Section 148A of the Central Goods and Services Tax Act, 2017 introduces a statutory framework for a track and trace mechanism for certain goods. The provision enables the Government, on the recommendations of the GST Council, to specify particular goods and the persons or classes of persons dealing with those goods to which the mechanism will apply.
The provision is designed to improve the traceability of specified goods through the supply chain by using unique identification markings, electronic storage and access to information, prescribed records and, where applicable, information relating to manufacturing machinery.
Section 148A was inserted by the Finance Act, 2025 and brought into force from 1 October 2025 through Notification No. 16/2025-Central Tax dated 17 September 2025.
The provision is particularly relevant to sectors where the Government considers enhanced supply-chain visibility necessary for compliance and enforcement. The GST Council had earlier discussed the track-and-trace mechanism in the context of specified evasion-prone commodities and recommended an enabling provision in the CGST Act.
What Is Section 148A of the CGST Act?
Section 148A is titled “Track and trace mechanism for certain goods.”
The section gives the Government an enabling statutory framework under which, on the recommendations of the GST Council and through notification, it may specify:
- the goods covered by the mechanism; and
- the persons or classes of persons who are in possession of or deal with those goods.
Once goods and persons are brought within the notified framework, specified compliance requirements can apply, including:
- affixing a unique identification marking;
- furnishing information and details;
- maintaining prescribed records or documents;
- furnishing details relating to manufacturing machinery; and
- paying any prescribed amount relating to the track-and-trace system.
The important point is that Section 148A itself is an enabling provision. It does not automatically subject every product or every taxpayer in India to a track-and-trace system.
When Did Section 148A Come Into Force?
Section 148A was introduced through the Finance Act, 2025.
The Government subsequently notified its commencement from 1 October 2025 through Notification No. 16/2025-Central Tax dated 17 September 2025.
Therefore, Section 148A forms part of the current CGST Act framework from 1 October 2025.
The same legislative change also introduced the definition of “unique identification marking” in Section 2(116A). That definition covers a digital stamp, digital mark or similar marking that is unique, secure and non-removable.
Why Was Section 148A Introduced?
The GST Council had considered the need for a technological system to improve monitoring of specified goods, particularly commodities considered vulnerable to tax leakage.
The Council’s 55th meeting agenda recorded the earlier recommendation for a system under which specified products could carry unique identifiers and relevant information could be captured and made available for enforcement purposes.
The proposed mechanism was intended to provide better visibility over the movement of specified products through the supply chain.
The Council’s material discussed a system involving:
- unique identification of individual units or packages;
- electronic recording of relevant information;
- updating information during movement through the supply chain;
- authentication of identifiers when goods are received;
- access to relevant information by enforcement authorities; and
- measures designed to make the identifiers difficult to remove or tamper with.
Section 148A provides the statutory foundation for implementing such a mechanism.
Section 148A(1) – Government Can Specify Goods and Persons
Section 148A(1) is the starting point of the track-and-trace framework.
It provides that the Government may, on the recommendations of the GST Council and by notification, specify:
1. The Goods
The Government can identify the goods to which the track-and-trace mechanism will apply.
This means that Section 148A is product-specific, rather than automatically applying to every supply of goods under GST.
2. Persons or Classes of Persons
The Government can also specify the persons or classes of persons who are in possession of or deal with those goods.
Therefore, the applicability of Section 148A depends on both:
- the goods specified; and
- the persons or classes of persons specified.
Why Notification Is Important
Section 148A(1) does not itself list a permanent universal category of goods.
Instead, it gives the Government the power to specify the relevant goods and persons by notification, following the recommendation of the GST Council.
This provides flexibility to introduce the mechanism for particular commodities or sectors as required.
Therefore, a business should not assume that merely because Section 148A exists, every product manufactured or traded by that business requires a unique identification marking.
The applicable notifications and prescribed requirements must be checked for the particular goods and person concerned.
Section 148A(2) – Track and Trace System
Section 148A(2) deals with the system through which the unique identification mechanism can operate.
For the goods specified under Section 148A(1), the Government may:
- provide a system enabling the affixation of unique identification markings and electronic storage and access of information; and
- prescribe the unique identification marking, including the information that must be recorded in it.
