What a pharma wholesale invoice must carry

Batch, expiry, drug licence numbers — on top of everything GST already asks for.

Last checked 20 September 2026

A pharmaceutical wholesale invoice has to satisfy GST like any other bill, and then carry more on top: the batch number and expiry date of every item, the drug licence numbers of both seller and buyer, and the MRP. These come from the Drugs and Cosmetics Rules, not from GST.

Two sets of rules on one piece of paper

Requirement	Comes from
GSTIN, HSN, taxable value, tax split, place of supply, invoice number	GST — Rule 46
Batch number, expiry date, drug licence numbers, MRP	Drugs and Cosmetics Rules

A bill that satisfies one and not the other is non-compliant. Ordinary billing software handles the first set and quietly has nowhere to put the second.

The pharma-specific fields

Field	Why it is there
Batch / lot number	The identifier in a recall. Without it a recall means contacting every customer who ever bought the product
Expiry date	Both parties need to know what they are holding, and it governs returns and expiry claims
MRP	The ceiling price to the patient, and the basis of the whole PTR / PTS chain
Your drug licence numbers	Wholesale licences, commonly Form 20B and 21B, printed in the header
The buyer’s drug licence number	Evidence that you sold to someone licensed to receive it
Pack size	A strip of 10 and a bottle of 100 are not interchangeable quantities

Licence numbers are not decoration

Selling scheduled drugs to a buyer without a valid licence is a regulatory problem, not a paperwork one. Record the buyer’s licence on their account, and keep it current — expired licences are the thing an inspection finds.

Why batch has to come from stock, not from typing

If the batch number is typed onto the invoice by hand, three things follow. It gets typed wrong. It does not necessarily correspond to the carton that actually went out. And you cannot answer "which customers received batch B-2208" without reading every invoice.

The batch has to be an attribute of the stock, chosen when the line is billed, so the invoice records what physically left. See batch tracking and FEFO, and how batches work in TracEasy.

Records to keep

Sale records showing the drug, batch, quantity, buyer and date — the Drugs Rules prescribe both the content and how long to keep it.
Purchase records tracing each batch back to the supplier.
Your own licences, current and displayed.
Buyers’ licence numbers, with expiry dates you actually review.

Retention periods under the Drugs Rules and under GST differ. Keep to the longer one, and in practice keep them indefinitely.

What good looks like

One document, produced once, that carries both sets of requirements: GST fields from the party and product master, batch and expiry from the stock the line came out of, licence numbers from the two party records. Nobody types a batch number, and a recall is a query rather than an afternoon.

Which licence forms apply to wholesale?

Wholesale of drugs generally runs on Form 20B and, for the Schedule C and C(1) categories, Form 21B. Exactly which you hold depends on what you deal in — your state drugs control authority is the authority on this, not an article.

Do I need batch numbers on a retail counter bill?

Record-keeping obligations apply to sales of drugs generally, and what must be printed can differ between retail and wholesale. Confirm the requirement for your licence type with your state authority.

Can I print a GST invoice and a separate batch sheet?

It is not how the trade works and it is asking for the two to be separated. One document carrying everything is both simpler and safer.

Sources

Drugs and Cosmetics Act 1940 and Drugs Rules 1945
CDSCO — Central Drugs Standard Control Organisation
CGST Rules 2017, Rule 46

How TracEasy handles this

Create a GST tax invoice

The main billing screen, from picking the party to printing the bill.

Batches and expiry

Why the same product can hold several batches, and how the oldest is billed first.