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Chaitanya Giri, “Charting a Path to Controlled Growth for India’s ‘Sunrise’ Space Economy,” ORF Issue Brief No. 810, May 2025, Observer Research Foundation.
India is poised to become the world’s third-largest economy by 2030. Sustained reforms in academia and research, along with support for innovation startups, have contributed to a steady growth in India’s innovation and related economic indices.
Value addition to high-volume and low-technology goods, an increase in export of natural resources and agricultural produce, higher investment in research, development, testing, and evaluation (RDTE), and a strategic commercialisation of mid- and high-technology products are key to sustaining this growth and India’s continued position at a high world ranking. In this respect, a noticeable change is anticipated in Indian gross value-added indicators as export-ready goods and services from so-called ‘sunrise sectors’—a start to contribute to this and other indicators of national and global relevance. The Indian government, since the Union Budget of 2022, has identified the following as sunrise sectors for the Indian economy: electronics and semiconductors; electric vehicles; renewable energy (including green hydrogen); agro- and food-processing; healthcare and pharmaceuticals; and space economy.
The sunrise sector of the space economy encompasses a gamut of products and services emerging out of the commercialisation of space technologies and services. This commercialisation is a relatively new phenomenon in India. For nearly 50 years, the Government of India treated its space programme as a strategic and, therefore, wholly government initiative. The Indian industry participated in the national space programme only as contractors—they manufactured products and services based entirely on the technical specifications given by the Department of Space (DOS) institutions.
In 2020, the Government of India took measures to reform the space sector, implementing initiatives to meet the demands of space economic activities within the country. These included the establishment of NewSpace India Limited, a public-sector commercial enterprise under the DOS; the creation of the Indian National Space Promotion and Authorization Centre (IN-SPACe) as a regulator and facilitator of the space sector; and the opening of new shared RDTE facilities.
Commercial entities can now seek access to strategic testing and R&D facilities operated by the DOS and various ministries, including the Ministry of Defence. The reforms have allowed non-government commercial entities to conduct RDTE aimed at space technology and services, develop their intellectual property, commercialise it, and engage in business-to-government, business-to-business, and business-to-customer interactions. This has resulted in the Indian space programme diversifying its stakeholder base to include a variety of commercial entities.
Further support has come in the form of enabling 100-percent foreign direct investment in space. The government has also allocated INR1,500 crores to a venture capital fund and an IN-SPACe-led Technology Adoption Fund. This commercialisation has compelled the space programme to take notice of new financial touchstones—such as revenues, profits, earnings before interest, taxes, depreciation, and amortisation; domestic and international product competitiveness; and revenue erosion, product and obsolescence—rather than driven by the government’s allocation of budget for space activities.
State governments are also encouraged to explore new use cases and provide opportunities for commercial entities to meet their mandated targets for growing the space economy. Concurrently, commercial entities have established industry bodies and are developing industry–academia partnerships, maintaining interactions with funding organisations and regulatory, legal, and strategic consultants, and engaging in promotional activities both domestically and overseas.
India’s private commercial space sector entities have begun to contribute to the country’s space industrial output by offering goods and services for various space applications: scientific study and exploration, services for social and civilian purposes, technology manufacturing for commercial use, military and intelligence services, and high-end scientific space mission technology manufacturing.
Indeed, India’s private space sector’s capabilities have already received international acknowledgement through business contracts. Indian startups like Pixxel and Digantara are developing small satellites and downstream services for the US Department of Defense, as well as other services for North American and European markets. Commercial space cooperation is now the crux of several bilateral partnerships, particularly with the US.
India and Australia’s Space MAITRI (Mission for Australia-India’s Technology Research Innovation) mission stands as another significant example of the confidence of international partners in collaborating with Indian private space entities. The Australian government has established a well-structured financing grant known as the International Space Investment India Projects Program, specifically designed for Australian commercial entities and academic institutions collaborating with Indian public and private partners on commercial space projects. As the first initiative under Space MAITRI, a consortium led by Australia’s Space Machines Company and India’s Ananth Technologies, along with the Australian Space Agency, the Indian Space Research Organisation (ISRO) and other partners, is constructing a state-of-the-art Orbital Servicing Vehicle named Optimus. Optimus will be manufactured in India and launched by the public-sector enterprise NewSpace India Limited using its Small Satellite Launch Vehicle.