This creates the technological and information framework for the mechanism.
What Is a Unique Identification Marking?
The expression “unique identification marking” is separately defined in Section 2(116A).
It means the unique identification marking referred to in Section 148A(2)(b) and includes:
- a digital stamp;
- a digital mark; or
- any other similar marking,
provided that it is:
- unique;
- secure; and
- non-removable.
This definition is important because the mechanism is not restricted to one particular physical type of marking.
The statutory definition allows the Government to prescribe an appropriate technological marking system for the goods covered by the mechanism.
What Information Can Be Included in the Unique Identification Marking?
Section 148A(2)(b) authorises the Government to prescribe the unique identification marking, including the information to be recorded therein.
The exact information depends on the applicable prescribed framework.
The GST Council’s earlier track-and-trace proposal discussed information such as:
- date of manufacture;
- place and factory of manufacture;
- machine used for manufacture;
- production shift or time;
- product description;
- quantity;
- maximum retail price;
- intended retail market; and
- other relevant information.
These were part of the Council’s proposed design considerations. The actual legal requirements for a particular commodity depend on the notifications and rules issued under the enacted framework.
Section 148A(3) – Responsibilities of Specified Persons
Section 148A(3) imposes the principal compliance responsibilities on persons covered by Section 148A(1).
These responsibilities are divided into four clauses.
Section 148A(3)(a) – Affixing the Unique Identification Marking
Covered persons must affix on the specified goods or packages thereof a unique identification marking containing the prescribed information and in the prescribed manner.
Therefore, where the track-and-trace mechanism has been made applicable to particular goods and persons, the marking requirement becomes a statutory compliance responsibility.
The marking may be required on:
- the goods themselves; or
- packages containing those goods,
depending on the prescribed requirements.
Section 148A(3)(b) – Furnishing Information and Maintaining Records
Covered persons must also:
- furnish information and details within the prescribed time;
- maintain records or documents; and
- follow the prescribed form and manner.
This means the track-and-trace mechanism is not limited to placing a code or marking on a product.
The businesses covered by the system may also have continuing information and record-keeping responsibilities.
The exact nature, format and timing of those records will depend on the applicable rules and notifications.
Section 148A(3)(c) – Manufacturing Machinery Details
One of the distinctive features of Section 148A is the requirement concerning machinery used for manufacturing specified goods.
Covered persons may be required to furnish details of machinery installed at the place of business of manufacture of the specified goods.
The information can include:
- identification of the machinery;
- manufacturing capacity;
- duration of operation; and
- other prescribed details or information.
The information must be furnished within the prescribed time and in the prescribed form and manner.
This provision can help authorities compare production-related information with the movement and supply-chain information recorded through the track-and-trace system.
Section 148A(3)(d) – Payment of Prescribed Amount
Covered persons may also be required to pay an amount relating to the track-and-trace system.
The amount is not a universal amount specified directly in Section 148A.
Instead, Section 148A(3)(d) states that the amount is to be prescribed in relation to the system referred to in Section 148A(2).
Therefore, businesses should look at the applicable rules or notifications to determine whether a payment obligation applies to them and, if so, the applicable amount and procedure.
How Does the Track and Trace Mechanism Work?
At a conceptual level, the system can be understood as a chain of identification and information.
A simplified process is:
Specified goods → Unique identification marking → Information recorded → Movement through supply chain → Information available electronically → Verification and enforcement
The GST Council’s earlier proposal contemplated unique identifiers being attached to specified products and information being recorded electronically so that the movement of products could be tracked through relevant stages of the supply chain.
The exact operational procedure depends on the goods, persons and system notified under the law.
Example of Track and Trace
Suppose a particular category of goods is notified under Section 148A.
A manufacturer producing those goods may be required to:
- generate or use the prescribed unique identification marking;
- affix it to the specified goods or packages;
- record prescribed production information;
- maintain required records;
- furnish required information electronically;
- provide prescribed machinery details; and
- comply with any prescribed payment requirement.
When the goods move through the supply chain, the prescribed system can enable relevant information to be associated with the identified goods.
