Legal Metrology for online sellers

Legal Metrology rules for online sellers rest on one principle: a packaged product must tell the buyer what is inside, how much, the most it may cost and who stands behind it, on the pack and on the listing.

What are the Legal Metrology rules?

They are the rules under the Legal Metrology Act, 2009, chiefly the Legal Metrology (Packaged Commodities) Rules, 2011, which set what a pre-packed product sold in India must declare. They are enforced by the Legal Metrology departments of the central and state governments.

A packaged commodity, in the rules’ sense, is a product packed in advance, without the buyer present, in a predetermined quantity. Most goods sold online fit that description: a jar of cream, a set of towels, a boxed toy, shoes in a carton.

The rules exist so that a buyer can compare products on price and quantity before paying. Online, the buyer pays before the pack is in their hands, which is why the listing has to say what the pack says.

For online sales, the rules reach the listing too: the platform must show the declarations a buyer would otherwise read on the pack, apart from the month and year, and marketplaces ask sellers to supply them. A listing without them can be blocked or removed.

Do the rules apply to what you sell?

If you sell goods packed before sale to retail buyers, generally yes. Who carries the duty depends on your role: the rules look to the manufacturer, packer or importer named on the pack, and a seller who packs or brands goods may be the packer.

• Your own brand, made for you. The pack must carry full declarations; whose name appears as manufacturer or packer is a decision to take with your adviser.
• Goods bought and resold unopened. The maker’s or importer’s declarations should already be on the pack; check them before you list, because the listing must match.
• Goods you repack, bundle or relabel. Repacking can make you the packer, with your own declarations to print.
• Imports. The importer’s name and address and the country of origin go on the pack before the goods are sold.

Some packs are treated differently, such as packs made for industrial or institutional buyers rather than retail sale. Food, cosmetics and other regulated goods also follow labelling rules of their own.

Legal Metrology is also separate from BIS certification. Toys sold in India need BIS certification, shown by the ISI mark, under the Toys (Quality Control) Order, and some categories, footwear among them, fall under BIS quality control orders: check whether one covers your product.

Our pages on how to sell toys online in India and sell footwear online in India cover those categories in more depth.

Which declarations must a pack carry?

Six declarations come up on almost every pack: MRP, net quantity, the name and address of the manufacturer, packer or importer, the month and year of manufacture or import, consumer-care details, and country of origin for imports. The rules list more for some goods.

• MRP. The maximum retail price, inclusive of all taxes, in rupees. Nobody in the chain may sell above it, and the selling price on your listing must not exceed it.
• Net quantity. How much is in the pack, in standard units of weight, volume, length or number: grams, millilitres, metres or pieces.
• Name and address. Of the manufacturer, packer or importer, in full, so a buyer or an inspector can find them. Where the maker and the brand owner differ, packs often name both.
• Month and year. Of manufacture or import, for the batch in the pack. Goods with a shelf life also carry an expiry or use-by date under their own rules.
• Consumer care. A name, address, telephone number and email for complaints, which someone actually answers.
• Country of origin. For imported goods, the country where they were made.

Declare quantity the way the trade measures the product. A towel set is sold by number, a cream by weight or volume, a rope by length; a quantity a buyer cannot compare, such as “1 pack”, tells them nothing.

Where do declarations go on the pack?

On the principal display panel, which the rules define as the area of the pack where the declarations are grouped together. They must be legible and prominent, printed on the pack or on a label fixed securely to it.

The net quantity also has a minimum figure height that rises with the size of the panel, so a large box cannot carry a tiny number.

• Keep all six declarations together in one panel, so a buyer, an inspector and a marketplace reviewer find them in one place.
• Print the MRP with the words “inclusive of all taxes”.
• Do not overwrite or sticker over a printed MRP without checking how the rules allow a price change; ask your adviser first.
• For garments, put the declarations on the hangtag or the pack, and keep the care label for fibre and washing.
• Photograph the declaration panel for every product and batch, sharp enough to read.

Where do declarations go on the listing?

In the marketplace’s compliance fields and in the images, and nowhere in contradiction with the pack. The table maps each declaration from pack to listing; your marketplace’s own field names will differ.