The classical understanding of the space sector assesses the value created by the output of commercial entities that manufacture space-related products and deliver services. However, space is a highly value-added sector with a diversified portfolio of products and services, including software and information technology services utilised in various operational segments: upstream space operations, where a certain space asset is launched; midstream space operations, where the space asset is put into its final position in space; and downstream space operations, where the space asset is fully exploited and its data communicated to the ground receiving station for raw and value-added scientific, military, civilian, and commercial ends. Space also has supply chain linkages that traverse ‘non-space sector’ industries such as chemicals, plastic, and rubber. These diversified industries do not contribute exclusively to the space sector but do create ‘space-grade’ variants to be delivered for space applications.
Such new use cases of space services and products demand policy preparedness and regulations at levels that go beyond the long-established ambits of the DOS. The Indian context has examples of use cases where a certain space technology or service needs to be certified and regulated. The satellite toll collection system is one. The technology is aimed at increasing economic productivity by expanding the toll-collection ambit, increasing collection efficiency, and assisting in reducing traffic congestion and managing traffic, thereby also reducing the carbon footprint. In India, the system is regulated by the National Highways Fee (Determination of Rates and Collection) Amendment Rules, 2024, a new amendment to an old legislation that now facilitates the use of the indigenous satellite navigation system for a high revenue-generating, non-space sector. This new use case demands regulation on data security, stringent rules against tampering with the tracking of vehicles, and the standardisation of automatic number plate recognition cameras.
Thus, along with setting targets for the space economy, the government must work on incorporating appropriate policy changes, including space technology standards and certification bodies to determine the space-worthiness of products and services. Such steps are essential to ensure that Indian space economy products and services are export-ready in their ability to address regulatory concerns.
The aspiration to grow India’s space economy and its share in the global space economy necessitates a flourishing market in the export, re-export, and deemed export of space-sector goods and services. This policy brief outlines three recommendations to strengthen the space sector’s export strategy.
Space technology has a strategic and dual-use nature that necessitates balancing export promotion with control to secure the nation’s economic and strategic security interests.
The Special Chemicals, Organisms, Materials, Equipment, and Technologies (SCOMET) items list, maintained by the Ministry of Commerce’s Directorate General of Foreign Trade (DGFT), is India’s export control mechanism for goods with dual uses, and operates under the parameters set by the country’s foreign trade policy. The SCOMET list was first notified as part of the Foreign Trade (Development and Regulation) Act of 1992. In 2010, the Act was amended through the addition of Chapter IV A, which empowered the central government to monitor and amend the list. The SCOMET list is made up of nine categories (see Table 1), with only two of them assigned to a non-DGFT licensing authority–Category 0 is under the authorisation of the Department of Atomic Energy, and Category 6 falls under the Department of Defence Production.
Table 1: SCOMET Item Categories
SCOMET Item Category |
SCOMET Items |
Export Control Authorisation |
0 |
Nuclear materials, nuclear-related and other materials, equipment and technology |
Department of Atomic Energy |
1 |
Toxic chemical agents and other chemicals |
Directorate General of Foreign Trade |
2 | Micro-organisms and toxins |
Directorate General of Foreign Trade |
3 |
Materials, materials processing equipment and related technologies |
Directorate General of Foreign Trade |
4 |
Nuclear-related other equipment and technology, not controlled under category 0 |
Directorate General of Foreign Trade |
5 |
Aerospace systems, equipment, including production and test equipment, and related technology |
Directorate General of Foreign Trade |
6 |
Munitions list |
Department of Defence Production |
7 |
Computers, electronics, and information technology, including information security |
Directorate General of Foreign Trade |
8 |
Special materials and related equipment, material processing, electronics, computers, telecommunications, information security, sensors and lasers, navigation and avionics, marine, aerospace and propulsion |
Directorate General of Foreign Trade |
Category 9 (As proposed in this brief) |
Space technologies, space-grade materials, space-grade electronics, satellite communications systems, orbital guidance and manoeuvring systems, precision timing systems, space-based fly-by-wire systems, launch vehicle and spacecraft propulsion systems, up-, mid- and downstream softwares and information technology systems, ground infrastructure and receiving stations |
Department of Space |
Most space exports, including goods and services derived from commercial space-sector entities, are considered SCOMET exports. They are also subject to additional national and multilateral controls, particularly the Missile Technology Control Regime and the Wassenaar Arrangement. Despite this, a category dedicated to space-grade hardware and software is absent from the SCOMET list.
