GST

GST Reverse Charge & TDS Changes from 1 Nov 2026: Scrap, Cooking Oil, Vehicles & More

New RCM on used cooking oil, plastic/tyre scrap and e-waste from unregistered suppliers; 2% TDS where the supplier is registered; scrap suppliers lose the registration exemption; vehicle-renting RCM aligned to 18%. Plus e-invoicing on RCM from Jan 2027.

—·7 min read
Effective
1 Nov 2026 (RCM/TDS) · 1 Jan 2027 (e-invoicing)
New RCM goods
Used cooking oil, plastic/tyre scrap, e-waste
The twist
Unregistered supplier → RCM; registered supplier → 2% TDS
Also
Vehicle-renting RCM aligned to 18%; scrap suppliers lose reg. exemption

The short version

  • From 1 November 2026, GST reverse charge (RCM) extends to used cooking oil, waste & scrap of plastics and tyres, and electrical/electronic waste when bought from an unregistered supplier — the registered recipient pays the tax. (Metal scrap has been under RCM since October 2024.)
  • If the supplier of these goods is registered, RCM does not apply — instead the registered recipient must deduct 2% TDS (Section 51) where the contract value exceeds ₹2.5 lakh (excluding GST).
  • Suppliers of these goods can no longer use the registration exemption meant for wholly-RCM suppliers — they must register once turnover crosses the Section 22 threshold.
  • Renting of motor vehicles to a body corporate: the RCM exclusion is re-aligned to the 18% rate (from 12%).
  • Separately, from 1 January 2027, e-invoicing extends to RCM supplies from unregistered suppliers and to import of services (for businesses above ₹5 crore turnover).

A cluster of GST notifications is about to reshape how businesses handle reverse charge and TDS — especially anyone dealing in scrap, used cooking oil, or renting vehicles to companies. The headline is that several new goods come under reverse charge from 1 November 2026, but the detail that really matters is the fork in the road: whether your supplier is registered or not now decides whether you pay tax under RCM or deduct 2% TDS. Get that wrong and you've either under-deducted or double-counted. Here's the full set of changes, in plain terms.

1. Reverse charge on used cooking oil, plastic/tyre scrap and e-waste

Via Notification No. 04/2026-Central Tax (Rate) (with matching IGST and UTGST notifications), from 1 November 2026, a registered person who receives the following goods from an unregistered supplier must pay GST on them under reverse charge:

GoodsHSN
Used cooking oil1518
Waste and scrap of plastics3915
Waste and scrap of tyres4004
Electrical and electronic waste and scrap8549

This mirrors the treatment already in force for metal scrap (Chapters 72–81), which came under reverse charge from unregistered suppliers in October 2024. In short, the scrap-and-waste RCM net is being widened well beyond metals.

2. Scrap suppliers lose the registration exemption

Through Notification No. 06/2026-Central Tax, suppliers of these goods (used cooking oil, plastic/tyre scrap, e-waste, and metal scrap) are removed from the registration exemption that applies to persons making only supplies on which the recipient pays RCM. The effect:

  • Above the threshold → must register. A supplier of these goods must take GST registration once aggregate turnover exceeds the Section 22 threshold — they can't shelter behind the "wholly-RCM, so exempt from registration" route.
  • Below the threshold → may stay unregistered. If turnover is under the threshold, the supplier can remain unregistered, and the registered recipient pays under reverse charge (per change 1 above).

3. The crucial fork: registered supplier means 2% TDS, not RCM

This is the part that causes the most confusion, so read it carefully. Notification No. 07/2026-Central Tax provides that where the supplier of these goods is registered, reverse charge does not apply. Instead, the registered recipient must deduct TDS under Section 51:

  • Rate: 2% of the taxable value (1% CGST + 1% SGST within a State; 2% IGST inter-State), excluding GST.
  • Threshold: only where the total value of taxable supply under a contract exceeds ₹2.5 lakh (excluding GST).

So the supplier's registration status decides the mechanism entirely:

Your supplier is…What the registered recipient does
UnregisteredPay GST under reverse charge (RCM) on the purchase
RegisteredNo RCM — supplier charges GST; recipient deducts 2% TDS (Section 51) if contract value > ₹2.5 lakh

Why this matters in practice

A scrap or used-cooking-oil buyer now has to check each supplier's GST status before deciding the tax treatment of the purchase. Buy from an unregistered vendor and you self-account for GST under RCM. Buy from a registered vendor on a contract above ₹2.5 lakh and you instead withhold 2% TDS and report it — the vendor charges GST normally. Treating both the same way is the classic error this change will throw up. (For metal scrap, this registered-supplier-TDS treatment has applied since October 2024.)

4. Renting of motor vehicles to a body corporate — RCM aligned to 18%

Via Notification No. 08/2026-Central Tax (Rate), the reverse charge entry for renting of a passenger motor vehicle (with fuel) by a person other than a body corporate to a body corporate is re-aligned to the 18% rate. The body corporate pays tax under reverse charge unless the supplier charges GST at 18% (the exclusion earlier referred to 12%). In rate terms, the carve-out shifts from central tax 6% to 9% — i.e., 12% to 18% total.

