DGS Stakeholder Inputs on MMTG Act 1993 Reform AMTOI - Version 20-04-2026
Shantanu Bhadkamkar (via Google Docs)
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Shantanu Bhadkamkar
Dear Shantanu Sir,
Greetings!
Please find attached draft of version 3 of Stakeholder Inputs on MMTG Act 1993 Reform AMTOI to DGS shared by you on 20th April,2026 for your further modification.
Thanks and regards,
Neha Loke
Sr. Coordinator -AMTOI
From: Shantanu Bhadkamkar (via Google Docs) <drive-shar...@google.com>
Sent: 20 April 2026 11:23
To: in...@amtoi.org
Cc: am...@googlegroups.com; pres...@amtoi.org
Subject: DGS Stakeholder Inputs on MMTG Act 1993 Reform AMTOI - Version 20-04-2026
Shantanu Bhadkamkar attached a document
Shantanu Bhadkamkar (s...@atc.co.in) has attached the following document:
Please take note of the version 3 of Stakeholder Inputs on MMTG Act 1993 Reform AMTOI to DGS. This version amplifies response to Sr 6. Category: Legislative Cohesion (Sr 6 - Legislative Cohesion: Amendments to Schedule - Cargo Liability), and on page one emphasises on benefits of Conciliation as a non-adversarial means of dispute resolution.
DGS Stakeholder Inputs on MMTG Act 1993 Reform AMTOI - Version 20-04-2026
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Shankar Shinde
Thank you for your detailed update on the representation.
Just a suggestion — if feasible, we may also consider incorporating a provision relating to Imports under the MMTG Act:
“Any person or party endorsing carriage documents or issuing Delivery Orders in EXIM trade should be registered under the MMTG Act.”
This would also create an opportunity to protect and secure import transactions through Indian entities issuing Indian-registered Bills of Lading, where cargo liabilities are covered under our own B/Ls, instead of depending upon foreign forwarder entities issuing foreign B/Ls. This becomes particularly relevant in claim situations, especially in nomination shipments.
Such a provision could further encourage the issuance and acceptance of Indian B/Ls, thereby promoting and strengthening the presence of Indian entities in global trade and logistics.
Further, this may help bring imports and other stakeholders within a more structured and accountable framework under the MMTG Act, while also contributing towards expanding the professional ecosystem and membership base of AMTOI.
This is only a thought/suggestion, considering that the present representation provides a good opportunity to include imports and allied players within the overall system.
Shankar Shinde
+91 9321473101
+91 22 41708000
Managing Director (GEMPL) : Global Express Multilogistics Pvt. Ltd.
Chairman (IFCBA) : International Federation of Customs Broker Association
Vice Chairman (ICCTT) : International Coordinating Council on Trans-Eurasian Transportation
Vice Chairman (IMC) : Indian Maritime Centre
Vice President (MACCIA) : Maharashtra Chamber of Commerce, Industry & Agriculture.
Governing Council Board Member : Logistics Skill Council (LSC)
On 29 May 2026, at 8:27 AM, 'Shantanu Bhadkamkar' via AMTOI <am...@googlegroups.com> wrote:
Dear Colleagues,Please find attached version 4 of the DGS Stakeholder Inputs on the MMTG Act 1993 Reform for AMTOI. This updated draft is prepared for final submission to the Deputy Director General of Shipping (DGS), taking into account the discussions held during the 'Review of Stakeholder Inputs – MMTG Act 1993 Reform' VC Meeting onWednesday, 20 May, 13:00 – 14:00.I would appreciate it if you could review the document and provide any final feedback before we proceed with the formal submission.In the meantime, the Secretariat may prepare the letter for submission by email and as a printed, signed version.Thanks & regardsShantanu BhadkamkarATC Global Logistics Pvt. Ltd.
On Wed, 20 May 2026 at 16:28, Sr.Coordinator AMTOI - Neha Loke <sr.coor...@amtoi.org> wrote:
Dear Shantanu Sir,
Greetings!
Please find attached draft of version 3 of Stakeholder Inputs on MMTG Act 1993 Reform AMTOI to DGS shared by you on 20th April,2026 for your further modification.
Thanks and regards,
Neha Loke
Sr. Coordinator -AMTOI
From: Shantanu Bhadkamkar (via Google Docs) <drive-shar...@google.com>
Sent: 20 April 2026 11:23
To: in...@amtoi.org
Cc: am...@googlegroups.com; pres...@amtoi.org
Subject: DGS Stakeholder Inputs on MMTG Act 1993 Reform AMTOI - Version 20-04-2026
Shantanu Bhadkamkar attached a document
<image001.png>
<~WRD3638.jpg>
Shantanu Bhadkamkar (s...@atc.co.in) has attached the following document:
Please take note of the version 3 of Stakeholder Inputs on MMTG Act 1993 Reform AMTOI to DGS. This version amplifies response to Sr 6. Category: Legislative Cohesion (Sr 6 - Legislative Cohesion: Amendments to Schedule - Cargo Liability), and on page one emphasises on benefits of Conciliation as a non-adversarial means of dispute resolution.
