Summary: This article deals with the relaxation granted by the Department of Consumer Affairs on September 18, 2025 to businesses dealing with pre-packaged commodities affected by recent GST rate changes. The advisory allows businesses to voluntarily affix revised MRP stickers on unsold packages manufactured before September 22, 2025, without obscuring the original MRP. This affixation of revised stickers is purely optional and addresses compliance burdens created when GST rate changes affect MRP declarations. Additionally, the compliance requirements have been simplified by waiving newspaper advertisement mandates and requiring only circulars to dealers and retailers with copies to the regulatory authority.
The revised advisory issued by the Department of Consumer Affairs, Ministry of Consumer Affairs, Food and Public Distribution, dated September 18, 2025[1](“Advisory“), superseding an earlier advisory dated September 9, 2025[2], on the same subject matter, and issued in response to representations made by the industry and trade associations, addresses a critical challenge faced by manufacturers, packers, and importers of pre-packaged commodities in light of the recent changes to the Goods and Services Tax (“GST”) rates[3], providing much-needed regulatory flexibility for businesses dealing with unsold inventory.
Background and Context
The Legal Metrology (Packaged Commodities) Rules, 2011 (“LMPC Rules”), mandate strict compliance with declaration of ‘Maximum Retail Price’ (“MRP”) on pre-packaged commodities. However, Rule 33 of the LMPC Rules empowers the Central Government to permit manufacturers or packers to package commodities for sale for a reasonable period by relaxing one or more provisions of these Rules, provided the government ascertains the genuineness of the request and specifies appropriate corrective measures. Exercising this discretionary power under Rule 33 of the LMPC Rules, the Central Government vide the Advisory has clarified that manufacturers, packers, or importers of pre-packaged commodities may voluntarily affix additional revised MRP stickers on unsold packages manufactured before September 22, 2025, i.e., prior to GST rate changes provided that the original MRP printed on the package is not obscured.
Since the MRP on pre-packaged commodities is inclusive of all taxes that are levied, including GST, any change in the MRP owing to tax rate revisions would require fresh packaging or labelling, creating significant compliance burdens and potential wastage for manufacturers and pre-packagers. However, the Advisory emphasises that such re-stickering is purely optional and not mandated by the LMPC Rules, as the extant LMPC Rules do not require affixing revised price stickers on such unsold packages.
Interestingly, when GST was introduced in 2017, similar challenges arose regarding pre-packaged commodities with pre-printed MRP declarations. The transition from the previous tax regime to GST created comparable situations where businesses held substantial inventory with MRP declarations that no longer reflected the applicable tax-inclusive prices[4]. The government had issued relief measures during the GST implementation phase, recognising the practical difficulties faced by manufacturers, packers, and importers in managing existing stock during tax regime transitions[5]. In another instance, vide an order dated December 4, 2017, the Legal Metrology Division, Department of Consumer Affairs, had while exercising its powers under Rule 33 of LMPC Rules relaxed the manner of declaring retail sale price for single brand retail trading entities for a limited period, wherein, instead of marking prices on individual products, the retailers could display prices through rack labels and use a barcode scanning system[6].
Key Provisions and Compliance Framework
The relaxation granted under the Advisory covers scenarios where GST rates have increased (requiring inclusion of additional tax amounts) or decreased (allowing reduction in the declared MRP). Further, the Advisory clarifies that any packaging material or wrapper that could not be exhausted by manufacturers, packers, or importers prior to the GST revision may be used for packing, up to March 31, 2026, or until such stock is exhausted, whichever is earlier. Companies can correct the MRP on such packaging by stamping, putting sticker, or online printing at any suitable place on the package, thereby allowing for cost-effective compliance solutions. This timeframe accommodates inventory management and enables businesses to clear existing stock without compliance violations.
Additionally, businesses must adhere to the following when implementing revised MRP declarations:
Preservation of Original MRP
The revised price shall not overwrite or obstruct the original MRP, which too must be displayed. This requirement ensures transparency for consumers and maintains the integrity of the original information.