This allows authorities to verify information concerning the goods more effectively.
Track and Trace Is Different From E-Way Bill
Section 148A should not be confused with the e-way bill system under GST.
An e-way bill primarily facilitates the electronic documentation and monitoring of the movement of goods in accordance with the applicable GST rules.
The track-and-trace mechanism under Section 148A is different because it focuses on identifying specified goods or their packages through unique identification markings and maintaining/accessing related information.
The two systems can therefore serve different compliance and enforcement purposes.
A business covered by Section 148A may have to comply with the track-and-trace requirements in addition to other applicable GST requirements.
Track and Trace Is Different From GST Invoice
A tax invoice identifies the supplier, recipient, goods or services, taxable value, tax and other prescribed particulars.
A unique identification marking under Section 148A serves a different purpose.
It is connected with the identification and traceability of specified goods or packages and the information prescribed for the track-and-trace mechanism.
Therefore, a unique identification marking should not be treated as a replacement for a GST tax invoice.
Section 148A and Supply Chain Monitoring
The broader objective of the mechanism is to improve visibility over the movement of specified products.
The GST Council’s discussion contemplated the recording of relevant movements throughout the supply chain and making information available for enforcement purposes.
This can potentially help authorities identify inconsistencies between:
- manufacturing information;
- product identifiers;
- movement records;
- supply-chain information; and
- tax-related information.
The exact information available to authorities will depend on the prescribed system.
Section 148A and Manufacturing Units
Manufacturers may have additional compliance considerations because Section 148A(3)(c) specifically refers to machinery installed at the place of business of manufacture.
Where applicable, information concerning machinery may include:
- machinery identification;
- production capacity;
- operating duration; and
- other prescribed details.
This means the mechanism can extend beyond finished-product identification to information about the manufacturing process itself.
Section 148A and Importers
The GST Council’s earlier proposal considered the possibility of applying unique identifiers to both domestically manufactured and imported specified products.
However, the actual applicability to importers depends on the goods and persons specified by the Government and the detailed rules or notifications governing the mechanism.
Businesses dealing with specified imported products should therefore examine the applicable notification rather than assuming that every imported product automatically falls within Section 148A.
Section 148A and Wholesalers or Dealers
Section 148A(1) allows the Government to specify persons or classes of persons who are in possession of or deal with specified goods.
Therefore, the compliance framework is not necessarily restricted to manufacturers.
Depending on the applicable notification, persons involved at different stages of the supply chain may fall within the notified category.
The exact obligations should be determined from the notification and prescribed procedures applicable to the relevant goods.
Is Every Business Required to Use Track and Trace?
No.
Section 148A is not a blanket requirement applicable to every business.
The Government must specify:
- the relevant goods; and
- the persons or classes of persons to which the section applies,
through notification on the recommendations of the GST Council.
Therefore, a normal retailer or manufacturer dealing in goods that are not covered by the relevant notification does not become subject to Section 148A merely because the section exists in the CGST Act.
Is Every Product Required to Have a Unique Identifier?
No.
The unique identification marking requirement applies to goods brought within the Section 148A framework.
The Government first specifies the goods and relevant persons under Section 148A(1), and the prescribed marking system then operates for those goods.
The statutory framework is therefore targeted rather than universal.
Role of the GST Council
The GST Council plays an important role because Section 148A requires the Government to act on the recommendations of the Council when specifying the goods and persons covered by the mechanism.
This is consistent with the broader GST legislative framework in which the Council recommends measures relating to GST administration and compliance.
The GST Council’s 55th meeting agenda specifically records the development of the track-and-trace proposal and the recommendation to create an enabling provision in the CGST Act.
Section 148A and the Definition of Unique Identification Marking
The introduction of Section 148A was accompanied by the insertion of Section 2(116A).
Section 2(116A) defines unique identification marking as the marking referred to in Section 148A(2)(b), including:
- digital stamp;
- digital mark; or
- similar marking,
which is unique, secure and non-removable.
This creates a direct connection between:
Section 2(116A) → Definition
Section 148A → Track-and-trace mechanism
Section 148A and Section 122B
Section 148A should also be read with the related penalty provision introduced as Section 122B.
