India Expands Export Controls with New SCOMET Category 7 for Emerging Technologies

Posted by Written by Archana Rao Reading Time: 4 minutes

India strengthens export-control rules with the addition of Category 7 to the SCOMET list, impacting semiconductor, quantum, and cryogenic technologies. Learn how exporters can meet the new regulatory obligations.


India has expanded its export-control framework by adding Category 7 to the Special Chemicals, Organisms, Materials, Equipment, and Technologies, or the SCOMET list, bringing advanced semiconductors, quantum technologies, cryogenic systems, and related software and know-how under a formal licensing regime.

The new rules took effect on October 23, 2025, requiring exporters to evaluate product classifications, strengthen internal compliance, and revise contractual arrangements to ensure alignment with India’s export-control obligations.

India updates the SCOMET list periodically to reflect new technologies and to maintain consistency with global export-control agreements.

Understanding the SCOMET framework

The SCOMET list regulates dual-use products, items that can serve commercial purposes but also carry potential military or strategic applications. Any export of such goods, software, or technology generally requires authorization from the Directorate General of Foreign Trade (DGFT).

The list currently contains eight categories, and Category 7 now broadens its reach into high-technology domains that were previously not covered.

India’s SCOMET List as of September 23, 2025

Product category

Description

Category 0

Nuclear materials, nuclear-related other materials, equipment and technology

  • 0A Prescribed substances (0A1 source material, 0A2 special fissionable material, 0A3 other materials)
  • 0B Prescribed equipment
  • 0C Technology

Category 1

Toxic chemical agents and other chemicals

  • 1A Prohibited chemicals, related technology and software
  • 1B Chemicals permitted only to states party to the Chemical Weapons Convention
  • 1C Chemicals permitted also to states not party to the Chemical Weapons Convention
  • 1D Other chemicals
  • 1E Other chemicals

Category 2

Micro-organisms, toxins

  • 2A Bacteria, related technology and software
  • 2B Fungi, related technology and software
  • 2C Parasites
  • 2D Viruses, related technology and software
  • 2E [*Reserved]
  • 2F Toxins, related technology and software
  • 2G Plant pathogens, related technology and software
  • 2H Genetic elements and genetically-modified organisms, related technology and software

Category 3

Materials, materials processing equipment and related technologies

  • 3A Materials (3A1 Special materials, 3A2 Structural materials, 3A3 Rocket propellants and constituent chemicals, 3A4 High explosives, 3A5 Stealth materials)
  • 3B Materials processing and production equipment, related technology, and specially designed components and accessories therefor.
  • 3C [*Reserved]
  • 3D Chemical and biomaterial manufacturing and handling equipment and related technology and software

Category 4

Nuclear-related other equipment and technology, not controlled under Category 0

  • 4A Equipment, assemblies, components including test and production equipment
  • 4B Equipment, assemblies, components including test and measurement equipment usable in development of nuclear explosive devices
  • 4C Technology

Category 5

Aerospace systems and equipment, including production and test equipment, related technology, and specially designed components and accessories, therefore.

  • 5A Rocket systems (5A1 Systems, 5A2 Production and test equipment, 5A3 Technology)
  • 5B Unmanned aerial vehicles
  • 5C Avionics and navigation systems
  • 5D [*Reserved]
  • 5E Micro-light aircraft and powered ‘hang-gliders’

Category 6

Munitions list

Category 7

Certain emerging technologies and related items

  • 7A Systems, Equipment and Components
  • 7B Test, Inspection and Production Equipment
  • 7C Materials
  •  7D Software
  • 7E Technology

Category 8

Special materials and related equipment, material processing, electronics, computers, telecommunications, information security, sensors and lasers, navigation and avionics, marine, aerospace and propulsion

Source: Updated SCOMET List 2025, DGFT

Please note that prior to the latest amendments to SCOMET’s list, category 7 remained under reserved status.

*Reserved status is temporary and intended to facilitate the future inclusion of items not yet detailed in the list.

Scope of the revised Category 7

The DGFT’s 23 September 2025 notification introduces export controls over a set of emerging technologies with increasing strategic relevance. Category 7 specifically addresses:

  • Advanced semiconductor devices and integrated circuits
  • Quantum components and quantum-based systems
  • Cryogenic and cryo-electronic technologies
  • Semiconductor fabrication, testing, and diagnostic equipment
  • Related software, technical data, and know-how

Similar to other SCOMET categories, Category 7 is organized into sub-sections (7A to 7E), covering equipment, materials, software, and technology.

Global context and policy alignment

India’s move reflects a broader global trend to regulate sensitive emerging technologies:

  • European Union (EU): The EU revised its dual-use list in 2025 to widen controls over quantum computing infrastructure, semiconductor-related equipment, and associated software and technology.
  • United States (US): Since 2023, the US has implemented a series of export-control measures on advanced computing, semiconductor manufacturing tools, high-end memory chips, and certain artificial intelligence (AI)-related technologies, using detailed performance thresholds and targeted end-use restrictions.
  • United Kingdom (UK) and Switzerland: Both countries have also increased oversight on exports relating to quantum computing, semiconductor technologies, additive manufacturing equipment, etc.

India’s Category 7 aligns its regulatory posture with these international developments.

Effective date and compliance roadmap

India’s SCOMET Category 7 has been in force since October 23, 2025, making prompt compliance a priority for exporters. Companies must ensure the following measures:

  1. Conduct a classification review to determine whether current or planned exports fall within Category 7.
  2. Update internal compliance systems, including screening procedures and documentation flows, to support timely license applications.
  3. Review and modify contracts to manage export-control risks. This may include:
  • Clauses confirming non-applicable end-uses
  • Exclusions for restricted or sensitive applications
  • Contractual provisions recognising delays caused by licensing processes

These proactive measures will help avoid disruptions to cross-border shipments and ensure business continuity.

Conclusion

India’s introduction of new items under Category 7 is expected to play a pivotal role in India’s export-control architecture. The expanded SCOMET list underscores the intent to balance technological advancement with national security priorities. For exporters, the shift demands a more rigorous approach to product classification, licensing, and contractual safeguards. Early compliance, supported by robust internal processes, will be essential to navigate the new requirements effectively and maintain uninterrupted access to international markets.

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