Keeping in view of the complete lockdown in the country due to Covid-19, the representatives of the below-mentioned 13 Associations had recently organised a meeting to assess its impact on the industry and how to address the unprecedented challenges. During detailed discussions, the representatives had made several observations on the subject matter and taking in view all aspects of the current situation and the post-lockdown impact, it was decided by the representatives that the following recommendations should be conveyed to the Government of India through the concerned Ministries including PMO, which are absolutely necessary as immediate relief for reviving the Industry –
- Graphic Arts and Packaging Industry (Printing, Packaging, Corrugation, Label, Screen Printing, Inks & Consumables, Authentic Solutions, etc.) should be included in essential sector.
- Extension of financial year and advance tax: It is proposed to extend the financial year up to 31st July 2020 instead of 31st March 2020. Even after the normalisation of the prevailing conditions, it will take considerable time for the industry to come back to the normal position. Similarly, advance income tax payments of June, Sept, Dec should be shifted to March 2021 as Instalments without interest or Penalty since firms cannot estimate the profits for the year 2020-21.
- Liability of workforce on Entrepreneurs: practically it is not possible for entrepreneurs to take overall responsibility of workers from Corona virus infection, as movement of material and staff are common in the production of any product. order.
- Govt should provide quarantine facilities for migrant workers, in coordination with MSME units, for 14 days before working in factories.
- Wages, Salary, Bonus, ESI and PF: Considering the advice of the Government of India and the State Governments, the Members of the Associations/Federations have already paid the salary of March 2020 to the workers. However, it is not possible for the entrepreneurs to bear the burden of wages for the coming months, particularly by the MSME Units, due to severe financial constraints. In this context the following submissions should be considered for implementation: a. ESI benefit of Medical Leave to workers: As per provisions of ESIC Act, any person insured with ESIC, is entitled to get salary against medical leave, based on the Medical Certificate issued by a Medical practitioner, duly registered with ESIC. In the present scenario of lockdown, due to COVID-19, the absence of the employees from the workplace should be treated as medical leave and 100% wages and salaries for the lockdown period should be paid by ESIC. ESIC has enough funds. b. ESI, PF and Bonus: The Government should grant exemption to the Industry from making payment/contribution towards ESI, EPF and Bonus for the entire lockdown period, whether complete or partial. The Government should also bear EPF contribution at least for a period of 9 months, without limitation of Rs 15,000/- ceiling, in respect of all eligible units, irrespective of number of people employed or the turnover. All eligible MSME Units should also be permitted to pay arrears of ESIC, EPF contribution in 9 monthly installments and ensure that all legal actions contemplated or being taken are dropped/withdrawn against the concerned defaulting MSME units, if any. c. Allow Salary and Wages to be reduced by 30%, for all other employees who are not covered under ESIC, in line with the Government’s announcement of a pay cut of 30%, for the entire lockdown period. d. Shifts of 12 hours should be permitted/allowed, where partial relaxation/exemption has been given to industrial units for operation, as these Units cannot operate with full workforce due to social distancing. e. Most of the MSME Units employ migrant labour from different areas within the State or from other States. Due to lockdown, most of the workforce have already left for their home States. Once the lockdown is lifted partially or completely, the MSME Units will again face a problem of shortage of workforce. The Government should devise a special package for the workforce/labour to return to the workplace.
- Electricity, Water, Property Tax and other Utilities:a. State Governments should advise all DISCOMS and Water Supply Boards to waive of the fixed charges for the lockdown period. Only actual consumption charges should be collected for this period. b. Allow payments up to 31st July ’20 without any levy of interest for Electricity/Water bills payable for the period 1st March ’20 to 30th June ’20. c. State Governments should also advise all Municipal Corporations to extend the due date for payment of Property Taxes, Corporation Taxes etc. till 31st December’20. d. State Governments should also advise their respective State Pollution Control Boards to defer Compliances under the State Pollution Control Acts till 31st Dececember’20.
- Machine Maintenance: Due to lockdown, the plant & machines have remained completely in shut-down condition for almost a month. It is, therefore, requested to allow all Graphic Arts & Packaging Industrial units to carry out repairs/maintenance, with bare minimum staff. It will help to run the plant and machinery immediately after lifting of the lockdown.
- Raw Material issues:a. The Government should monitor the prices of raw material during or post-lockdown period so that the industrial units do not face undue hardships.b. Imported Consignments of Graphic Arts and Packaging Industry should be allowed to be cleared by Customs on top priority, without detention or demurrage charges.c. The import of Paper, which are not being manufactured in India, should be allowed dutyfree at least till 31st March 2021.
- All commercial vehicles should be allowed toll free movement till August 2020.