<~WRD3638.jpg>DGS Stakeholder Inputs on MMTG Act 1993 Reform AMTOI - Version 20-04-2026
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Disclaimer
This email and any files transmitted with it are confidential and solely for the use of the intended recipient. If you are not the intended recipient or the person responsible for delivering it to the intended recipient, be advised that you have received this email in error and that any dissemination, distribution, copying or use is strictly prohibited. Please delete the same & inform the sender.
The contents of an attachment to this email may contain software viruses, which could damage your own computer system. While the sender has taken every reasonable precaution to minimize this risk, we cannot accept liability for any damage, which you sustain as a result of software viruses. You should carry out your own virus checks before opening any attachments to this email.
All rates are subject to fluctuation.
No insurance of goods will be effected except upon express written instructions + payment of Insurance premium in advance with corresponding subsequent written confirmation from ATC
Funds for payment of Duties, Taxes, Freight, any govt. / semi govt. and other statutory dues and other on account payments are required in advance.
Documents may only be sent using Standard Shippers / Importers Letter of Instructions / Covering letter, format available on request.
All business is undertaken by the company only in accordance with FFFAI Standard Trading Conditions, latest edition. A copy of which is available upon request.DisclaimerThis email and any files transmitted with it are confidential and solely for the use of the intended recipient. If you are not the intended recipient or the person responsible for delivering it to the intended recipient, be advised that you have received this email in error and that any dissemination, distribution, copying or use is strictly prohibited. Please delete the same & inform the sender.The contents of an attachment to this email may contain software viruses, which could damage your own computer system. While the sender has taken every reasonable precaution to minimize this risk, we cannot accept liability for any damage, which you sustain as a result of software viruses. You should carry out your own virus checks before opening any attachments to this email.All rates are subject to fluctuation.No insurance of goods will be effected except upon express written instructions + payment of Insurance premium in advance with corresponding subsequent written confirmation from ATCFunds for payment of Duties, Taxes, Freight, any govt. / semi govt. and other statutory dues and other on account payments are required in advance.Documents may only be sent using Standard Shippers / Importers Letter of Instructions / Covering letter, format available on request.
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<DGS Stakeholder Inputs on MMTG Act 1993 Reform AMTOI - Version 29-05-2026.pdf>
Shantanu Bhadkamkar
Dear Shankar,
The MMTG Act framework is not compatible with imports. In our assessment, its inclusion is likely to create more operational and regulatory complications than it resolves.
At present, there are three possible approaches:
- The Bangladesh model
- The Sri Lanka model
- Allowing import forwarders to participate as Associate Members of AMTOI, similar to the existing structure for LLCs and NVOCC non-MTO members. We will need any change in law for it.
The entire logic and reasoning underlying the present submission are based on maintaining a clear distinction in this area. Inclusion of imports at this stage would fundamentally alter the framework and weaken the coherence of the submission.
Our objective is to promote the growth and development of multimodal transport. We should remain focused on that objective and avoid diluting the framework by expanding into areas that require a substantially different regulatory approach.
This has been AMTOI’s consistent and firm position for the past 25 years. Any departure from this longstanding position would require a fresh round of detailed discussions and consultations. Similar discussions have already taken place on four separate occasions in the past.
The submissions were already in second/third circulation by 20 April 2026 for consideration. Thereafter, a meeting was held on 20 May 2026, the suggested changes were incorporated, and the positions were finalised at the level of the final draft.
If there are any suggestions regarding the drafting, language, or presentation, please do let us know. However, it would not be appropriate to reopen or alter the substantive position at this stage after finalisation of the draft.
Shantanu Bhadkamkar President - AMTOI
To view this discussion, visit https://groups.google.com/d/msgid/amtoi/6636B97F-2FD5-42D4-9FF6-DDED4E13A41C%40globalbm.com.
Global - Shankar Shinde
Shantanu Bhadkamkar
On 29 May 2026, at 8:41 PM, Global - Shankar Shinde <shankar...@globalbm.com> wrote:
Dear Santanuji,
To view this discussion, visit https://groups.google.com/d/msgid/amtoi/CAJP-TYWh01KqHwK_3YPqHrc-nO%3D5XU900Zy7T7CTNcJoNN_OKQ%40mail.gmail.com.