Price Revision
As per Rule 18(3) of the LMPC Rules, the difference between the originally printed retail sale price and the revised price shall not exceed the extent of increase in tax or in cases of tax reduction, the revised price shall not exceed the price after appropriate tax reduction, such that any MRP revision is directly correlated to the actual tax impact.
Notification Requirements
The Advisory waives the requirement under Rule 18(3) of the LMPC Rules to publish at least two advertisements about revised prices in one or more newspapers. Instead, manufacturers, packers, or importers are now required to send only circulars to the dealers and retailers about revised prices, with copies endorsed to authorities at both the central and state level. This simplified requirement reduces procedural burden while maintaining market transparency and provides the regulator with adequate notice and information.
Implications, Challenges and Considerations
For Businesses
This Advisory provides significant relief for businesses grappling with tax compliance and legal metrology requirements, enabling them to avoid substantial costs associated with repackaging or relabelling entire inventory stocks. The Advisory also clarifies that manufacturers, packers, importers, or their representatives can voluntarily declare revised unit sale prices on unsold pre-packaged commodities or unused packaging material bearing pre-printed MRP.
For Consumers
Advisory maintains consumer protection through several mechanisms. For instance, the requirement to maintain original MRP visibility ensures consumers can identify price changes where manufacturers, packers or importers have chosen to voluntarily affix the revised price sticker. The enhanced communication requirements, including use of electronic, print, and social media channels, ensure consumer awareness of price changes while reducing compliance burden on businesses.
Conclusion
It is pertinent to note that GST rate reductions or rationalizations are implemented by the government with the expectation that such benefits will be passed on to consumers through reduced retail prices[7]. The Advisory provides regulatory relief by making MRP revision voluntary, enabling businesses to implement price reductions on existing inventory without the burden of repackaging while ensuring consumer benefits from GST rate reductions. This Advisory represents a pragmatic regulatory approach that balances business needs with consumer protection.
For businesses dealing in pre-packaged commodities, this Advisory grants enhanced flexibility by clarifying that MRP revision is voluntary while significantly simplifying compliance procedures through waiver of newspaper advertisement requirements. The deadline of March 31, 2026, for using old packaging material, requires businesses to prioritise, plan and implement compliance measures to maximise the benefits of this regulatory relief, whilst ensuring full adherence to the prescribed conditions.
[1] The advisory bearing number I-10/14/2020-W&M dated September 18, 2025 issued by Department of Consumer Affairs, Government of India bearing subject – “GST revision – Permission by Central Govt., under Rules 33 of the Legal Metrology (Packaged Commodities) Rules, 2011, to relax provisions contained in Rule 18(3) – reg.”
[2] The advisory bearing number I-10/14/2020-W&M dated September 9, 2025 issued by Department of Consumer Affairs, Government of India bearing subject – “Permission to the manufacturers or packers or importers of pre-packaged commodities to declare the revised retail sale price (MRP) on the unsold stock – Change in GST rates of goods & Services – reg.”
[3] Press Information Bureau, Government of India dated September 3, 2025 -“ Frequently Asked Questions (FAQs) on the decisions of the 56th GST Council held in New Delhi”, Press Release ID: 2163560
[4] Press Information Bureau, Ministry of Consumer Affairs, Food and Public Distribution, Government of India dated September 29, 2017 titled – “ Permission to display revised MRP due to Implementation of GST extends up to 31st December, 2017: Shri Ram Vilas Paswan” available at – Permission to display revised MRP due to Implementation of GST extends up to 31st December, 2017: Shri Ram Vilas Paswan and Office letter bearing number WM-10(31)/ 2017, issued by Legal Metrology Division, Ministry of Consumer Affairs dated December 23, 2017, available at https://cwnm.nic.in/gst.pdf
[5] Ibid
[6] Order No. WM-10(54)/2016 dated December 4, 2017 by Legal Metrology Division, Ministry of Consumer Affairs, Food and Public Distribution, Government of India
[7] Ministry of Commerce & Industry, Press Information Bureau, Government of India, “GST Rationalisation for a Competitive Economy, Thriving MSMEs, and Consumer Welfare,” Press Release ID: 2163839, September 4, 2025