A first label error now earns a warning. The second can cost ₹5 lakh.

On 1 May 2026 the Legal Metrology provisions of the Jan Vishwas (Amendment of Provisions) Act, 2026 came into force. They rewrote section 36 of the Legal Metrology Act, 2009, which deals with pre-packaged commodities that do not carry the declarations the law requires. The section now names sale "through digital modes of sale such as e-commerce platforms" expressly.

The new penalty ladder

• Declarations that do not conform (section 36(1)): a warning with an improvement notice for a first offence, a penalty of up to ₹5 lakh for a second, and a fine of ₹25 lakh to ₹50 lakh for later offences. Imprisonment no longer applies.
• Net quantity outside the prescribed error (section 36(2)): no improvement notice. A first offence carries a fine of ₹10,000 to ₹1 lakh, a second up to ₹5 lakh, and a third or later offence up to ₹50 lakh, imprisonment of up to one year, or both.
• Breach of rules made by the Central Government, such as the Packaged Commodities Rules: section 52(3) now allows those rules to provide a penalty of up to ₹5 lakh and suspension or revocation.
• Under section 3 of the 2026 Act, fines and penalties rise by 10% of their minimum amount every three years from commencement.

Before 1 May, a first offence under section 36(1) carried a fine of up to ₹25,000. The new ladder is gentler the first time and far steeper after it. For a company printing the same artwork across many SKUs and channels, the period after an improvement notice is where the risk now sits.

The improvement notice is a warning, not a licence. It is the second label that costs money.

How the improvement notice works

The same Act added three sub-sections to section 15. An officer with reasonable grounds to believe that a person has not complied with the Act, the rules or directions may serve an improvement notice stating the grounds, the failures, the measures needed and a reasonable period to take them. If the person does not comply, the registration or approval is to be suspended or revoked, after a hearing and for recorded reasons. Inspections, searches and seizures made under a written authorisation of the Director or Controller are now deemed to be made under a lawful warrant.

Registration details matter more as a result. Amendments to rule 27 of the Packaged Commodities Rules, notified on 29 May 2026, require applications to name the director responsible for violations, require firms to update their details each year, and make certificates valid until cancelled.

What retail packs must still declare

For packages intended for retail sale, rule 6 of the Legal Metrology (Packaged Commodities) Rules, 2011 requires, subject to exceptions (some items on food and cosmetics packs follow those sectors' own laws, medical devices follow the Medical Devices Rules, 2017, and rule 3 excludes packs above 25 kg or 25 litres and packs meant for industrial or institutional consumers): the name and complete address of the manufacturer, packer or importer; the country of origin for imported goods; the common or generic name; the net quantity in standard units or by number; the month and year of manufacture; a best-before or use-by date where applicable; the retail sale price inclusive of all taxes; dimensions where size matters; and consumer-care details. The unit sale price must also be declared, in the form that applies from 1 January 2024, unless it is the same as the retail sale price.

Rule 6(2) defines the consumer-care details: the name, address, telephone number and e-mail address of the person or office to contact about consumer complaints. Rule 6(3) bars individual stickers that alter or add a mandatory declaration, except a sticker showing a lower maximum retail price, which must not cover the original. Rule 6(9) separately allows a label to be affixed to imported packages to make the required declarations.

Panel size and letter height

Declarations go on the principal display panel. Table I under rule 7 sets the minimum height of numerals and letters by the panel's area, with a larger minimum where the text is blown, formed or moulded on the container:

• Up to 50 cm²: 1 mm, or 2 mm if moulded.
• 50 to 100 cm²: 1.5 mm, or 3 mm.
• 100 to 500 cm²: 2.5 mm, or 4 mm.
• 500 to 2,500 cm²: 4 mm, or 6 mm.
• Above 2,500 cm²: 6 mm in both cases.

Characters must be at least a third as wide as they are tall, except the numeral 1 and the letters i, I and l. The area excludes the top, the bottom, can flanges and the shoulders and necks of bottles and jars. For a rectangular pack it is the height multiplied by the width of the display side. For a cylindrical pack, such as a paint tin, the panel is 40% of the height multiplied by the circumference. Where another law also governs the label, these size rules still apply to the net quantity, retail sale price, expiry or best-before date and consumer-care details. Medical devices are an exception: since a 2025 amendment, the Medical Devices Rules, 2017 set the character sizes on those packs. Under rule 8, the space around the net quantity must be free of print by at least the numeral's height above and below, and twice that height to each side.

An illustrative example: a hypothetical tin 12 cm tall with a circumference of 35 cm has a panel of 0.4 × 12 × 35 = 168 cm². That falls in the 100 to 500 cm² band, so printed declarations need numerals and letters at least 2.5 mm tall, or 4 mm if formed or moulded on the surface of the tin. Each pack size needs its own check.

Online listings carry the same declarations

Rule 6(10) requires an e-commerce entity to display the mandatory declarations listed in rule 6(1), except the month and year of manufacture, on the platform used for the sale. On a marketplace, the manufacturer, seller, dealer or importer answers for their correctness where the platform only provides access, does not initiate the transmission, select its receiver or modify its content, and observes its due diligence as an intermediary under the Information Technology Act, 2000. That protection falls away if the platform abetted the breach or fails to remove the material promptly once it knows or is notified. The physical pack must still carry every declaration.

The Consumer Protection (E-Commerce) Rules, 2020 add a parallel duty: sellers on a marketplace must give the platform all relevant details of their goods, including the country of origin, and the name and details of the importer for imported goods.

More is coming for imports and online sales

• Amended e-commerce rules in force from 1 January 2027 keep the existing duty on platforms selling imported goods to name the importer, and add a duty to identify the goods and give the full country of origin, as provided under the Packaged Commodities Rules. Sellers must also give the best-before or use-before date.
• A substituted rule 6(10A), effective 1 July 2027, requires e-commerce entities to give listings of imported products a searchable and sortable country-of-origin filter.
• A Department of Consumer Affairs advisory of 8 October 2026 says imported packs must carry their declarations before they are cleared from customs for home consumption. Since May 2026, importers may label goods in AEO Tier-2 and Tier-3 bonded warehouses.

Under the advisory, AEO Tier-2 and Tier-3 importers may affix declarations at their approved premises where Customs procedures permit. All others must do so in a bonded warehouse under section 57 or 58 of the Customs Act, 1962, before clearance.

What legal and packaging teams should do

• Check every artwork against the declarations and the panel-size rules before print, and keep the approval and the approved version on record.
• Treat an improvement notice as a portfolio issue: find every SKU and listing that shares the error, not only the one inspected, and close it within the period the notice sets.
• Make sure the master artwork, the e-commerce listing and the physical pack carry the same declarations.
• Keep registration details current, including the responsible director, and diarise the annual update.
• For imports, confirm that labelling happens before customs clearance, and that country-of-origin data is ready for platform filters.
• Retire wording that predates 2022: the Rules now ask for the month and year of manufacture, not the date of packing.