Add an image of the back of the pack with the declarations readable, if the marketplace allows one; reviewers and buyers both check it. On your own storefront, show the same declarations on the product page, because the rules do not stop at marketplaces.

Titles and images

Put the net quantity in the title wherever it decides the purchase, such as a pack of two or a 500 g jar, and keep it identical in the quantity field and on the pack.

Images that show a different pack size or count from the one shipped invite complaints and returns, and they contradict the declaration the listing carries. Update them whenever the pack changes.

We build listings from your pack artwork and documents, under our product listing services, and hold any listing whose declarations are missing until you have them.

What changes for garments, sets and combos?

The same declarations apply, with net quantity stated as a count and every component accounted for. A combo listing, two or more products sold as one, needs declarations that describe the combination as the buyer receives it.

• Garments. Net quantity as the number of pieces, on the hangtag or pack, with the MRP and the other declarations beside it. A three-piece kurta set says so.
• Multi-packs. A pack of three T-shirts declares three pieces and one MRP for the pack.
• Combos you assemble. Bundling two products into one listing describes a new pack: its net quantity, its MRP and, in practice, who packed it.

Our guide on how to start a clothing brand in India covers labels and hangtags for a new label from the first sample.

Who is responsible, you or the marketplace?

Both, for different things. The marketplace must show the declarations on its platform; the seller must supply them correctly and make sure the goods match. When a declaration is wrong, the marketplace usually acts against the listing, and the seller answers for the goods.

Marketplace seller agreements generally make the seller responsible for the accuracy of what they upload. Read yours for its clauses on product compliance, and keep the documents behind every declaration where you can produce them quickly.

Do packers and importers need to register?

Often, yes. The rules require manufacturers, packers and importers of packaged goods to register with the Legal Metrology authorities, and marketplaces often ask importers for that registration. Whether it applies to you depends on your role, so ask your adviser.

What if the MRP has to change?

Change the pack and the listing together, and check with your adviser how the rules let you declare a revised price on stock already packed.

After a change in GST rates, for example, the authorities have allowed revised prices on existing stock, but only in the manner and for the period they set. Our guide to GST for online sellers covers the tax side of a rate change.

On the listing, the MRP field must match the pack the buyer will receive. If old and new packs are both in stock, decide which one ships and keep the listing in step, or hold one back.

What should you check before listing?

1. All six declarations on the pack, grouped in one panel, legible at the pack’s actual size.
2. The MRP on the listing matches the pack, and no price on any channel exceeds it.
3. Net quantity in the title, the quantity field, the images and the pack, all saying the same thing.
4. Manufacturer, packer and importer details on the listing copied from the pack, not from memory or an old supplier sheet.
5. The consumer-care phone number and email tested by calling and writing to them.
6. Country of origin filled in for every product.
7. A readable back-of-pack image uploaded where the marketplace accepts one.
8. Any BIS certificate or quality control order checked for the category, with the certificate on file.
9. A record of which pack version and batch each listing describes, so changes reach the listing.

Common mistakes online sellers make

• A price above the MRP during a sale event, or an MRP raised to show a larger discount.
• A combo whose listing declares one product’s quantity and MRP, not the combination’s.
• Supplier declarations copied onto a listing after the goods were repacked under your brand.
• A consumer-care email address that bounces, or a number no one answers.
• Country of origin left blank because the goods are made in India.
• A pack reprinted with a new address or size while the listing still shows the old one.
• Declarations printed so small, or on a seam or fold, that no image can show them.

Non-compliance can bring penalties from the Legal Metrology authorities and blocked or removed listings from the marketplaces; the blocked listing is often the first sign.

How we handle declarations on listings

We enter what your packs and documents show, and we do not certify products or decide whether a rule applies to you. If a declaration or certificate is missing, the listing waits until you have it, because a non-compliant listing puts the account at risk.

We keep a photograph of every declaration panel with the product’s master record, so a reprinted pack is caught before the listing goes stale.

On the accounts we run, our marketplace account management answers compliance notices with you. For category rules beyond Legal Metrology, see how to sell personal care products online.

The terms used here, from RTO to TCS, are defined in plain English in our ecommerce glossary.