The GST Council’s legislative proposal specifically contemplated a separate penalty provision for failure to comply with the track-and-trace mechanism.
The current CGST Act includes Section 122B, which is titled “Penalty for failure to comply with track and trace mechanism.”
Therefore, businesses covered by Section 148A should not treat the marking and record requirements as merely voluntary compliance measures.
The consequences of non-compliance must be examined together with Section 122B and the applicable rules.
Section 148A and Section 148
Section 148 and Section 148A are both located in Chapter XXI of the CGST Act, but they serve different purposes.
Section 148
Section 148 allows the Government, on the recommendations of the GST Council, to notify special procedures for certain classes of registered persons and specify procedures relating to matters such as registration, returns, payment of tax and administration.
Section 148A
Section 148A specifically deals with the track-and-trace mechanism for certain goods.
Therefore:
Section 148 → Special procedure
Section 148A → Track and trace of specified goods
Section 148A and Section 149
Section 149 deals with the GST compliance rating framework.
Section 148A is different because it focuses on tracking and identifying specified goods.
Therefore, the two provisions should not be confused.
Section 148A and Section 150
Section 150 deals with the obligation to furnish information returns by specified persons and entities.
Section 148A, by contrast, focuses on the track-and-trace mechanism for specified goods.
Both are information-oriented provisions, but they operate for different statutory purposes.
Practical Compliance Checklist for Businesses
A business dealing with goods potentially covered by Section 148A should consider the following steps:
1. Identify Whether the Goods Are Notified
Check whether the particular goods fall within a notification issued under Section 148A(1).
2. Identify Whether the Business Is Covered
Determine whether the business falls within the persons or class of persons specified by the Government.
3. Understand the Unique Identification Marking
Review the prescribed format, technology and information requirements.
4. Prepare the Marking Process
Where applicable, ensure that the marking can be affixed to the specified goods or packages in the prescribed manner.
5. Maintain Required Records
Establish systems for maintaining information and documents required under the applicable rules.
6. Maintain Manufacturing Information
Manufacturers covered by the provision should be prepared to furnish the required machinery information.
7. Integrate Information Systems
Where electronic storage or transmission is prescribed, accounting, production and supply-chain systems may need to be integrated appropriately.
8. Monitor Notifications and Rules
Section 148A is an enabling provision. Detailed compliance requirements depend on the applicable notifications and prescribed procedures.
9. Review Penalty Provisions
Businesses should understand the consequences of non-compliance, including the provisions of Section 122B where applicable.
Practical Example – Manufacturer of Specified Goods
Suppose the Government notifies a particular category of goods under Section 148A and specifies manufacturers dealing with those goods.
A manufacturer falling within the notified class may have to:
- affix unique identification markings;
- maintain prescribed information;
- furnish required details;
- provide information about manufacturing machinery;
- maintain the prescribed records; and
- comply with any prescribed payment requirement.
The manufacturer would also need to comply with other applicable GST provisions, such as invoicing, returns, e-way bills and tax payment requirements.
Section 148A therefore creates an additional traceability layer, rather than replacing ordinary GST compliance.
Practical Example – Dealer in Specified Goods
Suppose a dealer is included within the class of persons specified under a Section 148A notification.
The dealer may have obligations concerning the prescribed information and records associated with the goods.
The exact responsibilities depend on the notification and rules applicable to that class of person.
The dealer should therefore determine whether the applicable framework requires action at the point of receipt, storage, onward supply or another stage of the supply chain.
Practical Example – Change in Manufacturing Machinery
Suppose a manufacturer covered by Section 148A installs a new production machine.
Where the applicable rules require machinery details to be furnished, the manufacturer may need to update the prescribed information regarding:
- machine identification;
- capacity;
- duration of operation; and
- other prescribed particulars.
The exact reporting requirement depends on the applicable rules.
Benefits of a Track and Trace Mechanism
A properly implemented track-and-trace system can provide several compliance and enforcement benefits.
Better Product Traceability
A unique identifier can help associate a product or package with relevant information.
Supply Chain Visibility
Electronic information can provide greater visibility into the movement of specified goods.
Manufacturing Monitoring
Where machinery information is required, production-related information can provide an additional compliance reference point.
