LMPC registration and packaged commodity compliance

Law

Legal Metrology Act 2009; PC Rules 2011, Rule 27

Deadline

Within 90 days of commencing business

Authority

Director (importers) or state Controller (packers)

Fee

Varies by authority and state

Who needs LMPC registration

Rule 27 requires every person who manufactures, packs or imports any commodity for sale, distribution or delivery in packaged form to register. In practice this covers:

• Importers of packaged consumer goods such as electronics, mobile accessories, cosmetics, toys, kitchenware, food products and apparel sold in packs;
• Manufacturers who pack their own products for retail sale;
• Packers who buy in bulk and repack into retail packs, including private label and e-commerce sellers who get goods packed under their brand.

The Rules do not apply in some cases, notably packages of more than 25 kg or 25 litres (other than cement, fertiliser and agricultural produce in bags above 50 kg, which have their own treatment), and commodities packed for industrial or institutional consumers as defined in the Rules. Whether an exemption applies depends on how and to whom the goods are sold, so it should be checked product by product.

Importer or packer: which authority registers you

Fees and processing times vary between states and should be checked at the time of application. Some states also prescribe a validity period and renewal for registrations, while others treat it as one-time; we confirm the position for your state.

LMPC registration is separate from licences for manufacturing, repairing or dealing in weights and measures themselves, which a business needs only if it deals in weighing or measuring instruments.

Mandatory declarations on every package

Rule 6 of the Packaged Commodities Rules prescribes the declarations that must appear on a retail package. In summary:

1. name and address of the manufacturer, packer or importer, and for imported goods the country of origin;
2. common or generic name of the commodity;
3. net quantity in standard units of weight, measure or number;
4. month and year of manufacture or of import, and best-before or use-by date where the product is perishable or time-sensitive;
5. retail sale price as maximum retail price (MRP) inclusive of all taxes;
6. unit sale price, such as price per kg or per litre, where required;
7. consumer care details: name, address, phone number and email of the person to contact for complaints.

Declarations must be legible, of the prescribed size, and on the principal display panel where the Rules require. E-commerce sellers must also ensure the mandatory declarations are displayed on the product listing, under the provisions of the Rules applicable to e-commerce entities.

Special points for importers

Imported packaged goods must carry the declarations before they are sold in India. Customs checks Legal Metrology compliance at clearance for many consumer goods, and consignments without the required details can be held. Importers commonly handle this by printing India-specific labels at the factory abroad, or by affixing stickers in a customs bonded warehouse before clearance, where permitted.

An importer also needs an Import Export Code, and depending on the product may need BIS registration, an FSSAI Central licence, a drug or cosmetic import registration, or other approvals. Food importers must ensure their labels satisfy both the Legal Metrology rules and FSSAI's labelling regulations; see our page on the FSSAI licence.

How LMPC registration is done

1. Identify each role you play (importer, manufacturer, packer) and the authority for each.
2. Prepare the application with business details, the list of commodities and pack sizes, premises and, for packers, details of the packing machinery and weighing equipment.
3. Apply online or in the prescribed form with the fee, and the supporting documents.
4. The authority scrutinises the application and may inspect the premises of a packer or manufacturer, including verification of weighing instruments used.
5. The registration certificate is issued, and its number can be used on the package where the business chooses or the authority requires.

Controls a packer should run every day

Registration is only the starting point for a manufacturer or packer. To stay compliant during inspections, a packing unit should:

• use weighing and measuring instruments of an approved model that are verified and stamped by the Legal Metrology department at the intervals required;
• check net quantity on a sample of packs from each batch and keep the records, since the Rules permit only small errors in the declared quantity;
• print the month and year of manufacture or packing and the batch number on every pack;
• keep artwork approval records showing that each label was reviewed against Rule 6 before printing; and
• train dispatch and warehouse staff not to alter MRP or other declarations once goods leave the line.

These controls are also what a Legal Metrology officer asks to see, and having them in place makes compounding of any minor lapse straightforward.

Penalties and enforcement

Legal Metrology officers inspect retail outlets, warehouses and e-commerce listings. Common violations are packages without MRP or with MRP overwritten, missing consumer care details, wrong net quantity declarations, short quantity, and selling above MRP. The Legal Metrology Act prescribes fines for selling non-standard packages and for other contraventions, which increase for repeat offences, and some contraventions are compoundable on payment of a compounding fee. Carrying on business without the Rule 27 registration is itself a contravention.

Penalties per offence may look modest, but they apply per product line and per inspection, and seizure of non-compliant stock can disrupt sales. Where a notice has been received, a prompt and well-documented response, often with compounding, usually limits the damage.

Mistakes we commonly correct

• Assuming the overseas supplier's label is enough. Foreign labels rarely include MRP inclusive of taxes or Indian consumer care details.
• Registering only with the state when the business is an importer, or only centrally when it also repacks.
• Stickering MRP over existing price markings in a way the Rules do not permit.
• Missing the unit sale price or using non-standard units.
• Not updating listings on marketplaces with the mandatory declarations.

Documents you need

The documents required differ between the central importer registration and state packer registrations. Usually we need the following.

• PAN and constitution document of the business (incorporation certificate, LLP certificate or partnership deed)
• GST registration certificate
• Import Export Code, for importers
• Address proof of the office, warehouse and packing unit
• List of commodities with pack sizes and specimen labels
• Details of weighing and measuring instruments used in packing, with verification certificates
• ID proof of the proprietor, partners or directors and authorised signatory
• Board resolution or authority letter for the signatory

How we handle it for you

1. Map your roles

   We confirm whether you need central importer registration, state packer registration, or both.

2. Review labels

   We check specimen labels against Rule 6 declarations before you print or sticker.

3. Prepare and file

   We prepare the application with commodity lists and documents and file with the right authority.

4. Support inspection

   We help you through scrutiny and any premises or instrument inspection.

5. Handle notices

   If an inspection notice arrives later, we draft the reply and pursue compounding where appropriate.

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Frequently asked questions