Legal Metrology compliance under the Legal Metrology Act, 2009 and Packaged Commodities Rules, 2011 applies to every cosmetics business in India — covering LMPC registration, Rule 6 package declarations, and MRP enforcement.
Legal Metrology compliance is a non-negotiable parallel track to CDSCO registration for every cosmetics business operating in India. Section 18(1) of the Legal Metrology Act, 2009 prohibits the manufacture, packing, sale, import, distribution, delivery, or possession for sale of any pre-packaged commodity unless the package bears the declarations and particulars prescribed under the Act. The obligation is absolute — CDSCO approval does not substitute for or waive Legal Metrology requirements.
For cosmetics businesses, Legal Metrology compliance breaks into three distinct obligations: registration under Rule 27(1) of the Legal Metrology (Packaged Commodities) Rules, 2011; mandatory package declarations under Rule 6; and MRP declaration and enforcement. Each operates independently. Non-compliance with any one of the three triggers separate penalties.
The Legal Metrology Act, 2009 came into force on 1 April 2011. Section 18(1) establishes the declaration requirement for all pre-packaged commodities. Section 18(2) extends this to advertisements — any advertisement referencing the retail sale price of a pre-packaged commodity must declare net quantity in prescribed form. Section 52(1) and Section 52(2) empower the government to make rules, including the registration obligation for manufacturers, packers, and importers that flows through Rule 27 of the Packaged Commodities Rules.
The Legal Metrology Act and the Cosmetics Rules, 2020 operate in parallel. CDSCO jurisdiction governs formula safety, ingredient approval, import licensing (COS-1), and labelling content requirements under Rule 34 of the Cosmetics Rules, 2020. Legal Metrology jurisdiction governs packaging declarations, net quantity accuracy, MRP format, and importer registration. Both frameworks apply simultaneously to every imported cosmetic product. Compliance with one does not satisfy the other.
Rule 7(5) of the Packaged Commodities Rules (as substituted by the 2017 Amendment) provides a reconciliation mechanism: except for the size of numbers and letters for declaring net weight, retail sale price, expiry or best before date, and consumer care details, the Legal Metrology formatting provisions do not apply to a package if the required information is also mandated by any other law in force. This means where CDSCO labelling requirements and Legal Metrology requirements overlap in content, the Legal Metrology formatting rules on font size for those specific fields govern — but duplication of content declarations is not required.
Every individual, firm, Hindu undivided family, society, company, or corporation that pre-packs or imports any commodity for sale, distribution, or delivery must register with the Controller of Legal Metrology in the relevant state under Rule 27(1) of the Packaged Commodities Rules. Registration is mandatory before the first import shipment clears customs — it is not a post-import formality.
Registration is entity-level, not product-level. A single LMPC registration covers all pre-packaged commodities imported or manufactured by the registered entity. The government registration fee under Rule 27(1) is ₹500; this is the statutory fee payable to the state authority. Validity and renewal cycles are set at the state level; apply for renewal 30 to 60 days before the certificate expiry date.
Retailers and dealers who do not pre-pack goods are not required to register.
Every pre-packaged cosmetic product must carry the following on its label, each traceable to a specific Rule 6 clause:
Rule 6(1)(a) — Name and address of the manufacturer. Where the manufacturer is not the packer, both must be named. For imported products, the importer's name and complete address with PIN code is mandatory in addition to the manufacturer.
Rule 6(1)(aa) — Country of origin, manufacture, or assembly. Inserted by the 2017 Amendment. Mandatory for all imported cosmetics without exception.
Rule 6(1)(b) — Common or generic name of the commodity.
Rule 6(1)(c) — Net quantity in standard units of weight, measure, or number.
Rule 6(1)(d) — Month and year of manufacture, pre-packing, or import. For cosmetics packages, a specific proviso directs that the provisions of the Drugs and Cosmetics Rules, 1945 apply — meaning the date of manufacture, best before, and period after opening declarations as required under the Cosmetics Rules, 2020 govern this field.
Rule 6(1)(e) — Maximum retail price inclusive of all taxes in Indian rupees, in the standardised format prescribed by the 2017 Amendment: "Maximum or Max. retail price Rs. xx.xx (inclusive of all taxes)" or "MRP Rs. xx.xx incl. of all taxes." Paise rounded to the nearest rupee or 50 paise.
Rule 6(8) — Every package containing soaps, shampoos, toothpastes, and other cosmetics and toiletries must bear a green dot for vegetarian-origin products or a red/brown dot for non-vegetarian-origin products at the top of the principal display panel. This was inserted by the 2014 Amendment.
A note on Rule 6(8): there is an unresolved jurisdictional tension between the Legal Metrology Directorate, which maintains the marking is mandatory, and the Drugs Technical Advisory Board under CDSCO, which has advised the marking is voluntary given the absence of a standardised national certification system for ingredient classification. A Delhi High Court has directed joint consultations between Legal Metrology and the DCGI to resolve this. Until formal resolution, treat the Rule 6(8) dot declaration as mandatory for all cosmetics and toiletries.
