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The Department of Consumer Affairs, Legal Metrology Division, issued its latest update to the Frequently Asked Questions (“FAQs”) on 11 November 2025, offering important clarifications under the Legal Metrology Act, 2009 and the Legal Metrology (Packaged Commodities) Rules, 2011 (“LMPC Rules”). The revised FAQs aim to reduce ambiguity around packaging, labelling, and import requirements—areas where businesses often face compliance challenges and regulatory action.
Key Clarifications from the Updated FAQs
1. Retail Sale Price (RSP)
The FAQs confirm that the retail sale price may be indicated using either “₹” or “Rs.”. This flexibility accommodates varied industry practices, but the chosen expression must be clear, prominent, and not misleading. Any ambiguity or illegibility may result in penalties or seizure of non-compliant products.
2. Minimum Font Size Requirements
The LMPC Rules mandate minimum font sizes for statutory declarations. The FAQs reiterate that while larger fonts are permissible, using anything smaller than the prescribed minimum—especially on small packs—constitutes a violation and may lead to enforcement action, including prosecution or product recall.
3. Footwear Declarations
A clear distinction is now emphasized:
- Boxed footwear: All mandatory declarations must be printed on the box or on a label affixed to it.
- Unboxed footwear: Declarations must appear on a durable tag or sticker affixed to the product.
Missing or incomplete declarations, particularly for unboxed items, may expose manufacturers and importers to penalties.
4. Institutional and Industrial Packages
Packages meant exclusively for institutional or industrial consumption are exempt from standard LMPC declarations. However, they must display the phrase “Not for Retail Sale.” If such packages enter retail channels without full declarations, businesses may face significant penalties under the Legal Metrology Act.
5. Outer and Shipper Cartons
Outer cartons or shipper cartons used only for transportation or wholesale distribution do not require mandatory declarations. They should, however, be clearly marked to indicate non-retail use—helping prevent misinterpretation by enforcement authorities.
6. Manufacturer/Brand Owner Details
The FAQs clarify that providing the full name and address of the brand owner, along with the words “Marketed by” or “Brand Owner,” is sufficient to meet the manufacturer-details requirement under Rule 6(1)(a). This is especially relevant for businesses using outsourced or contract manufacturing.
7. Imported Products
For imported pre-packaged commodities, only the importer’s name and address and the country of origin must be displayed. Details of the foreign manufacturer are not mandatory. Incorrect importer details or misrepresentation of origin may still result in product detention or penalties.
Additional Clarifications
- All mandatory declarations may be grouped together on the principal display panel or presented separately if pre-printed or provided online.
- For combination, group, or multi-piece packages, unit sale price declarations are not required, and the net quantity may be written as “1 N” or “1 U.”
Compliance Recommendations
To align with the new clarifications, businesses should:
- Review packaging and labelling artwork for consistency with the FAQs and statutory rules.
- For footwear, maintain separate workflows for boxed and unboxed products.
- Ensure robust controls over institutional/industrial packs to prevent retail diversion.
- Update artwork for imported goods to reflect correct importer details and country of origin.
- Conduct regular staff training and internal audits to ensure continued compliance.
Conclusion
The 2025 update to the Legal Metrology FAQs provides welcome clarity on common compliance issues, helping businesses avoid regulatory pitfalls. While the guidance simplifies interpretation of the LMPC Rules, non-compliance risks—including fines, product seizures, and reputational damage—remain substantial. Companies should therefore proactively update their packaging and labelling processes to align with these clarifications and maintain a strong compliance posture.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
