Important Keyword: Circular No. 208/02/2024 - GST, GST Circular 208/02/2024, Notification No. 04/2024 - Central Tax, Special Procedure for Manufacturers, GST SRM-I, GST SRM-II, GST SRM-III, Packing Machine GST Rules, Chartered Engineer Certificate GST, GST on Specified Commodities, Job Work GST Compliance, SEZ GST Special Procedure, Manufacturing GST Compliance, CBIC GST Circular June 2024,
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F.No. CBIC-20001/4/2024-GST
Government of India
Ministry of Finance
(Department of Revenue)
Central Board of Indirect Taxes and Customs GST Policy Wing
*****
North Block, New Delhi Dated the 26th June, 2024
Circular No. 208/02/2024 - GST: Clarifications on various issues pertaining to special procedure for the manufacturers of the specified commodities.
To,
The Principal Chief Commissioners/ Chief Commissioners/ Principal Commissioners/ Commissioners of Central Tax (All)
The Principal Directors General/ Directors General (All)
Madam/Sir,
Subject: Clarifications on various issues pertaining to special procedure for the manufacturers of the specified commodities as per Notification No. 04/2024 - Central Tax dated 05.01.2024– reg.
Based on the recommendation of 50th GST Council meeting, a special procedure was notified vide Notification No. 30/2023-Central Tax dated 31.07.2023 to be followed by the registered persons engaged in manufacturing of goods mentioned in the schedule to the said notification. The said notification has been rescinded vide Notification No. 03/2024-Central Tax dated 05.01.2024 and a revised special procedure has been notified vide Notification No. 04/2024- Central Tax dated 05.01.2024.
- Representations have been received from various trade associations seeking clarity on some issues pertaining to the said special procedure. To ensure uniformity in the implementation of the provisions of law across the field formations, the Board, in exercise of its powers conferred by section 168 (1) of the Central Goods & Services Tax Act, 2017 (herein after referred to as the “CGST Act”), hereby clarifies various issues as under:
.
| S.No. | Issued Raised by Trade | Clarification on the issue |
| 1. | Non availability of make, model number and machine number - The trade bodies have raised the issue that some of the manufacturers of the said goods are using very old packing machines since decades including second hand machines. Therefore, the details of make, model number and machine number of these machines are not readily available. | It is clarified that in Table 6 of FORM GST SRM-I as notified vide Notification No. 04/2024-CT dated 05.01.2024, make and model number are optional. However, where make of the machine is not available, the year of purchase of the machine may be declared as the make number. It is also clarified that the machine number is a mandatory field in Table 6 of FORM GST SRM-I to be filled up by the manufacturer. If the machine number is not available either on the machine or as per the available documents/ records, then the manufacturer may assign any numeric number to the said machine and provide the details of the same in Table 6 of FORM GST SRM-I. |
| 2. | In cases where the electricity consumption rating of the packing machine is not available in the specifications of the said machine or in the documents/record of the same, then how to declare the electricity consumption rating of the said machine in Table 6 of FORM GST SRM-I? | It is clarified that electricity consumption rating of the packing machine is to be declared in Table 6 of FORM GST SRM- I on the basis of details of the same as available either on the machine or in the documents/record of the said machine. However, if the same is not available either on the machine or in the documents/records, then the manufacturer may get such electricity consumption per hour of the said machine calculated through a Chartered Engineer and get the |
| same certified by the said Chartered Engineer in the format prescribed in FORM GST SRM-III, as notified vide Notification No. 04/2024-CT dated 05.01.2024. The said electricity consumption rating can be declared in Table 6 of FORM GST SRM-I accordingly. The copy of such certificate of the Chartered Engineer needs to be uploaded along with FORM GST SRM-I. The details of the documents so uploaded needs to be provided in Table 10 of the said form. It is also clarified that in cases where there are certificates of Chartered Engineer for more than one machine, then all such certificates may be uploaded in a single PDF file. | ||
| 3. | Which value has to be reported in Column 8 of Table 9 of FORM GST SRM-II in case of goods having no MRP, for example, goods manufactured for export market? | In cases where there is no MRP of the package, then the sale price of the goods so manufactured shall be entered in Column 8 of Table 9 of FORM GST SRM-II as notified vide Notification No. 04/2024-CT dated 05.01.2024. |
| 4. | What should be the qualification and eligibility of the Chartered Engineer for providing Chartered Engineer certificate under the special procedure notified vide Notification No. 04/2024-CT dated 05.01.2024? | It is clarified that a Practicing Chartered Engineer having a certificate of practice from the Institute of Engineers India (IEI) is qualified to provide Chartered Engineer certificate under the special procedure notified vide Notification No. 04/2024-CT dated 05.01.2024. |
| 5. | Whether the special procedure notified vide Notification No. 04/2024-CT dated 05.01.2024 is applicable to the manufacturing units located in Special Economic Zone (SEZ)? | It is clarified that the special procedure as notified vide Notification No. 04/2024-CT dated 05.01.2024 is not applicable to the manufacturing units located in Special Economic Zone. |
| 6. | Whether the special procedure notified vide Notification No. 04/2024-CT dated 05.01.2024 is applicable to the manual processes using electric operated heat sealer and seamer? | It is clarified that the said special procedure notified vide Notification No. 04/2024-CT dated 05.01.2024 is not applicable in respect of manual seamer/ sealer being used for packing operations. Further, it is also clarified that the said special procedure is not applicable in respect of manual packing operations such as those in cases of post-harvest packing of tobacco leaves. |
| 7. | In cases where multiple machines are required for filling, capping and packing of containers, the serial number of which machine is required to be declared in Table 6 of FORM GST SRM-I? | It is clarified that in a manufacturing process there may be different machines being used such as one for filling of packages, another for putting seal on the packages and another for final packing. The detail of that machine is required to be reported in Table 6 of FORM GST SRM- I which is being used for final packing of the packages of the specified goods. |
| 8. | In case of job work or contract manufacturing, which person shall be required to comply with the special procedure as notified vide Notification No. 04/2024-CT dated 05.01.2024? | It is clarified that the special procedure notified vide Notification No. 04/2024-CT dated 05.01.2024shall be applicable to all persons involved in manufacturing process including a job worker / contract manufacturer. However, if the job worker/ contract manufacturer is unregistered, then the liability to comply with the said special procedure will be of the concerned principal manufacturer. |
- It is requested that suitable trade notices may be issued to publicize the contents of this Circular.
