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Scrap, waste and manufacturing by-products

CA Finalist, ACCA FinalistReviewed by Chartered Advisory Team of Chartered Accountants
Sales tax guide: Sales tax on scrap, waste and by-products
Quick answer: Scrap, waste and by-products produced in the course of business are goods, so selling them is a taxable supply and sales tax applies on the consideration received. Certain scrap categories, such as some metal or plastic scrap, are subject to withholding or specific-rate regimes that should be checked, and the input tax already claimed on the raw materials is not disturbed by later selling the resulting scrap.

Manufacturing and processing generate scrap, offcuts, waste and by-products, and many businesses sell these on to recyclers and traders. Because it feels like disposing of leftovers, the sale is sometimes treated casually for tax. But scrap is goods, and selling goods is a taxable supply. There are also specific regimes for certain scrap categories, so this is worth handling deliberately.

Selling scrap is a taxable supply

Scrap, waste and by-products are goods. When a registered person sells them in the course of business, that is a taxable supply, and sales tax applies on the consideration received for the scrap. A manufacturer selling its production scrap to a recycler is making taxable supplies, in exactly the way it makes taxable supplies of its main products — the fact that scrap is a residual output does not put it outside the net. So scrap sales belong on the sales tax return as output, valued at what the scrap actually fetches. Treating scrap proceeds as if they were incidental cash outside the tax system is a common and correctable error.

Withholding and specific-rate regimes

Some scrap categories do not simply follow the ordinary rule. Certain kinds of scrap — some metal and plastic scrap, for example — have at various times been brought under withholding sales tax mechanisms or specific-rate regimes, reflecting the sector's compliance history. Under a withholding mechanism, the buyer may be required to withhold and deposit tax on the scrap purchase, which changes who accounts for it. Because these regimes are specific and subject to change, a business dealing in those categories should confirm the current treatment for its particular scrap rather than assume the general position holds. The practical point is to check whether your scrap falls into a special regime before setting your invoicing, because the mechanics can differ from an ordinary sale.

The input tax already claimed

A frequent worry is whether selling scrap disturbs the input tax already claimed on the raw materials. It does not. Input tax on materials used in production is not clawed back merely because part of the output emerged as scrap or a by-product — the materials were used in the taxable activity, and selling the resulting scrap is itself a taxable supply. This is the opposite of an obsolete-stock write-off, where goods never reach a taxable supply and an input-tax reversal can arise. With scrap, the chain from input to taxable output stays intact: materials in, products and scrap out, tax on both when sold.

Worked illustration. A fabrication workshop generates metal offcuts from its production. It sells the offcuts to a scrap dealer and accounts for output tax on what it receives, because scrap is goods and the sale is a taxable supply. It keeps the input tax it claimed on the raw metal — that metal was used in its taxable activity. Before invoicing, it confirms whether its particular scrap falls under any withholding or specific-rate regime for that category.

Common mistakes

  • Treating scrap and by-product sales as incidental proceeds outside the sales tax net.
  • Ignoring a withholding or specific-rate regime that applies to a particular scrap category.
  • Wrongly reversing input tax on raw materials just because some output became scrap.
  • Under-valuing scrap supplies rather than accounting on the actual consideration received.
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Where it fits

Scrap sales sit close to the treatment of used and second-hand goods and are the mirror image of an obsolete-stock write-off — one is a taxable sale, the other a non-sale. The mechanics rest on input and output tax, and charging at all depends on being a registered person. Scrap is goods; sell it and tax it.

An evidence-led way to apply this guidance

The useful question in Scrap, waste and manufacturing by-products is not simply whether a rule exists. For Scrap, waste and manufacturing by-products, the file must prove the facts that make the rule apply. Start the Scrap, waste and manufacturing by-products working by writing down classification, place of supply, registration status and the exact invoice base. Then tie each Scrap, waste and manufacturing by-products conclusion to contract, tax invoice, customer location, payment trail and the return working. That article-specific exercise separates a defensible Scrap, waste and manufacturing by-products position from one built around a label, a memory or a copied rate.

The legal starting point for Scrap, waste and manufacturing by-products is the Sales Tax Act 1990, its rules and current notifications. The operational check for Scrap, waste and manufacturing by-products belongs with FBR. Read the instrument, current guidance and actual transaction together for Scrap, waste and manufacturing by-products: guidance explains administration, but it does not rewrite the law or repair missing evidence.

Rate discipline. The 18% used below is an explicit case assumption for Scrap, waste and manufacturing by-products, not a substitute for checking the rate that applies to the actual period, supply, entity or election. For Scrap, waste and manufacturing by-products, replace that assumption with the confirmed current rate before the working is used in a return or invoice.

