Is MOOWR Only for Big Companies or Can MSMEs Apply?

Is MOOWR only for big companies is a common concern among smaller importers, and the answer is no. MSMEs can apply for MOOWR on exactly the same terms as large corporations. The Manufacture and Other Operations in Warehouse Regulations, 2019 prescribe no minimum turnover, no minimum investment threshold, no employment condition and no locational restriction. Central Board of Indirect Taxes and Customs has itself described the scheme as MSME friendly for precisely these reasons.

Is MOOWR only for big companies is a question that comes up because the scheme is most visible in large manufacturing announcements. Visibility is not eligibility.

Is MOOWR Only for Big Companies: What the Regulations Say

Eligibility flows from the Customs Act, 1962, not from company size. Any person who holds a private bonded warehouse licence under Section 58 and obtains permission under Section 65 may carry out manufacturing and other operations in that warehouse. Anyone asking is MOOWR only for big companies will find no size test anywhere in Notification No. 69/2019-Customs (N.T.) or Circular No. 34/2019-Customs. Neither references turnover, paid up capital or MSME classification.

The practical eligibility test is therefore threefold.

• Premises: you must have a secure, demarcated facility that customs can license as a private bonded warehouse.
• Bond and security: you must execute a triple duty bond backed by a solvency certificate.
• Records: you must maintain a digital account of receipt, consumption and removal of goods.

A single proprietor running a 4,000 square foot unit in Navi Mumbai satisfies these conditions in the same way a listed manufacturer does. Registration formalities such as IEC are handled through the Directorate General of Foreign Trade portal, while customs filings run through ICEGATE.

What MOOWR Gives an MSME That Other Schemes Do Not

Duty deferment is the headline benefit. An MSME importing raw materials, components, consumables or capital goods into a MOOWR warehouse pays no Basic Customs Duty and no IGST at the time of import. Duty crystallises only when the goods, or the finished goods containing them, are cleared into the domestic market. If the finished goods are exported, the deferred duty on the imported inputs is never payable at all.

For a smaller business, this is not a marginal saving. It converts what would have been an upfront cash outflow at the port into working capital that stays in the business. There is no interest charge on the deferred amount and no time limit on how long goods may remain bonded, so an MSME with lumpy or seasonal demand is not penalised for holding stock.

Equally important is what MOOWR does not impose. There is no export obligation. EPCG requires an export obligation of six times the duties saved over six years. Advance Authorisation requires a minimum 15 percent value addition. MOOWR requires neither, which means a domestic market focused MSME can use it without taking on an export commitment it cannot realistically meet.

The Real Constraint for MSMEs Is the Solvency Certificate, Not Company Size

Is MOOWR only for big companies in practice, even if not in law? This is the fairer version of the question, and the honest answer lies in the bond.

This is the point most articles on the subject miss. The scheme does not cap eligibility by size, but it does cap the quantum of duty you may defer at any one time, and that cap is set by the solvency certificate furnished along with the triple duty bond.

The bond must cover the duty foregone on goods held in the warehouse. A solvency certificate for one crore rupees supports duty deferment up to that amount. If an MSME wishes to defer more, it furnishes an additional solvency certificate. The certificate is issued by a scheduled bank and reflects the applicant’s net worth.

So when someone asks is MOOWR only for big companies, the accurate reply is that entry is open to all, while the quantum of duty deferred scales with the security furnished. Planning the bond value against a realistic twelve month import projection is the single most useful thing a smaller applicant can do before filing Annexure A.

Compliance an MSME Must Budget For

The compliance load is lighter than EOU or SEZ, but it is not nil. A MOOWR unit is a bonded warehouse and is treated as one.

• Monthly returns. The form prescribed under Circular No. 34/2019-Customs must be filed with the jurisdictional Bond Officer by the tenth of the following month. These are monthly, not quarterly.
• Digital stock account. Receipt, consumption, waste and removal must be recorded in the format prescribed under Regulation 12.
• Physical security. A single entry and exit point, CCTV coverage and adequate lighting are expected at the licensing stage.
• Warehouse keeper. A person must be nominated and approved to be responsible for the warehouse.
• Bond maintenance. The bond must remain sufficient to cover duty on goods in the warehouse at all times.

An MSME should budget for a person, whether in house or outsourced, who owns this monthly cycle. Lapsed returns are the most common cause of trouble at a MOOWR unit.

One Amendment MSMEs Should Be Aware Of

Section 65A was inserted by the Finance Act, 2023. It provides that goods deposited in a warehouse for operations under Section 65 must, on deposit, be subjected to the integrated tax and compensation cess leviable under the Customs Tariff Act. The provision has not been brought into force by notification, and Basic Customs Duty deferment under Section 65 continues unaffected. Budget 2024 additionally empowered the Board to exclude specified goods or processes from the scheme.

Neither change targets MSMEs, and neither has altered the position on eligibility. Both are worth tracking, because they affect how the deferred IGST component of a business case should be modelled. An applicant building a five year cash flow on deferred IGST alone should treat that line as contingent.

Who Cannot Use MOOWR

Two exclusions matter. First, MOOWR is available to manufacturers and to entities carrying out permitted operations such as repacking, labelling, sorting, testing and repair. Pure service providers with no goods handling are outside its scope. Second, the premises must be capable of being licensed under Section 58. A shared or unsecured facility will not clear the licensing inspection.

Is MOOWR Only for Big Companies: The Real Filters

The filters that do exist have nothing to do with size. Is MOOWR only for big companies matters far less than whether your premises can be licensed under Section 58. If you compare frameworks before deciding, our note on MOOWR vs SEZ sets out where each is appropriate.

Frequently Asked Questions

Q1. Is MOOWR only for big companies?

No. Is MOOWR only for big companies is a common misconception. The Manufacture and Other Operations in Warehouse Regulations, 2019 prescribe no minimum turnover, no minimum investment and no locational restriction. MSMEs apply on identical terms.

Q2. Is there a minimum investment or turnover requirement under MOOWR?

No. The Manufacture and Other Operations in Warehouse Regulations, 2019 prescribe no minimum investment, no minimum turnover and no locational restriction. This is one of the reasons the scheme is described as MSME friendly.

Q3. Can a small proprietorship apply for MOOWR?

Yes. Any person holding a licence for a private bonded warehouse under Section 58 of the Customs Act, 1962 may seek permission under Section 65. Constitution of the business, whether proprietorship, partnership, LLP or company, is not a bar.

Q4. How much duty can an MSME defer under MOOWR?

The quantum is governed by the solvency certificate submitted with the triple duty bond. A solvency certificate of one crore rupees supports deferment up to that amount, and additional certificates may be furnished to raise the limit.

Q5. Does an MSME under MOOWR have to export?

No. MOOWR carries no export obligation. Finished goods may be cleared into the domestic market on payment of proportionate duty on the imported inputs contained in them, or exported, in which case the deferred duty is not payable.

Q6. Are MOOWR returns monthly or quarterly?

Monthly. The prescribed return must be filed with the jurisdictional Bond Officer by the tenth day of the month following the month to which it relates.

Related guides

• Start here: What is the MOOWR Scheme in Customs?
• MOOWR Implementation Challenges: What Companies Face (2026)
• Is MOOWR Useful if You Export Only a Small Portion? (2026)
• How to Apply for the MOOWR Scheme Online (2026 Guide)
• Can Traders (Non Manufacturers) Apply for MOOWR?

If you want this done without the back and forth, we provide MOOWR approval support.