And from 1 January 2027: e-invoicing on reverse charge supplies

Separately, e-invoicing is being extended. So far it covered only supplies to registered persons and exports. From 1 January 2027, for registered persons whose aggregate turnover in any financial year from 2017-18 onwards exceeds ₹5 crore (exempt categories excluded), e-invoicing also covers:

  • Supplies on which tax is payable under reverse charge, where received from an unregistered supplier; and
  • Import of services.

Practically, the recipient's self-invoice for these supplies — already required within 30 days of receipt under Rule 47A — must now also be generated on the Invoice Registration Portal (IRP) under supply type RCMDOM (domestic RCM) or RCMIMP (import of services). We've covered the mechanics of this self-invoicing-on-IRP change in detail in a separate post — this is the notification that puts a firm date on it.

What businesses should do before 1 November

  1. Map your scrap / used-cooking-oil / e-waste purchases. For each vendor, record whether they're GST-registered — that single fact now decides RCM vs TDS.
  2. Set up RCM self-accounting for purchases from unregistered vendors of these goods, including the self-invoice under Rule 47A.
  3. Configure 2% TDS (Section 51) for purchases from registered vendors where the contract crosses ₹2.5 lakh — and get your GST TDS registration/returns (GSTR-7) in order if not already.
  4. Scrap/UCO suppliers: check your registration. If your turnover is over the Section 22 threshold, you can no longer stay unregistered on the "wholly-RCM" exemption — register in time.
  5. Body corporates renting vehicles: review your vehicle-rental contracts and the GST rate the supplier charges to confirm the correct RCM position from 1 November.
  6. ₹5 crore+ businesses: plan now for e-invoicing of RCM-from-unregistered and import-of-services self-invoices from 1 January 2027.

Frequently asked

Which new goods come under reverse charge from 1 November 2026?
Used cooking oil (HSN 1518), waste and scrap of plastics (3915), waste and scrap of tyres (4004), and electrical/electronic waste and scrap (8549) — when supplied by an unregistered person to a registered person (Notification 04/2026-Central Tax (Rate)). Metal scrap has been under RCM since October 2024.
If I buy scrap from a registered dealer, do I pay RCM?
No. When the supplier is registered, RCM doesn't apply — the supplier charges GST, and you (if registered) deduct 2% TDS under Section 51 where the contract value exceeds ₹2.5 lakh (excluding GST). RCM applies only when the supplier is unregistered.
What is the TDS rate and threshold on these goods?
2% of the taxable value excluding GST — split 1% CGST + 1% SGST within a State, or 2% IGST inter-State — deducted by the registered recipient where the total taxable supply under a contract exceeds ₹2.5 lakh (Notification 07/2026-Central Tax, Section 51).
Can a small scrap supplier still avoid GST registration?
Only if turnover is below the Section 22 threshold. The registration exemption for persons making only RCM supplies no longer covers these scrap/used-cooking-oil/e-waste suppliers (Notification 06/2026-Central Tax), so above the threshold, registration is mandatory.
What changed for renting motor vehicles to a company?
The RCM entry is aligned to 18%. A body corporate renting a passenger vehicle (with fuel) from a non-body-corporate pays under RCM unless the supplier charges GST at 18% (the exclusion earlier referred to 12%), per Notification 08/2026-Central Tax (Rate).
When does e-invoicing on reverse charge supplies start?
From 1 January 2027, for registered persons with aggregate turnover above ₹5 crore in any FY from 2017-18. It covers RCM supplies from unregistered suppliers and import of services; the self-invoice must be generated on the IRP under supply type RCMDOM or RCMIMP.

Dealing in scrap, used cooking oil, or vehicle rentals?

efiletax sets up your RCM self-accounting, GST TDS (Section 51 / GSTR-7), supplier-status mapping and e-invoicing — so you apply the right mechanism to every purchase from 1 November.

Talk to our GST team

Disclaimer: This article summarises GST amendments effective 1 November 2026 extending reverse charge to used cooking oil and specified waste and scrap from unregistered suppliers (Notification 04/2026-Central Tax (Rate)), removing the registration exemption for such suppliers (06/2026-Central Tax), introducing 2% TDS under Section 51 where the supplier is registered (07/2026-Central Tax), and aligning the renting-of-motor-vehicle reverse charge to the 18% rate (08/2026-Central Tax (Rate)), together with the extension of e-invoicing to reverse charge supplies and import of services from 1 January 2027. It is based on information available as at the date of publication and is for general understanding only — please refer to the official notifications and verify HSN coverage, thresholds and your specific facts before acting. This is not legal or tax advice; consult a qualified professional. Talk to efiletax if you need help.

#GST#Reverse Charge#RCM#TDS#Section 51#Scrap#E-invoicing