Essential E-Way Bill Regulations and Transporter Responsibilities
This article explains the critical e-way bill rules and compliance requirements for transporters under GST law in India. It details how unregistered transporters can obtain a unique Transporter ID (TRANSIN) and the step-by-step enrollment process on the e-way bill portal. The guide also covers procedures for updating conveyance details during transshipment, managing multiple consignments, and the necessary documents to be carried during goods movement. Furthermore, it outlines the inspection and verification processes for consignments in transit.
Transporters are required to understand the e-way bill regulations outlined by GST law, as they bear responsibility for non-compliance if an e-way bill, necessary for a consignment, is not generated by the supplier or recipient. Transporters must adhere to these rules to avoid penalties and ensure smooth logistics.
Understanding Transporter ID and Enrollment
Transporter ID (TRANSIN) Overview
A Transporter ID, also known as TRANSIN, is a distinct 15-digit identification code issued to transporters not registered under GST, allowing them to create e-Way Bills. This ID is derived from the State code, PAN, and a checksum digit. All transporters must generate an e-way bill under two conditions: (a) if the value of a single supply consignment or goods surpasses Rs. 50,000, or (b) if the total value of all goods transported in a vehicle collectively exceeds Rs. 50,000. Even unregistered transporters are obligated to generate e-way bills in these scenarios. Given that they do not possess a GSTIN, the Transporter ID concept was introduced to facilitate this requirement.
When and Where to Use Transporter ID
Unregistered transporters must include their Transporter ID (TRANSIN) on every e-way bill, substituting their GSTIN. This ID is shared with suppliers or consignors so they can include it on generated e-way bills, allowing the transporter to subsequently update vehicle details for goods movement.
Enrollment Process for Unregistered Transporters
Unregistered transporters obtain a Transporter ID upon successful enrollment on the EWB portal. This enrollment process grants them a distinct Transporter ID (TRANSIN) and a unique username for interacting with the e-way bill portal.
The following is a step-by-step guide for unregistered GST transporters to enroll on the e-Way Bill portal:
Step 1: Accessing the E-Way Bill Portal
Access the e-way bill portal.
Step 2: Initiating Transporter Enrolment
Select the 'Enrolment for transporters' option located under the Registration tab on the homepage.
Step 3: Completing the Application Details
Complete the application details from points 1 through 9 and then click 'Save'. The subsequent sections elaborate on each of the nine required fields in the 'Application u/s 35(2)' (GST ENR-01), noting that fields marked with an asterisk are compulsory.
- Choose your State.
- Provide specific information: a) Your name as it appears on your PAN card. b) Your trade name, if applicable. c) Your PAN. Upon entering and validating your PAN, the system will check for errors and discrepancies, allowing you to correct them before continuing.
- Specify the enrolment type. You must complete points 1 and 2 before proceeding. Select the appropriate type, such as warehouse, godown, cold storage, or transport service.
- Indicate the business constitution by selecting from options like foreign company, partnership firm, proprietorship, private limited company, public limited company, unlimited company, or others (e.g., HUF, AOP, BOI).
Providing Principal Place of Business Information
- Provide details for the principal place of business: a) Enter the complete address, ensuring all mandatory fields are filled. b) Input contact information including email address, telephone number, and fax number (if applicable). This email address will be used for authentication. c) Specify the nature of the premises (e.g., owned, leased, rented, consent, shared, or other), along with the name of the proprietor or primary individual of the company/firm and their mobile number. This mobile number will be used for OTP verification.
Setting Login Credentials
- Establish login credentials by setting a unique username (user ID) and password. Use the 'Check' function to confirm the availability of your chosen username.
Final Verification
- Complete the verification by ticking the declaration to confirm the accuracy of your provided information, entering the displayed captcha, and clicking 'Save'.
Receiving Your Transporter ID
Upon successful completion, the system will generate and display a 15-digit Transporter ID (TRANSIN). It is important to record this number and share it with clients.
Changing Conveyance During Transit
Should a transporter switch the mode of transport for goods while in transit, they are required to update the new conveyance details in the existing e-way bill (Form EWB-01) on the e-way bill portal prior to the transfer. However, an exception applies: if goods are transported to a consignee over a distance of 50 kilometers or less within the same State or Union Territory as the transporter's business location, updating the conveyance details in the e-way bill is not necessary.
Rules for Multiple Consignments in a Single Vehicle
When a transporter transports multiple consignments in a single vehicle, they must electronically list the serial numbers of the individual e-way bills for each consignment on the e-way bill portal. Additionally, a consolidated e-way bill (Form EWB-02) must be generated before the goods commence their journey.
Handling Goods Transshipment
Transshipment refers to altering the mode of transport or vehicle during the transit of goods. In such instances, the e-way bill portal allows the transporter or the e-way bill generator to update the vehicle number on the e-way bill for the new conveyance. Only the seller or the transporter listed in Part A of the e-way bill can perform these vehicle number updates, and this action can be repeated multiple times. The portal also offers the functionality to re-assign a different transporter to an e-way bill. Once the initial transporter re-assigns the responsibility, the seller loses the ability to modify this option.
Required Documents for Conveyance In-Charge
The individual overseeing a conveyance must carry specific documents: the invoice, bill of supply, or delivery challan, along with a physical copy of the e-way bill or its number, which can also be linked to an RFID (Radio Frequency Identification Device) embedded in the vehicle. The commissioner will announce further details regarding RFID usage. Nonetheless, the commissioner may permit the person-in-charge to carry a tax invoice, bill of supply, bill of entry, or a delivery challan for goods transported outside the scope of a 'supply', in lieu of the e-way bill. Registered individuals can submit a tax invoice using Form INV-1 on the e-way bill portal to obtain an Invoice Reference Number (IRN). This IRN is valid for 30 days from its upload date and can be presented to an officer for verification as an alternative to the physical tax invoice. It is important to note that when a registered person uploads an invoice, the details in Part A of Form GST INS-1 are automatically populated from GST INV-1. Furthermore, the commissioner has the authority to mandate certain transporters to obtain a unique RFID, which will be integrated into the conveyance and linked to the e-way bill prior to goods movement.
Stopping Vehicles and Document Verification in Transit
Vehicles can be halted for verification during both inter-state and intra-state movements. The Commissioner, or an authorized officer, may permit stopping a consignment to check its e-way bill. RFID readers will be deployed at critical points to verify goods movement by reading e-way bills mapped to RFIDs. Physical inspection of conveyances is also permissible. If 'specific information' about tax evasion exists, an authorized officer can conduct a physical verification of a vehicle, even if other checks have occurred.
Goods Inspection and Verification Procedures
Officers are required to record a summary of each goods inspection in transit online, using Part A of Form GST EWB-03, within 24 hours. The complete report, Part B of GST EWB-03, must be submitted within three days. Generally, goods are inspected only once per journey. Nevertheless, a vehicle can be stopped for a second inspection if 'specific information' regarding tax evasion arises, even after an initial check. If a vehicle is held for over 30 minutes, the transporter can log this incident in Form GST EWB-04 on the common portal.
For further reading and understanding on e-way bills:
- How to generate e-way bills on the portal?
- How to use SMS facility to generate/modify/cancel e-way bills?
- How to generate consolidated e-way bills on the e-way bill portal?