The Central Board of Indirect Taxes and Customs (CBIC) recently implemented additional reporting requirements under the Goods and Services Tax (GST) law for manufacturers of specific tobacco products and pan masala. This measure aims to increase transparency and streamline operational practices within the industry.

Introduction to CGST Notification No. 30/2023 dated 31st July 2023

CBIC issued Notification No. 30/2023 on July 31, 2023, introducing new mandates for the tobacco and pan masala manufacturing sectors. Key provisions include:

• Details of Packing Machines: Registered manufacturers are now required to submit comprehensive information about their packing machines used for retail packaging of tobacco products and pan masala. This data must include the machine's make, model number, purchase date, installation location, packing capacity, and electricity consumption, all to be recorded in Form SRM-I.
• Submission Deadlines: Existing manufacturers must provide these details within 30 days of the notification's release. New manufacturers, registered after the notification date, have 15 days from their GST registration grant to comply.
• Operational Record-Keeping: A daily record-keeping system has been established. Manufacturers are encouraged to document daily inputs, waste generated, electricity and generator meter readings, and specific production data. Prescribed formats for this are Forms SRM-IIIA and SRM-IIIB.
• Monthly Reporting: To further promote transparency, manufacturers must submit a special monthly statement detailing essential operational metrics. This statement, Form SRM-IV, must be uploaded to the GST portal by the tenth day of the following month.

These regulations are designed to improve oversight of a sector with significant economic and public health implications. The primary objectives are to ensure transparent operations, accurate reporting, and the promotion of responsible manufacturing practices.

Notified Registered Manufacturers of Goods

The registered manufacturers of goods, as specified in the Schedule, encompass those producing a range of items, including:

• Tobacco Products: This category includes pan masala, unmanufactured tobacco (both branded and unbranded, with or without lime tube), branded tobacco refuse, 'Hookah' or 'gudakhu' tobacco (branded and unbranded), other unbranded water pipe smoke tobacco, smoking mixtures for pipes and cigarettes, and other types of smoking tobacco (branded and unbranded).
• Homogenized or Reconstituted Tobacco Products: This specifically refers to "homogenized" or "reconstituted" tobacco that bears a brand name.
• Chewing Tobacco and Similar Products: This group covers chewing tobacco (with and without lime tube), filter khaini, preparations containing chewing tobacco, and jarda scented tobacco.
• Snuff and Extracts: This includes snuff, preparations containing snuff, and tobacco extracts and essence (branded and unbranded).
• Miscellaneous: Other items such as cut tobacco, pan masala containing tobacco 'Gutkha', and all other goods (excluding pan masala with tobacco 'gutkha', both branded and unbranded) are also covered.

Clarifications on Terminology and Interpretation

1. Terms such as "tariff item," "heading," "subheading," and "Chapter" within this Schedule correspond to their definitions in the First Schedule of the Customs Tariff Act, 1975 (Act No. 51 of 1975).
2. The interpretation of this notification will adhere to the guidelines provided in the First Schedule of the Customs Tariff Act, 1975. This includes observing the Section and Chapter Notes, along with the General Explanatory Notes of the First Schedule, where applicable.
3. For the purposes of this notification, "brand name" encompasses both registered and unregistered brands and trade names. It refers to any name, symbol, monogram, label, signature, or coined word that indicates a trade connection between specific goods and a person or entity utilizing such a descriptor, even if the exact identity of that party is not disclosed.

Time Limit for Submission of Documents

Manufacturers must adhere to specific deadlines for document submission:

• For Existing Registered Manufacturers: Those registered before the issuance of CGST Notification No. 30/2023 must submit the necessary information within 30 days from the notification's effective date.
• For Newly Registered Manufacturers under GST: Manufacturers obtaining their GST registration after this notification's release are required to provide the specified details within 15 days of receiving their registration grant.

List of Documents Required for Submission

Details of Packing Machines

Manufacturers are obligated to provide comprehensive information about their packing machines, including the make, model number, purchase date, installation address, packing capacity, and the machine's hourly electricity consumption.

FORM SRM-I

These details can be verified using purchase invoices, machine manuals, and internal inventory records.

Installation of Additional Machines

If any new filling and packing machine is installed at the business premises after the initial declaration, its details must be submitted. This action facilitates the generation of a unique identification for each newly installed machine.

FORM SRM-IIA

Information can be gathered from recent purchase documentation, installation receipts, and internal asset tracking systems.

Removal of Existing Machines

Registered manufacturers must report the removal of an existing filling and packing machine from their premises within a 24-hour timeframe, providing the reasons for its removal.

FORM SRM-IIB

Relevant information can be obtained from asset disposal logs, decommissioning reports, and internal inventory adjustments.

Daily Records of Operations

A detailed daily record is mandatory, covering inputs procured, waste generated, electricity and generator meter readings, and shift-wise production specifics.

FORM SRM-IIIA

FORM SMR-IIIB

These records should be diligently maintained on a daily basis, utilizing procurement logs, production sheets, and utility meter readings.

Special Monthly Statement

A dedicated monthly report containing crucial operational data points must be prepared and submitted by the manufacturer.

FORM SRM-IV

Manufacturers should consolidate data from their daily records for this monthly submission.

Adherence to these guidelines, ensuring accurate and timely submissions, is crucial. Effective document management practices can simplify this process and help maintain seamless compliance.