How to generate e-way bill for unregistered person

Implementation of e-way bill mechanism under GST is a landmark development and a step of Government towards controlling unauthorized and clandestine movement of goods. Under E-Way Bill system, e-way bill is mandatory to be generated where the value of consignment exceeds Rs. 50,000. In such case, the registered person causing the movement of goods shall generate the e-way bill through E-way Bill Portal. A major part of business in India is under unorganized sector and being dominated by unregistered small traders. So, a basic question in this case arises as:-

"Is an e-way bill required to be generated where goods are supplied by an unregistered supplier?" 

GST Act provides detailed rules for e-way bill where goods are supplied by or to unregistered dealers. There may be following possibilities in this issue:-
(a) Supplier is unregistered but recipient is registered:
          (i)  Recipient is known at the time of commencement of movement of goods
          (ii) Recipient is not known at the time of commencement of movement of goods
(b) Both supplier and receipient are unregistered

(a) Supplier is unregistered but Recipient is registered:-

GST Rules states that where the goods are supplied by an unregistered supplier to a registered recipient, the movement shall be said to be caused by such recipient if the recipient is known at the time of commencement of the movement of goods. Thus, there may be two conditions therein:-
(i) Recipient is registered and known at the time of commencement of movement of goods
(ii) Recipient is registered but not known at the time of commencement of movement of goods

(i) Recipient is registered and known at the time of commencement of movement of goods:-

• In this case, it is deemed that movement of goods is caused by the recipient of goods. Hence, the recipient shall be responsible to generate e-way bill on the E-Way Bill Portal.
• The unregistered supplier or transporter are not liable to generate e-way bill, though they may at their option choose to generate the e-way bill.  

(ii) Recipient is registered but not known at the time of commencement of movement if goods:-

• In certain business models, unregistered supplier manufactures or buys the goods for sale and then transports it for sale to a market where they can get number of buyers (like in haat). In this situation, the buyer (recipient) is not known when the movement of goods commences. Later, the goods are sold to buyer (recipient) and is found to be registered.
• In such case, it is not mandatory to generate e-way bill.
• However, the unregistered supplier may choose at his option to generate the e-way bill through "Enrolment for Citizen" option on the E-Way Bill Portal.

(b) Both Supplier and the recipient are unregistered:-

• In this situation, e-way bill is not required to be generated.
• However, the unregistered supplier will have an option to generate the e-way bill through "Enrolment for Citizen" option on the E-Way Bill Portal.

However, it should be noted that where an unregistered handicraft dealer transports handicraft goods from one state to another, he shall be required to generate e-way bill irrespective of the value of consignment.