When you walk into a store and pick up a packaged product, everything printed on that label — from the weight to the MRP to the country of origin — is governed by a specific law: the Legal Metrology Act, 2009 and its associated rules. This blog breaks down the core requirements for anyone dealing with pre-packaged commodities in India. Whether you’re a manufacturer, importer, or retailer, here’s what you need to know about labelling, compliance, penalties, and registration, exactly as laid out in the M2K Alert.
Legal position
The labelling of pre-packaged commodities in India is governed by the Legal Metrology Act, 2009 and the relevant rules (LM Provisions). These rules are not just for show — they ensure that consumers know exactly what they are buying and protect them from misleading practices.
Why is this law relevant?
This law applies to all goods that are sold or distributed by weight, measure, or number. That means whether you’re selling sugar, electronics, or a pack of screws — if it’s pre-packed, this law likely applies to you.
Applicability
The law kicks in wherever goods are manufactured, packed, sold, imported, or delivered as pre-packaged commodities. In all such cases, the package must carry specific declarations, without exception.
Applicability – Declarations to be made on all pre-packaged commodity
If you’re dealing with any kind of pre-packaged commodity, the law mandates certain declarations that must appear clearly on the package. And yes, that includes e-commerce and bulk delivery too.
What must a person dealing in Pre-packaged commodity do
Anyone who deals in pre-packaged commodities — whether it’s for manufacturing, importing, distributing, or retail — must ensure full compliance with the labelling provisions of the Legal Metrology law.
What is a Pre-packaged commodity?
A pre-packaged commodity is defined as any item that is placed in a package without the purchaser being present. This is irrespective of whether it is sealed. The key here is that the product has a pre-determined quantity.
In simpler terms: if you packed it and the buyer wasn’t there, it’s pre-packaged — and the LM Act applies.
Commodities to which LM Act Apply
The LM Act applies to most products sold in packaging, including but not limited to:
- Food products
- Electronics
- Textiles
- Household goods
But there are some exclusions, which are covered in the next section.
Exclusions from the applicability of LM Act
Not every product is covered. The following do not fall under the LM Act’s labelling requirements:
- Fast food items packed by restaurants or hotels
- Certain drugs
- Items notified by the government
- Any commodity weighing more than 25 kg or 25 liters
- Agricultural produce sold in bags over 50 kg
- Items with a net weight or measure less than 10 grams or milliliters
These exclusions are based on practical considerations and the way such products are handled or consumed.
Who are “industrial consumer”
An industrial consumer is someone who buys packaged commodities directly from the manufacturer, importer, or a wholesale dealer — for use within that industry. It’s not for resale or trade but for in-house operational use.
Who are “institutional consumer”
An institutional consumer is a business, organisation, or body that buys directly from the source — again, for internal use only, not for resale. Think hospitals, hotels, schools, etc., buying large quantities of packaged goods for their own use.
Industrial consumers and Institutional consumers
If a commodity is sold to an industrial or institutional consumer, the label must clearly state that it is “Not for retail sale.” This helps avoid confusion in case such products enter the retail supply chain accidentally or otherwise.
Important caveat
Every pre-packaged good must carry multiple mandatory declarations, including:
- Name and address of the manufacturer and packer
- For imported items: name and address of the importer
- Country of origin for imported or assembled goods
- Month and year of manufacture or packaging
- Maximum Retail Price (MRP) in Indian currency
- Clearly identifiable Principal Display Panel
- Compliance with mandatory size and font rules
- Adequate spacing for readability
- Customer care number for complaints
If the package contains more than one item, additional declarations will be required.
Also, any person who pre-packs or imports goods for sale must register under the Legal Metrology (LM) Act. This is not optional.
Compliance requirements under the LM Provisions
To stay compliant, businesses must follow these practices:
- Obtain proper LM registration
- Ensure all mandatory declarations are made
- Conduct label reviews regularly to keep up with any updates in law
- Be ready for inspections, as LM officers are known to carry out surprise checks at retail stores
- Address any Show Cause Notices (SCNs) with documented proof of compliance
Penal provisions for non-compliance
Failing to follow the LM rules can result in:
- Financial penalties
- Prosecution of responsible individuals
- In serious cases, imprisonment
LM officers are empowered to inspect packaging, review compliance, and initiate action on the spot.
Penalty for continuous offence
The more you violate, the steeper the penalty:
- 1st Offence → ₹25,000 fine
- 2nd Offence → ₹50,000 fine
- Subsequent Offences → ₹1,00,000 fine + up to 1 year imprisonment
Additional penalties include:
- Fines for incorrect weight or quantity
- Action for failing to produce records or register
- Penalty for giving false information
These are not symbolic punishments. In many cases, companies have faced litigation, reputational loss, and operational delays.
Can any liability be fixated on the Board?
Yes. Under the LM Act:
- Every person in charge and responsible for the conduct of the business at the time of offence is considered guilty.
- By default, every director of the company may receive notices or face prosecution.
- However, a company may nominate one director who will be the sole person to receive such notices — provided this is communicated clearly to authorities.
This makes it crucial to assign and document compliance responsibility internally.
Major Sectors where LM Act is applicable
The Legal Metrology Act applies across a wide range of industries, including:
- Auto components
- FMCG (Fast Moving Consumer Goods)
- Electronics
- Leather & Textiles
- Consumer durables
- Sports goods
- Retail & E-commerce
Basically, if your business involves selling packaged goods, you likely fall under this law.
How can we assist you..
If you’re unsure about your compliance status, here’s how M2K can support:
- Verify if the LM law applies to your product or business
- Help obtain mandatory registration
- Review your packaging and labels for full compliance
- Advise on best practices for market readiness
- Help draft replies and provide legal support in case of SCNs or litigation
- Guide you through compounding processes to avoid escalation
Being LM-compliant isn’t just about avoiding penalties — it builds trust with your buyers, regulators, and stakeholders.