As India seeks to expand its space exports and solidify its position in the global space economy, this is a glaring omission. Many Indian space-sector manufacturing entities are likely to leverage the Export Promotion Capital Goods (EPCG) Scheme, which facilitates the import of capital goods necessary for producing quality goods and services, thereby enhancing India’s overall manufacturing competitiveness. A condition of the EPCG scheme is the obligation to export goods amounting to six times the taxes, duties, and cess saved on the importation of capital goods. This export obligation must be fulfilled within six years from the date of authorisation issuance.
This makes it essential to create a new category of SCOMET items, which includes dual-use space technologies, space-grade materials, space-grade electronics, satellite communications systems, orbital guidance and manoeuvring systems, precision timing systems, space-based fly-by-wire systems, launch vehicle and spacecraft propulsion systems, and software and information technology systems. In addition, given the substantial export potential from the domestic space sector and the recognition of space technology as a sunrise sector, the Department of Space—like the Department of Atomic Energy and the Department of Defence Production for Categories 0 and 6—must be the authorising governmental department. This initiative will boost competitiveness and enhance trade security by helping monitor the exports of sensitive technologies, products, and services, particularly from entities under the export obligation.
Figure 1: Export Control Relationship: 20th-C Heritage Space Technologies & Critical Tech-Integrated
Source: Author’s own
Figure 2: Classification of Goods & Services Under HS Codes
Source: Adapted from the West of England Protection & Indemnity Club
Table 2: WCO HS Amendments and Recommendations for HS Amendments Scheduled for 2034
WCO 2022 HS Amendments |
1. New HS code for electronic waste (in accordance with the Basel Convention)
|
WCO 2028 HS Amendments (partial announcement as of March 2025) |
21 new classification opinions, 23 amendments, and 18 classification decisions related to global challenges like climate change, global security threats, trade disruptions and global health crises |
WCO 2034 HS Amendments (as proposed in this issue brief) |
1. Prepare the Case for a new classification opinion to consolidate space-sector goods and services from three HS codes (88, 90, and 99) into one. 2. WCO has yet to notice the rise of the global space economy 3. WCO has no partnership with UNOOSA or any other national or international space body for HS revision 4. The only partnership is with European Space Agency but for WCO’s capacity building (signed in 2024) |
The World Customs Organization (WCO) is the leading intergovernmental institution that standardises tariff schedules for goods and services traded worldwide. The WCO's standardisation norms apply across 211 member countries, and ensure the integrity of global supply chains. It also plays a crucial role in facilitating the supply of humanitarian assistance and relief goods during ‘black swan events’ such as natural disasters and pandemics. To achieve these functions, the WCO maintains a comprehensive list of nearly 5,600 HS codes to classify traded goods, with codes updated and amended every six years to accommodate new and significant traded goods and services.
The last amendment to the HS codes was in 2022, with several new technologies and substances added to the list. For one, an HS code for electronic waste has been introduced, designed to control the export of hazardous waste in accordance with the Basel Convention. Smartphones are now categorised under a new subheading, differentiating them from traditional telephones, and a revised definition of the term ‘smartphone’ has been introduced. Additionally, a new HS subheading for heavy-duty vehicles equipped with full or partial electric motors has been established. Most recently, at the 74th session of its HS Committee, the WCO decided upon 23 amendments, considered 21 new classification opinions, and made 18 new classification decisions which are to be be brought into force in 2028. Global challenges such as climate change, security threats, trade disruptions, and health crises were taken into consideration during the decision-making process.
