The amendments to the Legal Metrology (Packaged Commodities) Rules, 2011 (“LMPC Rules”), notified on 2nd November 2021 are set to take effect on 1sT April 2022. The LMPC Rules provide for, among other things, the mandatory declarations that should appear on labels of prepackaged commodities, where the declarations should appear and the manner in which they should appear.
The stated intent of the amendments is to safeguard the interest of consumers. The amendments seek to do this by removing certain ambiguities in interpretation of the rules, while also trying to ease the compliance burden on manufacturers and packers of commodities.
Key Provisions and Impact
The following amendments are likely to be of significant interest to consumers as well as manufacturers, packers, and importers.
- The unit sale price will now have to be declared on prepacked commodities. This is aimed at allowing easier comparison of the prices of the commodities at the time of purchase.
- The requirement to state month and year of pre-packaging or import has been removed, thus requiring only the month and year of manufacturing to be displayed. This is expected to remove ambiguity related to which date to declare on the package.
- The provisions of declarations of Maximum Retail Price (MRP) have been simplified by removing illustrations, which were restrictive, and providing for making the mandatory declaration of MRP in Indian currency “inclusive of all taxes”. This is expected to simplify compliance obligations.
- The quantity of a commodity in a package can now be expressed in terms of the number or unit or piece or pair or set or such other word which represents the quantity in the package. This is expected to remove the ambiguity of declaration of quantity sold by number in prepacked commodities and reduce the compliance burden.
This initiative to boost ease-of-doing-business in India is a step forward in reducing compliance requirements for businesses specifically because, the manner of making declarations and corresponding violations for the same under the regulations was a cause of concern. In an effort to overcome confusion associated with mandatory declarations, these amendments seek to bring about significant changes vis-à-vis mandatory declarations on product labels.