As per Warehousing (Development and Regulation) Registration of Warehouses Rules, 2017 notification dated February 23, 2017, it is mandatory for every warehouseman to register with e-negotiable warehouse receipt repository. Further, with effect from such date as may be specified by WDRA, no warehouseman shall issue any negotiable warehouse receipts in physical form, and shall register with one or more repositories registered with WDRA for issuing negotiable warehouse receipts in electronic form. National E- Repository Limited is registered repository with WDRA.
As per WDRA guidelines a warehouseman/Warehouse Service provider may use the NERL system for which is created for:-
- enabling safe and accurate creation, storage, maintenance and cancellation of electronic Negotiable Warehouse Receipts;
- enabling the delivery of goods in part or full, underlying the electronic Negotiable Warehouse Receipts, through the warehousemen;
- A warehouseman is eligible for becoming a Repository Participant –Account Maintenance if it meets the requirements as specified by NERL, Provided that a Warehouseman shall adhere to following conditions:
- A Warehouseman shall segregate its operations as the Repository Participant from its warehouse operations completely that shall include both at the technological and operational level.
- Warehouseman may facilitate opening of Client account for farmers if and only if Repository Participant conducts Biometric or OTP based verification of AADHAR
- Warehouseman shall have necessary infrastructure like web-camera etc. to enable in-person verification by the Repository Participant’s authorized personnel.
Apart from other important matters, these rules also contains the general obligations of a warehouseman to:-
- issue a negotiable warehouse receipt only in respect of such goods that have been specified by the Authority from time to time;
- deliver the goods referred to in a negotiable warehouse receipt, to the holder of the negotiable warehouse receipt on demand made by the holder after satisfying the warehousing lien;
- ensure that the negotiable warehouse receipt holder, on receiving the goods from the warehouseman, acknowledges the receipt of the goods in a form and manner required by the Authority;
- take necessary actions to maintain the quality and quantity of goods stored in the warehouse;
- maintain and record a complete and accurate set of records and accounts of all transactions pertaining to the operation of a registered warehouse as per the requirements that the Authority may specify from time to time;
- ensure that the physical inventory tallies exactly with the record;
- maintain effective control of all registered warehouse storage space;
- provide necessary assistance in the execution of inspections and audits by the Authority;
- resolve grievances efficaciously;
- not differentiate among depositors regarding use of and access to a warehouse;
- . not store goods belonging to itself in a registered warehouse; and
- not sell, remove or dispose of the goods deposited in a registered warehouse except as permitted under the Act.
Onboarding of Warehouseman/WSP:
Every Warehouse registered under WDRA shall be eligible to become a User of NERL Repository System for generation and cancellation of Electronic Negotiable Warehouse Receipts. On receipt of information about completion of registration process with WDRA, NERL would issue unique administrator user ID for access to use the Repository System to the Warehouse Service Provider who in turn would be entitled to create user ID’s for its respective Warehousemen.
Activities to be carried out on NERL platform:-
NERL would give complete user manual to all WSP and other support as may be required for carrying out transactions on NERL platform effectively.
Warehouse stock reconciliation:-
As directed by WDRA, NERL would provide complete information for enabling WSP to carry out stock reconciliation and confirmation on daily basis. Please refer the user manual for further details on the process to be followed for reconciliation.
Warehouse Rent Collection Services:
NERL would provide additional voluntary services to Warehouse Service Provider for collection of warehousing rent through the Repository System by entering into a separate agreement with the Warehouse Service Provider. Further, the voluntary services shall be provided by the concerned Repository Participant where Clients have Page 3 of 3 opened accounts and given their consent for use of such facility for collecting warehousing rent by the Warehouseman through the Repository System.
Compliance with WDRA directives
Warehouseman/Warehouse Service Providers need to comply with all the regulatory directives issued by WDRA at all times. The indicative list is given below for information.
- The Warehousing (Development and Regulation) Act, 2007
- The Warehousing (Development and Regulation) Registration of Warehouses Rules, 2017
- Procedures for registration of warehouses
- Warehouse manual
- Compliances with inspection requirement
- Compliance with security deposit requirement
- Compliance with insurance requirement
- Compliance with net worth requirement etc.