Yet, despite these efforts, there have been no reforms to the HS classification of space and space-related technologies and services. Institutional gaps within the WCO are to blame, the largest being the absence of the United Nations Office for Outer Space Affairs as a partner institution in the WCO. The second-largest gap is that the global space economy, projected to grow from US$630 billion in 2023 to US$1.8 trillion by 2035, is still not acknowledged by the WCO. Finally, there is a lack of cooperation with national and international space agencies. It is only recently that the European Space Agency has made initial moves to establish synergies with the WCO, with the two bodies signing a memorandum of intent in October 2024. Although the focus is still not on the ‘space economy,' the European Space Agency aims to provide capacity-building services to WCO officials and space technology solutions to address issues such as illicit trafficking, the management of fragile border areas, and the restriction of cross-border movement of goods used in terrorist attacks.
Given the growing diversity of satellites and spacecraft based on their end-use, the rise of commercial launch vehicles, especially small launchers that can be transported internationally, the immense diversity of space payloads and up, mid- and downstream software that could be traded globally, preparations should be made at the WCO to amend the existing HS codes and create new sub-headings and scope of terms to define the above-mentioned technologies and services in greater detail. The significance of accommodating newer subheadings for space items must be put across to the WCO HS Committee, which meets twice every year, and also before the WCO HS Scientific Sub-Committee, which meets once every year.
During its G20 2023 Presidency, India established its position as the ‘Voice of the Global South.’ In keeping with this, India should consider taking a leadership role in ensuring that the upcoming HS nomenclature and classification amendments, scheduled for 2034, accurately classify tradable space technology products and services.
Advocacy in this respect is essential to India’s trade interests. India is involved in developing four major trade routes: the India–Middle East–Europe Economic Corridor, the International North–South Trade Corridor, the Asia–Africa Growth Corridor, and the Chennai–Vladivostok Trade Corridor. None of these corridors can be established without the strategic application of space technologies—whether for ensuring smooth trade flows, promoting ‘good governance’ solutions, controlling illicit and terror-enabling goods, or ensuring peace and security across these corridors. The exchange of space technologies and services among the participating countries will necessitate HS code reforms.
Streamlining HS codes is also necessary to enhance India’s space-sector trade with the Global South and its capacity to offer or receive technical assistance. Trade of space technologies will become increasingly crucial when India signs free trade agreements, particularly with Australia, the European Union, and the US. This will lead to the exchange of technologies that require more precise classification than what the HS codes currently provide. For example, an Orbital Servicing Vehicle is a dual-use spacecraft platform: it can be designed for civilian purposes as an on-orbit servicing vehicle (to perform functions of repairing, refuelling, and replenishing) or, conversely, for military applications (to carry out rendezvous and proximity operations related to intelligence-gathering or close-proximity anti-satellite missions involving the disruption and destruction of satellites). The HS classifications available must be able to signify this crucial distinction. Without reform in the HS, it will be challenging for any government to balance export control and promotion effectively.
The complexity of space-sector goods and services in their design, construction, and operation (whether for civilian, commercial, or military use cases) is increasing every passing year. The lines between civilian and military space operations are blurring as militaries increasingly prefer to use ‘space-as-a-service’ offerings by commercial players as end-users and achieve their military goals. To that end, an unusual phenomenon is occurring in the US, where it is easing military restrictions on ‘non-cutting-edge’ and less-advanced space technologies enlisted in its Commerce Control List, while tightening controls on emerging technologies, especially metal or alloy additive manufacturing items, gate-all-around field effect transistor technology, semiconductor manufacturing, and quantum technology.
These tighter controls are also likely to be applied to space technologies that are built or operated based on such export-restricted emerging and crucial technologies. Therefore, tracking space technologies based on the currently simplistic HS codes may lead to an evasion of export controls, unless controllers consider the component or subsystem’s HS code, which could be a more sensitive item. Simply put, a satellite or a launch vehicle built with twentieth-century technologies and components is less likely to be deemed a sensitive item and may receive export control relaxations. That, however, will not be the case with satellites and launch vehicles built with emerging and strategically crucial technologies.
