Exemptions from mandatory declarations on MRP Label under Legal Metrology

by | Mar 22, 2023 | Outlook

The Legal Metrology Act, 2009 provides standards & regulations for weights & measurements including incidental aspects and the Legal Metrology (Packaged Commodities) Rules, 2011 (‘LMPC Rules’) enlist various mandatory declarations to be made on pre-packaged commodities.

Off late there is a sharp surge in issuance of notices on violations of LMPC Rules. Vide this Outlook, we intend to apprise you about various exemptions available to businesses under the LMPC Rules.

Notably, exemptions under the LMPC Rules can be divided under various categories with alternate declarations mandated / recommended in certain cases. The same is tabulated below for ease of reference:


Alternate declarations

Basis form

Goods imported in unpacked form


Goods sold in unpacked form


Loose goods / Retail packages in box / container / bags etc. used for transportation and safety purposes

Transportation Box / For storage only


Pre-packaged goods meant for export

For export only


Basis type of ultimate consumer

Industrial Consumer*

Not for retail sale


*Person who buys products directly from manufacturer / importer / wholesale dealer for use by that industry

Institutional Consumer*

Not for retail sale


*Person who buys products directly from manufacturer / importer / wholesale dealer for use by that institution & not for commercial / trade purposes

Basis type and quantity of commodities inside packages

Commodities of quantity > 25 kg / 25 L


Cement, fertilizer and agricultural farm produce of quantity > 50 kg


Commodities of quantity ≤ 10 g / 10 mL (except tobacco and tobacco products)


Basis type of commodity

Fast food items packed by restaurant or hotel and like


Scheduled and non-scheduled formulations covered under Section 3 of the Essential Commodities Act, 1955 (except medical devices declared as drugs)


Thread sold in coil to handloom weavers


Garments in loose form

–                Name and address of manufacturer / importer / brand owner / marketer


–                Consumer care number and e-mail id


–                Size with international indicators such as M, XL etc. along with metric units such as m, cm etc.


–                MRP in Indian currency

Basis type of declarations

Month and Year of manufacture for food articles

As per Food Labelling Laws

Month and Year of manufacture for seeds

As per Seeds Laws

Month and Year of manufacture for cosmetics products

As per Drugs & Cosmetics Laws

Month and Year of manufacture / pre-packing in case of bidi / incense sticks / domestic LPG cylinder of 14.2 kg or 5 kg, bottled and marketed by PSUs


Retail Sale Price and Unit Sale Price for alcoholic beverages or spirituous liquor

As per State Excise Laws (if applicable)

Vegetarian / Non-vegetarian symbol in case of soap, shampoos, toothpastes and other cosmetics and toiletries

Ad-interim stay by Bombay High Court – Indian Beauty and Hygiene Association v. UOI, W.P. (L) No. 2370 of 2014, Case also pending in Delhi High Court – Ram Gaua Raksha Dal v. Union of India, W.P.(C) 12055/2021

NITYA Comments: Considering heightened action at department’s end in recent times, businesses should comply with express declaration requirements if their products fall under the purview of the LMPC Rules. Notably, exemption from declarations under the LMPC Rules do not absolve liability of business entity to make declarations as per other specific labelling regulations such as Food Laws, Drugs & Cosmetics Laws, Waste Management Regulations etc. Thus, businesses should be wary of such nuances while making declarations on the packages.