdom have also expanded dual-use controls on quantum computing, semiconductors and additive manufacturing devices, associated equipment, software and technology.
The revised SCOMET list, which includes Category 7, became effective from 23 October 2025. Industry stakeholders must promptly assess whether their current exports fall within this category. For covered exports, stakeholders should initiate the process of flagging and updating their internal compliance mechanisms to facilitate timely application for an export licence to avoid any disruption to ongoing export activities.
Going forward, suppliers should also consider including export-control related clauses in their customer/supplier contracts to help establish the non-applicability of Category 7 to exports. For instance, clauses to exclude specific end uses may be helpful. In cases where the exports are covered under SCOMET, an exception in the performance of the contract on account of delay in issuance of licence by the relevant authorities should also be carved out.
[1] Notification No. 31/2025-26, dated 23 September 2025
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