Enforcement Support
The GST Council’s proposal specifically contemplated making relevant data accessible to officers for enforcement purposes.
Reduced Scope for Unrecorded Movement
A robust identification system can make it more difficult to move specified products through the supply chain without leaving the prescribed information trail.
Limitations and Compliance Considerations
A track-and-trace system also requires businesses to develop appropriate technological and operational processes.
Businesses may need to consider:
- software integration;
- marking equipment;
- data storage;
- data accuracy;
- security;
- supply-chain coordination;
- record retention;
- system downtime;
- reconciliation of identifiers; and
- employee training.
The exact requirements will depend on the notified goods and prescribed system.
Important Points to Remember About Section 148A
The major points of Section 148A can be summarised as follows:
- Section 148A deals with the track and trace mechanism for certain goods.
- It was inserted into the CGST Act through the Finance Act, 2025.
- It came into force from 1 October 2025.
- The Government may specify the goods covered by the mechanism.
- The Government may also specify the persons or classes of persons dealing with those goods.
- The specification is made by notification on the recommendations of the GST Council.
- The Government may provide a system for unique identification markings.
- The system may provide for electronic storage and access to information.
- The Government may prescribe the unique identification marking.
- The marking can include prescribed information.
- Covered persons may be required to affix the marking to goods or packages.
- Covered persons may have to furnish prescribed information and details.
- They may also have to maintain prescribed records and documents.
- Manufacturers covered by the mechanism may have to furnish prescribed details of machinery installed at the place of manufacture.
- Machinery information can include identification, capacity and duration of operation.
- Covered persons may be required to pay a prescribed amount relating to the track-and-trace system.
- “Unique identification marking” is defined in Section 2(116A).
- The definition includes a digital stamp, digital mark or similar unique, secure and non-removable marking.
- Section 148A does not automatically apply to every product or every taxpayer.
- The actual applicability depends on the goods and persons specified through the relevant notification.
- Section 148A is different from the e-way bill system.
- Section 148A is also different from the GST tax invoice system.
- The provision is intended to strengthen traceability of specified goods through the supply chain.
- Section 148A should be read along with the related penalty provision under Section 122B.
- Businesses covered by the mechanism should monitor the relevant notifications, rules and prescribed procedures.
Conclusion
Section 148A of the CGST Act establishes the statutory foundation for a track-and-trace mechanism for specified goods. It was introduced through the Finance Act, 2025 and became effective from 1 October 2025.
The provision allows the Government, on the recommendations of the GST Council, to specify particular goods and the persons or classes of persons dealing with those goods to which the mechanism will apply. This targeted approach means that Section 148A does not automatically impose track-and-trace requirements on every GST-registered business.
For goods and persons brought within the notified framework, the Government can provide a system for unique identification markings and electronic storage and access of related information. Covered persons may be required to affix the prescribed marking to goods or packages, furnish information, maintain records and provide prescribed details about manufacturing machinery. They may also be required to pay an amount prescribed in relation to the system.
The concept of a unique identification marking is separately recognised in Section 2(116A), which includes a digital stamp, digital mark or similar marking that is unique, secure and non-removable.
The background to Section 148A lies in the GST Council’s consideration of technological measures for improving traceability and addressing revenue leakage in specified sectors. The Council’s earlier proposal contemplated unique identifiers, electronic information storage, supply-chain tracking and access to relevant information for enforcement purposes.
For businesses, the most important point is that Section 148A is an enabling provision and its practical obligations depend on the goods, persons, notifications and prescribed procedures applicable to the particular case. A business should therefore verify whether its products and activities have actually been brought within the track-and-trace framework before determining the specific compliance requirements.
Based on Google's Helpful Content System, this article emphasizes user value, transparency, and accuracy. It incorporates principles of E-E-A-T (Experience, Expertise, Authoritativeness, Trustworthiness).
Why Choose Sarkari Bakery?
Official Information
Government schemes & banking information based on official sources.
Step-by-Step Guides
Simple application process explained for every service.
Regular Updates
Content updated whenever official rules or services change.
People-First Content
Helpful, transparent and user-focused content.