India, too, must ensure that its space technology is readily available for export while maintaining strict control and monitoring over space technology that involves sensitive emerging technologies. This requires reforming the codes within the HS classification, which have become overly simplistic and outdated.
Three two-digit HS chapters are relevant for the space sector: Chapter 88 (aircraft, spacecraft, and parts thereof); Chapter 90 (optical, photographic, cinematographic, measuring, checking, precision, medical, or surgical instruments and apparatus); and Chapter 99 (raw materials, construction materials, and other miscellaneous consulting and information technology services). The Indian Ministry of Commerce’s Export Import Data Bank and Monitoring Board, in its current iteration, does not assist in tracking the diversity of space technology goods and services. For instance, Chapter 88 has several six-digit codes denoting diverse aircraft tools and parts but none for different spacecraft components, systems, and sub-systems. Within this chapter, the trade of all space technology goods is categorised as HS 880260, which denotes “spacecraft (including satellites and suborbital), spacecraft launch vehicle.” This means the export control of strategic emerging space technologies, for example, a quantum-communication satellite, is cumbersome: if it is classified simply as HS 880260, this will not help in distinguishing it from a satellite with unremarkable and mundane technological characteristics.
Likewise, within HS Chapter 99, no six-digit code is attributed to the diversity of space payloads: from geospatial, telecommunication, and human spaceflight systems, to analytical, rover, lander, or extraterrestrial uncrewed aerial vehicles. Several space payloads may go unnoticed under four- and six-digit HS codes attributed to instruments that find application in non-space sector laboratories.
To that end, there is an opportunity for the Ministry of Commerce, in consultation with space industry bodies such as the Confederation of Indian Industry, the Satcom Industry Association India, and the Indian Space Association, to amend the Indian Trade Classification of HS (ITC-HS). As part of these amendments, the ministry must consider further classifying the six-digit ITC-HS code 880260 at an eight-digit level by assigning specific eight-digit codes in the 880260 series for each product type, including tradable space technology components, payloads, systems, subsystems, space-grade materials, space-grade electronics, chemicals, and software.
By doing this, the ministry could also consolidate various space products and services scattered across different HS chapters into a single code, facilitating the monitoring of space economic activities. The current fragmentation hinders the accurate measurement of actual economic activities related to space within the country and international trade.
Despite the tremendous progress driven by reforms in the space sector, India’s potential for exporting space technology and services remains underutilised. Developing a national strategy for space exports faces various challenges.
In the coming years, the global economy will be influenced by geopolitical multipolarity, which could lead to escalated tariff wars, trade wars, trade dumping, supply chain disruptions, and economic sanctions, both between countries as well as geopolitical blocs. The space economy represents an arena for both genuine technical cooperation and intense great-power competition. Therefore, it is essential to achieve a delicate balance between addressing challenges to global trade to ensure equitable development and facilitating the space economy as the backbone of various peripheral economic activities and effective governance mechanisms, while also controlling the trade of sensitive emerging technologies. India’s space exports must be regulated to ensure that Indian intellectual property remains within secure supply chains, complies with international export control treaties, and is leveraged by the Indian state to uphold its comprehensive national interests.
With the rise of a public-private partnership–driven global space economy, India also needs to cultivate the private space sector to work independently of the ISRO. The nation must implement measures that ensure the national space economy’s growth is carefully measured and monitored, and accomplish its important role in reforming the WCO HS tariff schedules.
It is only when these challenges are addressed that domestic space economic activities will be able to achieve the goal of a 15-percent share of the global space economy.
Chaitanya Giri is Fellow, Centre for Security, Strategy and Technology, Observer Research Foundation.
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Dr. Chaitanya Giri is a Fellow at ORF’s Centre for Security, Strategy and Technology. His work focuses on India’s space ecosystem and its interlinkages with ...
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