An evidence-led way to apply this guidanceDecision file for Scrap, waste and manufacturing by-products
CheckpointEvidence to place on fileReviewer question
Legal triggerthe Sales Tax Act 1990, its rules and current notificationsWhich fact activates the Scrap, waste and manufacturing by-products rule, and where is that fact evidenced?
Period and cut-offDated contract, invoice, return period and acknowledgementDoes the Scrap, waste and manufacturing by-products amount belong in this period rather than the one before or after it?
Classificationcontract, tax invoice, customer location, payment trail and the return workingWould an independent reviewer reach the same Scrap, waste and manufacturing by-products classification from the documents alone?
Rate or treatmentCurrent authority publication saved with the workingWas the Scrap, waste and manufacturing by-products source effective on the transaction date?
Submission trailFinal computation, payment proof and portal receiptCan the Scrap, waste and manufacturing by-products filed figure be rebuilt without asking the preparer?

Two worked case files

Worked example 1 — build the taxable invoice base. For a file concerning Scrap, waste and manufacturing by-products, assume the records show Rs 800,000 as the gross contract and invoice value, Rs 130,000 as the separately documented out-of-scope component, and Rs 35,000 as the credit note or price adjustment. The taxable value carried to the rate working for Scrap, waste and manufacturing by-products is therefore Rs 635,000:

Two worked case filesWorked base for Scrap, waste and manufacturing by-products
LineAmountFile reference
gross contract and invoice valueRs 800,000Primary control schedule
Less: separately documented out-of-scope component(Rs 130,000)Supporting document index
Less: credit note or price adjustment(Rs 35,000)Reviewer-approved adjustment
taxable value carried to the rate workingRs 635,000Signed computation

WORKING 1 Rs 635,000 x 18% = Rs 114,300; Rs 635,000 + Rs 114,300 = Rs 749,300

The arithmetic is the easy part of Scrap, waste and manufacturing by-products. The Scrap, waste and manufacturing by-products judgement sits in classification of the supply, place of supply, tax point and documentary support for each exclusion, including why Rs 130,000 and Rs 35,000 were removed. If any Scrap, waste and manufacturing by-products answer is weak, keep the amount in the exception list rather than forcing it into a filing, resolution or account.

Worked example 2 — reconcile the return to customer balances. For Scrap, waste and manufacturing by-products, assume Rs 1,125,000 as the customer-ledger control total, Rs 170,000 as the receipts matched to tax invoices, and Rs 55,000 as the valid credit notes and timing differences. The open amount supported by the return file for Scrap, waste and manufacturing by-products is Rs 900,000.

WORKING 2 Rs 1,125,000 - Rs 170,000 - Rs 55,000 = Rs 900,000

For Scrap, waste and manufacturing by-products, place the Rs 1,125,000 customer-ledger control total, the Rs 170,000 support for the receipts matched to tax invoices, and the Rs 55,000 schedule for the valid credit notes and timing differences beside the final Rs 900,000 balance. A Scrap, waste and manufacturing by-products reviewer should be able to move from source evidence to control total, from control total to decision, and from decision to the submitted figure without a hidden spreadsheet or oral explanation.

The final quality-control questions

  • Has the file for Scrap, waste and manufacturing by-products identified the controlling law and the version effective for the relevant date?
  • Are the Scrap, waste and manufacturing by-products assumptions visibly labelled and separated from enacted rates, thresholds and deadlines?
  • Do the Rs 635,000 and Rs 900,000 results reconcile to source evidence and the general ledger?
  • Is every Scrap, waste and manufacturing by-products exception assigned to a person and date rather than buried in a note?
  • Has the client or responsible officer approved the Scrap, waste and manufacturing by-products facts before submission?

This is the standard that makes Scrap, waste and manufacturing by-products useful in practice: the conclusion is stated, the law is named, the numbers can be recomputed, and the evidence survives after the person who prepared the file has moved on.

Confirm before you rely on this. Scrap, withholding and specific-rate treatment is set by the Sales Tax Act 1990 and FBR rules and can change. Confirm the current position from the FBR or a qualified tax adviser before relying on it.

Sources

This guide is written against the official and clearly labelled professional references below. Rates, thresholds and portal procedures change between reviews, so open the primary source before relying on a figure.

Questions people also ask

Is the sale of scrap or waste subject to sales tax?

Yes, as a rule. Scrap, waste and by-products are goods, and a sale of them by a registered person in the course of business is a taxable supply. Sales tax applies on the consideration received for the scrap. So a manufacturer selling off its production scrap is making taxable supplies, not disposing of something outside the tax net, subject to any specific regime for the particular scrap.

Do some kinds of scrap have special sales tax rules?

They can. Certain scrap categories — some metal and plastic scrap, for example — have at various times been subject to withholding sales tax mechanisms or specific rate regimes rather than the ordinary approach. Because these regimes are specific and change, businesses dealing in those categories should confirm the current treatment for their particular scrap rather than assume the general rule applies unchanged.

Do I lose the input tax on materials that became scrap?

No. Input tax claimed on raw materials used in production is not clawed back merely because some output emerged as scrap or a by-product. The materials were used in your taxable activity, and selling the resulting scrap is itself a taxable supply. This is different from writing off stock that never reaches a taxable supply, where an input-tax reversal can arise.

Scope note: General educational information for Pakistan, not a legal opinion or a substitute for advice based on your documents. Law, notifications, portal procedures and individual facts can change the result.
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