- Cash Flow, Working Capital and Interest:a. Bank interest levied on the finances which are taken by the Industrial units to meet their requirement of working capital and that they make best use of the same for the growth and development of the business. As everything is on hold, therefore, it is requested to give relaxation on the bank interest too. b. To Extend Ad hoc Working Capital – WCTL to the extent of 25-30% on the existing Working Capital limits, by all Public and Private Sector banks, without exception and with Interest subvention or @ 6% p.a. The same can be repaid in 36/48 months. This will ensure adequate cash flow for restarting and continuity of operations.c. In respect of existing Working Capital, Term Loans etc., Banks have been permitted to defer the Interest and Installments for the period 1st March’20 to 30 th May ’20. The accumulated Interest should be recovered after 30 th May ’20, otherwise it will create cash problems for the industrial units to operate. The recovery should be made in instalments. All Banks in Public or Private sector should be directed to defer the Interest and Installments of loans till 31st Dec’20 which should be recovered subsequently in 9 installments, over a period of 18 months, at a concessional rate of 6%. Interest subvention should be given by the Government. Moratorium should also be extended to LCs and Bank Guarantees which have fallen due in the lockdown period on the same basis. The banks and Financial institutions should be directed not to take adverse action against MSME units and relax the conditions related to maintenance of minimum balance against working capital limits obtained to run the businesses for at-least 90 days.10. 10
- Special Credit Linked Capital Subsidy Scheme and CC/OD:a. The due dates for filing the application under CLCSS for the financial years 17-18, 18-19 and 19-20 was 31st March’20. We request that those MSME Units who have not been able to file their application by the due date, owing to lockdown etc., be allowed to do so till 30th Sep’20. b. Nonpayment of CC or OD interest lead to NPA, it should be liberalized or Interest on loans and CC/OD limits should be waived off by 50% for next six months.
- Compliance under GST, Income Tax, FEMA etc: a. The ministry has allowed vide notification no. 35/2020- Central Tax dated 03.04.2020 a date extension till 30th June 2020 for compliance of action under GST. Also vide notification no. 31/2020-Central Tax has allowed NIL interest rate for first 15 days after due date of filing return in Form GSTR-3B and 9% thereafter till 30th June 2020. Since the lockdown has been extended till 3rd May 2020, it will be extremely difficult to submit GSTR-3B in the remaining 2 days till the expiry of interest free days, we therefore seek your support for request to ministry to extend this period till 30th May 2020 or further extended lockdown period particularly for the traders whose turnover is above Rs. 5 Cr. in connection to submission of GST returns and payment. b. Ongoing Pandemic has globally affected all the trades, all timebound commitments under Foreign Exchange Management Act (FEMA) such as collections from foreign debtors, export commitments, payment to foreign creditors, etc which may be falling due between 15th March 2020 to 30th April 2020 should be extended by 90 days from date of it being due. c. In case some LC opened for import of machines and raw materials, and it could not be honored due to pandemic, such deadlines should be extended for 90 days or converted into Term Loan. d. All the deadlines relating to the Government taxes should be extended up to September 2020 and penalties, if any, should be waved off. Government should extend GST return filing date for all MSMEs till 31st March 2021 and waive off late filing fees, penalty etc. The interest for late payments may be charged @ 6%. Government should also permit payment of arrears of GST by all MSMEs in installments, till 31st March 2021. The GSTR-9 and GSTR-9C return filing dates should be extended till 30th September 2020. e. Either the Bills issued during the lockdown period should be honored by the purchaser, or the Government should allow GST inputs on cancellation of these bills. Industry believes that the implementation of the above recommendations will not only help in the revival of the industry but will also bring it on its original track.
List of Associations/Federations:
AIDC Technologies Association of India Delhi
All India Federation of Masters’ Printers. (AIFMP) Delhi
All India Printing Ink Manufacturers’ Association. (AIPIMA) Maharashtra
Association of Label Printers and Suppliers. (ALPS) Delhi
Authentication Solution Providers’ Association (ASPA) Delhi
Federation of Corrugated Box Manufacturers (FCBM) Maharashtra
Federation of Paper Traders’ Association (FPTA) Maharashtra
Indian Flexible Packaging & Folding Carton Manufacturers Association (IFCA) Maharashtra
Indian Printing Packaging and Allied Machinery Manufacturers’ Association. (IPAMA) Delhi
The Institute of Packaging Machinery Manufacturers of India (IPMMI) Maharashtra
Label Manufacturers Association of India (LMAI) Mumbai
The Regional Institute of Printing Technology Alumni Association. (RIPTAA) West Bengal
Screen Printers’ Association of India (SPAI) Maharashtra