Rules 11 and 12 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Rule 11 sets the general principle for declaring net quantity, including when the words "when packed" may be used. Rule 12 decides which unit a commodity is declared in, and bars misleading words. The Third Schedule lists the goods that may use "when packed", and the Fourth Schedule lists the goods allowed a different unit.
The net quantity excludes wrappers and other materials. If a commodity will not vary in weight or measure with environment, the declared quantity must be what the consumer receives, with no "when packed". Soaps, lotions, creams (other than cream of milk) and camphor are the goods listed for the "when packed" qualifier. By default the unit is mass for solids, volume for liquids, length, area or number as sold, unless the Fourth Schedule says otherwise. Words such as "approximately" that mislead about quantity are barred.
Where these rules fit
Rule 6(1)(c) requires the net quantity on the pack in the standard unit or by number. Rules 11 and 12 set out how. Rule 13 sets the units themselves (see rule 13). The text used here is the Packaged Commodities Rules as amended up to G.S.R. 226(E) of 28 March 2022. Quantity declarations are checked at inspection under rule 19, so the wording matters; our FSSAI label compliance service covers label review.
Rule 11: general provisions
| Sub-rule | Text in substance |
|---|---|
| 11(1) | In declaring net quantity, the weight of wrappers and materials other than the commodity shall be excluded |
| 11(2) | Where a commodity is not likely to undergo any variation in weight or measure on account of environmental conditions, the declared quantity must correspond to the net quantity the consumer will receive, and must not be qualified by "when packed" or the like |
| 11(3) | Save as provided in (4), where a commodity is likely to vary with environmental conditions but the variation is negligible, the declaration must be made after taking the variation into account so that the consumer receives not less than the declared net quantity, and again without "when packed" |
| 11(4) | For commodities likely to undergo significant variations on account of environmental or other conditions, the declaration may be qualified by the words "when packed", as specified in the Third Schedule |
So there are three situations: stable goods, negligibly variable goods, and significantly variable goods. Only the third may use "when packed", and only for goods the Third Schedule names. The printed rule 11(1) ends with a stray "--" after the word "excluded"; the meaning is clear and unaffected. "Significant" and "negligible" are not defined in the Rules; the text gives no percentage.
The Third Schedule
Headed "Declaration of quantity in relation to commodities (sold by weight or volume) which may be qualified by the words 'When packed'", it lists four items:
- All kinds of soaps
- Lotions
- Cream (other than cream of milk)
- Camphor (inserted by G.S.R. 385(E) of 14 May 2015)
The Schedule applies to goods sold by weight or volume. A biscuit packet cannot use "when packed", since biscuits are not in the list. Even for a listed good, the Rule 11(4) condition of significant variation applies.
Rule 12: manner of declaring quantity
| Sub-rule | Text in substance |
|---|---|
| 12(1) | The quantity is expressed in a unit of weight, measure or number, or a combination, that gives accurate and adequate information to the consumer |
| 12(2) | Except for Fourth Schedule goods, use mass for solid, semi-solid, viscous or solid-liquid mixtures; length if sold by linear measure; area if sold by area measure; volume if liquid or sold by cubic measure; number if sold by number |
| 12(3) | Where quantity is declared by mass, the manufacturer, importer or packer may, at option, add the number of commodities in the package |
| 12(4) | Where weight, measure or number is not enough to inform the consumer of the dimensions or number, the declaration must be accompanied by dimensions or number, or both, where necessary |
| 12(5) | Additional information about the commodity shall appear on the same panel as the other required information |
| 12(6) | No word or expression creating an exaggerated, misleading or inadequate impression of quantity |
| 12(7) | For packs of ten cubic cm or less, the declaration is on a tag, card, tape or similar device affixed to the container, which also carries a mark or inscription identifying the manufacturer or packer |
Rule 12(6): the wording bar
The consolidation shows two versions. The first listed examples: "minimum", "not less than", "average", "about", "approximately". G.S.R. 784(E) of 24 October 2011 replaced it with a general bar on "any word or expression, of any sort whatsoever, which tends to create or is likely to create an exaggerated, misleading or inadequate expression as to the quantity". The general bar is the current text. The examples no longer appear, but words of that kind plainly fall within a bar on misleading or inadequate impressions.
The Fourth Schedule
The Fourth Schedule (see rule 12(2)) lists commodities that may be sold by a unit different from the default. The printed table has 26 entries. Samples:
| Commodity | Declared in |
|---|---|
| Aerosol products | Weight |
| Acids in liquid form | Weight or volume |
| Curd | Weight |
| Electric cables and wire | Length or weight |
| Fruits, all kinds | Number or weight |
| Honey, malt-extract, golden syrup, treacle | Weight |
| Ice cream and similar frozen products | Footnote: "volume" replaced by "Weight" (G.S.R. 784(E), 2011), then "weight or volume" (G.S.R. 426(E) of 5 June 2012) |
| Liquefied petroleum gas | Weight |
| Ready-made garments | Number |
| Sauces, all kinds | Weight |
| Yarn | Weight or length of yarn |
The full table also covers edible oils, vanaspati, ghee and butter oil (weight or volume), paints, tyres and tubes (number), cosmetics (weight or measure) and others. Read the printed Schedule itself for the complete list.
Practical examples
Example 1. A soap maker packs 100 g bars that lose moisture in storage. Soaps are in the Third Schedule, so the label can say "100 g when packed" if the variation is significant.
Example 2. A mineral water bottle says "approximately 1 litre". Rule 12(6) bars expressions that create a misleading impression of quantity, and "approximately" is of that kind.
Example 3. A sauce is declared by volume. The Fourth Schedule lists sauces, all kinds, for declaration by weight, so the pack must be declared by weight.
Need help with quantity declarations?
A wrong unit or a borrowed "when packed" qualifier can turn a correct fill into a non-conforming pack. Our FSSAI label compliance service can match each SKU with the unit and wording the Rules call for.
Key takeaways
- Net quantity excludes wrappers and materials other than the commodity.
- "When packed" is allowed only for significantly variable goods, and the Third Schedule lists soaps, lotions, cream other than cream of milk, and camphor.
- The default unit is mass, length, area, volume or number according to how the commodity is sold, subject to the Fourth Schedule.
- Words that create an exaggerated, misleading or inadequate impression of quantity are barred.
- Packs of ten cubic centimetres or less declare quantity on a tag, card or tape.
Read next
- Rule 10 of the Packaged Commodities Rules, 2011: Name and address of manufacturer, packer, importer
- Rule 13 of the Packaged Commodities Rules, 2011: Units of weight, measure or number
- Rule 6 of the Packaged Commodities Rules, 2011: Generic name, net quantity and dimensions
- Requirement of standard quantities in packaged goods
Disclaimer: Based on the Legal Metrology (Packaged Commodities) Rules, 2011 (as amended up to March 2022; check later amendments), read with the Legal Metrology Act, 2009 (Act 1 of 2010), as on 30 September 2026. The Jan Vishwas (Amendment of Provisions) Act, 2023 (in force) and the Jan Vishwas (Amendment of Provisions) Act, 2026 (in force only from the date the Central Government notifies) amend the Act's penalty sections, not rules 11 and 12. State Legal Metrology rules, later amendments and notifications change; verify the current position before acting.
