E-Way Bill for Job Work: Compliance Requirements for Manufacturers

The implementation of GST brought significant changes to the compliance requirements for manufacturers. One of the most crucial aspects of GST compliance is the generation of e-way bills for the transportation of goods. Manufacturers must comply with e-way bill regulations when goods are being transported for job work, including sending raw materials or receiving finished products. This article explains the compliance requirements for manufacturers and how the e-way bill is applicable to job work scenarios.

Latest Update
February 6, 2025

As per Rule 138(14) of the CGST Rules, 2017, goods under Chapter 71 are exempt from mandatory E-Way Bill (EWB) generation. While the National Informatics Centre (NIC) previously allowed voluntary EWB generation for these goods, this option has now been withdrawn. However, for intra-state movement in Kerala, EWB is mandatory as per Notification No.10/24-State Tax dated 27/12/24.

January 27, 2025

Kerala has introduced a new option for generating E-Way Bills (EWB) for gold (Chapter 71), excluding imitation jewellery (HSN 7117), for intrastate movement. Taxpayers can continue generating the E-way bill for imitation jewellery (HSN 7117) using the usual option in the EWB system . This update applies only to the movement within the state of Kerala.

17th December 2024

1. GST Network has issued an advisory on 17th December 2024 to expand the scope of mandating 2FA on NIC for taxpayers. If your enterprise/business have AATO over Rs.20 crores, use 2FA from 1st January 2025 mandatorily. Likewise, 2FA will be mandatory for businesses with turnover ranging Rs.5 Crore to Rs.20 Crore from 1st February 2025. All taxpayers irrespective of turnover should mandatorily use 2FA for e-invoice and e-way bill generation from 1st April 2025.
2. Generate e-way bills within 180 days from the date of the document/invoice starting from 1st January 2025.
3. e-Way bill validity extensions will be capped at 360 days from the original generation date from 1st January 2025. 

e-Way bill and job work

Job work forms an integral part of manufacturing industry as most of the manufacturing businesses outsource some part of the manufacturing activities. The process of job work could include initial processing, further processing, packing, assembling or such other process of completion. Specific scenarios which might happen with respect to job work which requires movement of goods–

1. Inputs sent by a principal to job worker
2. Inputs sent to a job worker directly from a vendor
3. Inputs received back by a principal after the job work is done
4. Finished goods supplied directly to the end customer from job worker

Inputs sent by Principal to Job worker or vice-versa

In case the principal is situated in a different state, and the principal is sending his goods to the job worker located in some other state, the principal needs to generate Eway bill compulsorily. Here, the threshold limit of INR 50,000 isn’t applicable; hence even where the value of goods sent out to the job worker doesn’t exceed INR 50,000, the principal needs to generate the Eway bill.

Inputs received back by a principal after the job work is done

Once a job work has finished the goods, the principal could either receive the goods back or could ask job worker to supply such goods to the end customers directly. In case such job worker is registered on the e-way bill portal, the job worker would generate the Eway bill for such movement of goods, and in case the job worker hasn’t registered himself, the respective principal needs to generate an e-way bill.

Finished goods supplied directly to the end customer from job worker

Where the goods are supplied directly from job worker’s place of business to the end customers, it’s mandatory that:

1. Such job worker must be registered under section 25 or,
2. Such principal must declare the job worker’s place as his additional place of business.

Here also, in case the job worker has registered himself on the portal, he would issue an Eway bill or such principal needs to issue Ewaye-way bill.

Documents required to be issued prior to sending goods to the job worker

In case the goods are sent to a job worker, there isn’t any requirement to issue a tax invoice. However, a delivery challan (DC) is to be issued for such goods. The DC would contain the following details –

1. Number of the DC along with the date,
2. Name, GSTIN and address of the principal (consignor) and the Job Worker (consignee). GSTIN is required to be mentioned in case consignor and consignee are registered under the GST.
3. HSN code and the description of such goods,
4. Quantities of goods supplied
5. Taxable Value of such goods
6. The rate of tax and amount of tax
7. Place of supply
8. Signature

e-Way bill requirement for different job works

Supply of liquid gas

Eway bill is required to be generated for the supply of liquid gas where quantity while removal from supplier’s place of business is not known. Also, a delivery challan (DC) needs to be issued by the supplier and has to be carried by a person who is in charge of the conveyance. In the case where the transportation is outsourced, the transporter needs to issue the delivery challan.

Supply on approval basis

As per the circular issued by the government, goods which are supplied on approval basis could be moved from place of business of a registered supplier to any other place within the same State or outside the State with a DC (delivery challan) together with Eway bill wherever relevant and invoice could be issued on delivery of such goods. The person could carry his invoice book and issue invoice as and when the supply is fructified.

Stock transfer and branch transfers

As per the rules laid down with respect to Eway bill, a manufacturer (supplier) is required to generate the Eway bill for stock transfer or branch transfer if the value of such consignment exceeds INR 50,000.

Sub-user facility for e-way bill generation

The Eway bill needs to be generated for each and every consignment where the value of such consignment exceeds INR 50,000.  There are many manufacturers with branch offices and multiple places of business at various. Generating the Eway Bill from different places with the single login could be a difficult task.

For overcoming this issue the sub-users concept is introduced. A sub-user could use the login credentials which were created originally and execute the actions according to the access provided to them. For instance, a sub-user could be allowed to generate the Eway Bill and could be restricted from rejecting any Eway Bill. However, the registered person is required to enter address accordingly in Eway bill. He could also create several sub-users and generate e-way bills accordingly.

Under the job work consignment goods may move in different stages such as from the manufacturer to the job worker, from the job worker back to the manufacturer, or directly from the job worker to the customer. In any of these movements, a delivery challan must accompany the goods, outlining the description, HSN code, taxable value, and tax rate.