- Difficulty, if any, in implementation of this Circular may please be brought to the notice of the Board. Hindi version would follow.
(Sanjay Mangal)
Pr. Commissioner (GST)
📚 Frequently Asked Questions (FAQs): Circular No. 208/02/2024 - GST
Q1. What is Circular No. 208/02/2024 - GST?
Answer:
Circular No. 208/02/2024-GST clarifies various practical issues relating to the special procedure prescribed under Notification No. 04/2024-Central Tax for manufacturers of specified commodities. It explains matters such as machine identification, electricity consumption details, Chartered Engineer certificates, SEZ applicability, job work, and GST SRM forms. The objective is to ensure uniform implementation of the law across India and reduce compliance-related confusion.
Q2. Which manufacturers are required to follow the special procedure?
Answer:
The special procedure applies only to registered manufacturers dealing in the specified commodities covered under Notification No. 04/2024-Central Tax. It is not applicable to every GST-registered manufacturer. Businesses should first verify whether their products are listed in the notification before implementing the GST SRM reporting requirements. If there is any uncertainty, obtaining professional guidance can help avoid unnecessary compliance errors.
Related: GST Registration – https://finodha.in/online-gst-registration/
Q3. What should a manufacturer do if the packing machine does not have a make, model number, or machine number?
Answer:
Many businesses actually face this issue because older or second-hand packing machines often do not have complete identification details. The circular clarifies that the make and model are optional. If the make is unavailable, the year of purchase may be declared as the make. However, the machine number is mandatory. If no machine number exists, the manufacturer may assign a unique numeric identification and report it in FORM GST SRM-I.
Q4. How should electricity consumption be reported if machine specifications are unavailable?
Answer:
If the electricity consumption rating is unavailable on the machine or in its records, the manufacturer can obtain a certificate from a Practising Chartered Engineer. The engineer should calculate the hourly electricity consumption and certify it in FORM GST SRM-III. This certificate must be uploaded along with FORM GST SRM-I, and the document details should also be reported in the prescribed table of the form.
Q5. Can one PDF contain multiple Chartered Engineer certificates?
Answer:
Yes. The circular specifically allows manufacturers to upload multiple Chartered Engineer certificates in a single PDF where more than one packing machine requires certification. This makes compliance easier for manufacturers operating several production lines and avoids uploading separate files for each machine. However, all supporting details should still be correctly reflected in FORM GST SRM-I.
Q6. What value should be reported for exported goods that do not have an MRP?
Answer:
Where a manufactured product does not carry an MRP, such as goods meant exclusively for export, the manufacturer should report the sale price in Column 8 of Table 9 of FORM GST SRM-II. This clarification removes uncertainty for exporters and contract manufacturers producing goods that are not intended for domestic retail sale.
Q7. Is the special procedure applicable to manufacturing units located in SEZs?
Answer:
No. The circular clearly states that the special procedure prescribed under Notification No. 04/2024-Central Tax does not apply to manufacturing units located in Special Economic Zones (SEZs). Businesses operating both inside and outside SEZs should carefully identify which units are covered to avoid unnecessary compliance or reporting under the GST SRM framework.
Q8. Does the special procedure apply to manual packing operations?
Answer:
No. The clarification confirms that manual packing operations using manual sealers or seamers are outside the scope of the special procedure. It also excludes manual post-harvest packing of tobacco leaves. If you look at it practically, this ensures that businesses using simple manual packing methods are not burdened with compliance requirements meant for mechanised packing operations.
Q9. Which machine should be reported if multiple machines are used in the manufacturing process?
Answer:
Many manufacturing units use separate machines for filling, sealing, and final packing. The circular clarifies that only the machine used for the final packing of the specified goods needs to be reported in Table 6 of FORM GST SRM-I. Businesses should therefore identify the last machine involved in the packaging process instead of reporting every machine used on the production line.
Q10. Who is responsible for compliance in job work or contract manufacturing?
Answer:
The special procedure applies to all persons involved in the manufacturing process, including job workers and contract manufacturers. However, where the job worker or contract manufacturer is not registered under GST, the responsibility to comply shifts to the principal manufacturer. Businesses should clearly define compliance responsibilities in their agreements to avoid disputes and missed filings.
Related: GST Compliance – https://finodha.in/gst-compliance/
Q11. Why did CBIC issue Circular No. 208/02/2024-GST?
Answer:
The circular was issued because several trade associations sought clarification on practical difficulties faced while implementing Notification No. 04/2024-Central Tax. Instead of changing the law, CBIC explained how existing provisions should be applied consistently. This helps manufacturers, tax officers, and GST professionals follow the same interpretation, thereby reducing compliance disputes and improving certainty in implementation.
Download PDF: Circular No. 208/02/2024 - GST
More Information: https://taxinformation.cbic.gov.in/
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