Rule 6(4A) — Inserted by the 2017 Amendment, this Rule permits manufacturers and importers to voluntarily add barcodes, GTIN, QR codes, and e-codes on packaging in addition to mandatory text declarations. QR codes are supplementary only — cosmetics are not eligible for the QR-code substitution provisions introduced for electronic products. All Rule 6 mandatory declarations must be printed directly on the label.
The MRP declared on the package is the maximum price at which the product can be sold at retail. Selling above MRP is a violation enforceable against the retailer, distributor, and importer. The 2017 Amendment standardised the declaration format — non-standard MRP formats (e.g., absence of the "inclusive of all taxes" qualifier) constitute a package declaration non-compliance under Section 36(1) of the Act, distinct from a retail price violation.
Customs authorities operate a two-checkpoint model for Legal Metrology compliance:
Pre-clearance verification — Customs verifies LMPC registration status and inspects physical packaging samples for Rule 6 declaration completeness before releasing a shipment. Missing LMPC registration or incomplete declarations trigger a hold. Demurrage accumulates during the hold period. Relabelling at the port of entry is operationally disruptive and commercially costly.
Post-clearance verification — State-level Legal Metrology inspectors conduct retail and warehouse inspections for MRP compliance and declaration accuracy after goods have entered trade channels. This is independent of customs clearance.
The October 2025 Legal Metrology (Packaged Commodities) Amendment Rules introduced provisions for medical device packaging in alignment with the Medical Devices Rules, 2017. No direct changes were made to the cosmetics declaration framework; existing Rule 6 obligations remain unchanged.
Legal Metrology registration must be sequenced correctly relative to other India market entry steps. The optimal order for a foreign cosmetics brand entering India:
Step 1 — Incorporate Indian legal entity or appoint Indian importer/authorised agent. LMPC registration requires a legal entity resident in India.
Step 2 — Obtain IEC (Import Export Code) from DGFT. Required for LMPC registration documentation.
Step 3 — Obtain GST registration. Required for LMPC application.
Step 4 — Submit COS-1 application to CDSCO via SUGAM portal (processed in parallel with Steps 5 and 6).
Step 5 — Apply for LMPC registration with the state Controller of Legal Metrology. Do not wait for COS-1 approval to initiate LMPC — process both in parallel. LMPC processing takes 7 to 20 working days; COS-1 processing is 60 days from complete receipt.
Step 6 — Finalise label artwork satisfying both Rule 34 of the Cosmetics Rules, 2020 (CDSCO content requirements) and Rule 6 of the Packaged Commodities Rules (Legal Metrology declaration requirements) simultaneously.
Step 7 — On COS-1 receipt, commence first import. LMPC registration must be in hand before customs clearance.
Violation | Applicable Provision | Penalty
Non-compliant package declarations | Section 36(1), Legal Metrology Act, 2009 | First offence: up to ₹25,000. Second offence: up to ₹50,000. Subsequent offences: ₹50,000–₹1,00,000 or imprisonment up to 1 year, or both
Operating without LMPC registration | Rule 32, Packaged Commodities Rules (2017 Amendment) | ₹5,000 per contravention
Obstructing a Legal Metrology officer | Section 40, Legal Metrology Act, 2009 | Imprisonment up to 2 years; subsequent offence up to 5 years
General rule contravention (no specific penalty prescribed) | Rule 32, Packaged Commodities Rules | ₹5,000
Non-compliance at the import stage compounds these penalties with customs hold costs, demurrage charges, and potential seizure of the entire shipment.
Rule 26 of the Packaged Commodities Rules provides the following exemptions from the declaration and registration requirements:
Rule 26(a) — Packages with net weight or measure of 10 grams or 10 millilitres or less. This exemption does not apply to tobacco products or pan masala.
Rule 26(b) — Fast food items packed by restaurants, hotels, and similar establishments.
Rule 26(c) — Scheduled and non-scheduled formulations covered under the Drugs (Price Control) Order, 2013.
Rule 3(b) (not Rule 26) — Packaged commodities intended exclusively for industrial or institutional consumers are excluded from the Chapter II retail declaration provisions.
Non-commercial samples not intended for sale, distribution, or delivery are outside the scope of Rule 27(1).
Legal Metrology compliance — LMPC registration, Rule 6 package declarations, and MRP enforcement — runs parallel to CDSCO registration for every cosmetics business operating in India. Both frameworks apply from the first import, and non-compliance with either results in customs holds, product seizure, or market access denial.
Cosmetics Consultants India manages Legal Metrology compliance as an integrated part of the India market entry process — coordinating LMPC registration, label artwork review against Rule 6 declarations, and sequencing alongside COS-1 applications. Contact us to initiate the process.
LMPC registration under Rule 27(1) of the Legal Metrology (Packaged Commodities) Rules, 2011 is mandatory for all cosmetics importers and domestic manufacturers before import clearance or retail distribution.
Learn more →COS-1 is the mandatory import Registration Certificate for all cosmetics from non-SAARC countries under Rule 12(1) of the Cosmetics Rules 2020. We manage the full application — Second Schedule, Letter of Authorization, fee calculation, and SUGAM portal filing.
Learn more →Rule 34 of the Cosmetics Rules, 2020 governs every mandatory label declaration for imported cosmetics in India — from RC number and INCI ingredients list to expiry date format and net contents. Full compliance reference with inner vs. outer label obligations.
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