Legal Metrology (Packaged Commodities) Rules, 2011
Every importer of pre-packaged goods has to be registered, and most are not
Rule 27 of the Legal Metrology (Packaged Commodities) Rules, 2011 requires every individual, firm, company or corporation that pre-packs or imports any commodity for sale, distribution or delivery to register its name and complete address with the Director or the Controller of Legal Metrology. The application is due within ninety days of commencing import.
It is a small obligation that carries disproportionate consequences, because Section 18 of the Legal Metrology Act, 2009 prohibits importing a pre-packaged commodity that does not bear the prescribed declarations at all. Medfins International handles the registration and, more usefully, reviews your artwork before the packaging is printed.
The registration itself
- Rule: Rule 27, Legal Metrology (Packaged Commodities) Rules, 2011.
- Fee: Rs 500 with the application; Rs 100 for any alteration to the certificate.
- Authority: the Director or the Controller, whichever receives the application, becomes the Registering Authority. Central registration is handled by the Department of Consumer Affairs; state registration by the State Controller of Legal Metrology.
- Timing: within ninety days of commencing pre-packing or import.
- Renewal: none. The registration does not carry an expiry. What does recur is the Rule 27(3) alteration fee whenever premises, commodities or partners change.
Rule 27(2) asks for only three particulars: the applicant’s name, the complete address of the premises where pre-packing or import takes place, and the name of the commodities. The document checklist is set by each registering authority, not by the Rules, which is why requirements differ between Delhi, Tamil Nadu and West Bengal.
What has to appear on the package
Rule 6 requires a definite, plain and conspicuous declaration of the name and address of the manufacturer and packer, and for any imported package the name and address of the importer; the common or generic name of the commodity; the net quantity in standard units; the month and year of manufacture, pre-packing or import; the retail sale price; and dimensions where relevant. Rule 6(2) separately requires the name, address, telephone number and e-mail of the person or office to be contacted in case of consumer complaints.
The 2025 amendment, and what it does not do
The Legal Metrology (Packaged Commodities) Amendment Rules, 2025 harmonised packaging declarations for medical devices with the Medical Devices Rules, 2017. For packages containing medical devices, the Medical Devices Rules prevail on the height and width of numerals and letters used for declarations, declarations on the principal display panel may be made in accordance with those Rules, and the Rule 33 relaxations do not apply where the Medical Devices Rules are applicable.
Read what that says, and not what the trade press said about it. It changes how declarations are made on a medical device package. It does not remove the requirement to make them, and it does not touch the Rule 27 obligation to register as an importer. Firms that concluded in late 2025 that medical devices had been taken out of legal metrology altogether are carrying a live exposure.
The institutional consumer exemption, and its trap
Rule 3 disapplies the retail packaging chapter to packages of more than 25 kg or 25 litres, and to packaged commodities meant for industrial or institutional consumers. The explanation defines an institutional consumer as one such as a hospital that buys packaged commodities directly from the manufacturer for use by that institution.
Those two words decide most disputes. An importer supplying hospitals through a distributor is not selling directly from the manufacturer, and the exemption does not apply. Nor does Rule 3 exempt anybody from registering under Rule 27, because registration sits in a different chapter.
Where this goes wrong
- Believing the 2025 amendment was an exemption. It was a harmonisation of how declarations are presented, not a removal of them.
- Claiming institutional status through a distributor. The exemption requires purchase directly from the manufacturer.
- Printing artwork before the declarations are settled. Rule 6(3) does not permit individual stickers to be affixed for making a declaration required by the Rules, with a narrow exception for revised price. Correcting artwork after printing is expensive.
- Omitting consumer care details. Routinely missed on imported medical and cosmetic packaging, and easy for an inspector to spot.
- Registering late. The ninety-day clock starts when import commences, not when someone notices.
Frequently asked questions
Do we register centrally or with the state?
Rule 27 names the Director or the Controller, and both routes are used in practice. The right answer depends on your footprint and is worth settling before filing rather than after a rejection.
Does the registration expire?
No renewal is prescribed. Alterations to the certificate attract a Rs 100 fee.
What are the penalties?
Under Section 36 of the Act, a non-conforming pre-packaged commodity attracts an improvement notice for the first offence, a penalty extending to five lakh rupees for the second, and not less than twenty-five lakh rupees for subsequent offences. Rule 32 separately provides a fine for contravention of Rules 27 to 31.
Is this the same as the registration for importing weights and measures?
No. Section 19 of the Act deals with importers of weights or measures, which is a separate requirement from Rule 27 registration for pre-packaged commodities.
Do declarations have to be on the package before customs clearance?
Section 18 prohibits importing a pre-packaged commodity that does not bear the prescribed declarations, so the safe assumption is that the package must comply when it arrives. Port practice is governed by customs instructions and should be confirmed for your port of entry.