A defining feature of the Trade Regulations, Accreditation & Compliance Enablement (TRACE) scheme is the use of a pre-notified Positive List of certifications. This list determines which testing, inspection, and certification activities are eligible for reimbursement, making it a central compliance filter under the scheme.
This article explains the structure, scope, sectoral spread, and policy role of the Positive List, strictly based on the notified guidelines.
Purpose of the Positive List Under TRACE
TRACE does not permit open-ended reimbursement of compliance costs. Instead, eligibility is anchored to a Positive List to ensure that support is:
Targeted to genuine regulatory requirements
Aligned with internationally recognised standards
Free from subjective or discretionary interpretation
Only certifications appearing in the Positive List are eligible for reimbursement.
Nature of Certifications Included
The Positive List covers certifications that are:
Mandated by importing-country regulations, or
Necessary to demonstrate compliance with internationally recognised standards
These certifications typically relate to:
Product safety
Quality management
Technical conformity
Health and sanitary requirements
Environmental and sustainability standards
The list reflects regulatory necessity, not commercial preference.
Sectoral Coverage of the Positive List
The Positive List is sector-neutral in design, but sector-specific in content. It spans a wide range of export sectors, including:
Food and Agriculture
Food safety certifications
Sanitary and phytosanitary compliance
Agricultural and aquaculture standards
Ethical and sustainability certifications
Electronics and Electrical Products
Product safety and conformity certifications
Electromagnetic and technical compliance
Electrical and electronic equipment standards
Medical Devices and Pharmaceuticals
Regulatory approvals for overseas markets
Safety, quality, and performance certifications
Chemicals, Textiles and Consumer Goods
Chemical safety and restriction compliance
Product safety and consumer protection standards
This broad coverage reflects the diversity of India’s export basket.
Geographic Spread of Certifications
The Positive List includes certifications required by or recognised in:
Major export markets such as:
United States
European Union
Japan
Middle East
Global standards-setting bodies and certification regimes
This ensures relevance across multiple jurisdictions and trade destinations.
Cost Characteristics of Positive List Certifications
Certifications included in the Positive List often involve:
High upfront testing and audit costs
Engagement with accredited international agencies
Periodic inspections and compliance checks
Indicative costs are provided in the annexure to facilitate planning, but reimbursement remains subject to notified ceilings and percentage limits.
Relationship With Reimbursement Rates
Certifications appearing in the Positive List are eligible for:
Reimbursement up to 60% of the actual cost
Cost considered net of applicable taxes
Subject to the lower of actual cost or notified ceiling
The Positive List represents the standard reimbursement tier under TRACE.
Mandatory Nature of List Inclusion
Even if a certification is:
Mandatory in an export market, or
Commercially critical for exports
It is not eligible under TRACE unless it appears in the notified Positive List or Priority Positive List.
List inclusion is therefore a non-negotiable eligibility condition.
Dynamic and Review-Based Structure
The Positive List is dynamic, not static. It may be:
Expanded to include new certifications
Revised to reflect regulatory changes
Pruned to remove obsolete or low-impact certifications
Revisions are based on:
Stakeholder consultations
Monitoring of international standards
Recommendations of the designated Sub-Committee
All changes apply prospectively.
Role of the Sub-Committee in the Positive List
The Sub-Committee on Export Quality and Technical Compliances plays a key role by recommending:
Inclusion of new certifications
Deletion or modification of existing entries
Sectoral prioritisation based on compliance intensity
DGFT notifies changes based on these recommendations.
What the Positive List Does Not Cover
The Positive List does not include:
Marketing or branding certifications
Consultancy or advisory services
Non-compliance-related audits
Certifications undertaken purely for commercial differentiation
TRACE support is confined strictly to regulatory and compliance-driven certifications.
Compliance Planning Significance for Exporters
For MSMEs, the Positive List serves as:
A planning tool for compliance expenditure
A filter to assess reimbursement eligibility
A guide to prioritise certifications within financial year limits
Exporters should always verify the latest notified list before incurring costs.
Conclusion
The Positive List of certifications is the cornerstone of TRACE’s eligibility framework. By restricting reimbursement to notified, internationally relevant compliance requirements, TRACE ensures that public funds are channelled toward legitimate market-access and regulatory obligations.
For MSMEs, understanding the scope and structure of the Positive List is essential to effective compliance planning, as TRACE does not permit reimbursement for certifications outside the notified framework.
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