Compliance For eWay Bill by Transporter and Other Important Rules

Transporters must be aware of the e-way bill rules prescribed by the GST law. It is because they are also made liable for non-compliance on their part wherever an e-way bill needs to be generated but is failed to be created by the supplier or the recipient, as applicable.

What is Transporter ID and how to enrol for it?

Transporter ID or TRANSIN is a 15-digit unique identification number allotted to an unregistered transporter enabling generation of e-Way Bills. It is generated based on the State code, PAN and check sum digit.

All Transporters are required to generate e- way bill if: 

(a) Value of consignment/value of goods of a single supply exceeds Rs.50,000.

OR 

(b) Value of all the goods in a vehicle through which goods are transported cumulatively exceeds Rs.50,000.

Even the unregistered transporters under GST have to note that e-way bills are required to be generated by them under the above circumstances. Since unregistered transporters will not have a GSTIN, the concept of transporter ID has been introduced. 

Where and when to use the Transporter ID or TRANSIN? 

Unregistered transporters have to mention this ID on every e-way bill in the place of GSTIN. Transporters provide this number to the suppliers/consignor to mention it on the e-way bills generated by them which in turn enables the transporter to update the vehicle number later for movements of goods.

Procedure to be followed by Unregistered transporters to get the transporter ID or TRANSIN?  

Every unregistered transporter will be issued a transporter ID on enrolling themselves on the EWB portal. By doing enrolment on e-way bill portal, the following are the outcome: 

i) The transporter gets a unique transporter ID or TRANSIN.

ii) A unique username to operate on the e-way bill portal. 

Here is the step-by-step process for enrolment on the e-Way Bill portal by GST unregistered transporters: 

Step-1: Visit the e-way bill portal.  

Step-2: Click on ‘ Enrolment for transporters ’ under the Registration tab available on the Home page.

Step-3: Enter the details in the Application at points 1-9 and Click ‘Save’. 
Let’s go through the entire ‘Application u/s 35(2)’ in GST ENR-01 for each of the 9 points:

Note that the fields marked (*) in red are mandatory.

1. Select Your State*. 

2. Enter certain details:

a) Enter Name as per PAN*. 

b) Enter Trade name, if any.

c)  Enter your PAN* (Note that once you enter PAN and click on Validate, the system validates for any error or mismatch, and rectifies the same before proceeding). 

3. Type of enrolment*: 

Note: The system does not allow you to proceed here without entering the details at point 1 and 2. Select the relevant type- warehouse/godown/cold storage/transport service.
 

4. Constitution of business*: Select the relevant business form from the drop down- foreign company/partnership firm/ proprietorship/ private limited company/ public limited company/unlimited company/ others (If HUF, AOP, BOI and so on)

5. Principal place of business

a) Type in the complete address entering all the red marked mandatory fields.* 

b) Contact information: Type the e-mail address, telephone number and fax number (if any) 

Note: The e-mail address mentioned here shall be used for authentication. 

c) Nature of premises mentioned at a)- Select whether the address at a) is a building that is owned /leased /rented/ consent/ shared/ any other case along with name of the proprietor or main person of the company/firm and mobile number.

Note: The mobile number mentioned here shall be used for OTP verification.. 
 

7. Create Login details* : Set a new unique username/ user ID and password. Check if the username you wish to set is already being used or not by clicking on ‘Check’. 

8. Verification* : Tick mark against the declaration confirming the correctness of the information you give, enter teh given captcha and Click ‘Save’. 

Outcome: System generates a 15-digit transporter ID or TRANSIN and displays the same. Note this number and inform clients.

What happens if the transporter changes the mode of conveyance during transit?

If a transporter is transferring goods from one conveyance to another during the course of the transit, then they must update the details of the new conveyance in the e-way bill already generated on the e-way bill portal in the form EWB-01, before such transfer takes place.

The caveat here is that if the goods are being transported to a consignee for a distance of fifty kilometres or less, within the same State or Union territory as the place of business of the transporter, the details of conveyance need not be updated in the e-way bill.

What is the rule to be followed when transferring multiple consignments in a single conveyance?

Where a transporter is moving more than one consignment in one conveyance, he must indicate the serial number of e-way bills for each consignment electronically on the e-way bill portal. A consolidated e-way bill in form EWB-02 must be generated before the movement of goods.

How to deal with the situation of transshipment of Goods?

“Transshipment” means the change in the mode of transport/conveyance or change of vehicles during the transit of goods.  Portal provides an option in such a case to the transporter/generator of the e-way bill to update the vehicle number on e-way Bill of the vehicle in which he is transporting that consignment. 

The seller or the transporter mentioned in Part A of the e-way bill can only update the vehicle number and this can be done ‘n’ number of times. Eway bill portal has also provided an option to change/ re-assign another transporter to an Eway bill. Once the originally assigned transporter re-assigns another transporter in his place, the seller cannot exercise this option any longer.  

What are the documents to be carried by the person-in-charge of conveyance?

The person-in-charge of a conveyance must carry:

• The invoice or bill of supply or delivery challan and
• A copy of the e-way bill or the e-way bill number, either physically or mapped to a RFID (Radio Frequency Identification Device). RFID is embedded onto the conveyance (mode of transport). Details of these will be notified by the commissioner. However, the commissioner may notify person-in-charge to carry the following documents instead of the e-way bill –
  • Tax invoice or bill or supply of bill of entry or
  • A delivery challan, where goods are transported other than by way of ‘supply’

A registered person can submit a tax invoice in form INV-1 on the e-way bill portal. After which he will get an Invoice Reference Number (IRN). IRN is valid for 30 days from the date of uploading. It can be given for verification by an officer instead of the tax invoice.

Note that where a registered person uploads the invoice, information in Part A of Form GST INS-1 is auto populated from GST INV-1. The commissioner may notify a class of transporters to get a unique RFID. This RFID will be embedded on to the conveyance (mode of transport) and mapped to the e-way bill before the movement of goods. 

What is the process for stopping vehicles and verification of documents in transit? 

Any mode of transport can be stopped for inter-state and intra-state movements. The Commissioner, or an officer empowered by him, may authorise an officer to stop a consignment to verify e-way bill. RFID readers will be installed at places where verification of movement of goods is required. 

Verification will be done through RFID readers where e-way bills are mapped with RFID. Physical verification of conveyances may also be done. In case there is ‘specific information’ of tax evasion, physical verification of a conveyance can also be done by an authorised officer.

What is the process of inspection and verification of goods?

A summary of every inspection of goods in transit will be recorded online by the officer in Part A of GST EWB-03 within 24 hours of inspection. The final report will be submitted in Part B of GST EWB-03 within 3 days of inspection. Goods will be inspected only once during a journey. However, if any ‘specific information’ of tax evasion is available even after an inspection is already done, the vehicle can be stopped again. If a vehicle is intercepted or stopped or detained for more than 30 minutes the transporter can upload this information 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?