Rules 24 and 25 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 24 lists the three declarations every wholesale package must carry. Rule 25 says an export package cannot be sold in India unless the manufacturer or packer has repacked or relabelled it to the Indian standard. Together they make Chapters III and IV of the Rules, each only one rule long.
A wholesale package must show (a) the name and address of the manufacturer or importer (or the packer, where different), (b) the identity of the commodity, and (c) the number of retail packages inside or the net quantity in standard units. The rule does not apply where another law requires similar declarations. An export package may be sold in India only after repacking or relabelling in line with Chapter II; if not, it is liable to be seized under the Act.
Rule 24: declarations on a wholesale package
What is a wholesale package?
Rule 2(r) defines it as a package containing (i) a number of retail packages, intended for sale, distribution or delivery to an intermediary and not intended for sale direct to a single consumer; or (ii) a commodity sold to an intermediary in bulk so that the intermediary can sell it to consumers in smaller quantities; or (iii) ten or more retail packages, provided the retail packages are labelled as the Rules require. The Rules also define "institutional consumer" in rule 2(bc): an institution buying packaged commodities bearing a declaration "not for retail sale", directly from the manufacturer, an importer or a wholesale dealer, for its own use and not for commercial or trade purposes.
The three declarations
Rule 24 says every wholesale package "shall bear thereon a legible, definite, plain and conspicuous declaration" as to:
| Clause | Declaration |
|---|---|
| (a) | The name and address of the manufacturer or importer or, where the manufacturer or importer is not the packer, of the packer |
| (b) | The identity of the commodity contained in the package |
| (c) | The total number of retail packages in the wholesale package, or the net quantity in standard units of weight, measure or number of the commodity in the wholesale package |
Note what is not in the list. Rule 24 does not ask for a retail sale price, a date of manufacture or the consumer care details required for retail packages by rule 6. A wholesale carton that also contains loose retail packs must of course have those retail packs labelled under Chapter II; that is the point of limb (iii) in the definition.
The proviso
"Nothing in this rule shall apply in relation to a wholesale package if a declaration similar to the declarations specified in this rule, is required to be made on such wholesale packages by or under any other law for the time being in force." So where another law prescribes similar wholesale declarations, for example a sector law, that law's requirement governs. The rule does not name the other laws; check the sector regime that applies to you. For food, the Rules defer some matters to the Food Safety and Standards Act, 2006 (see rule 6(1) and FSSAI label compliance).
If you pack cartons for distributors and want the carton marking reviewed, our FSSAI label compliance team can look at the label set together with the legal metrology declarations.
Rule 25: export packages sold in India
Rule 25 reads in full: "An export package shall not be sold in India unless the manufacturer or packer has re-packed or relabeled the commodity in accordance with the provisions contained in Chapter II, and where any export package is sold in India without such re-packing or re-labeling, such package shall be liable to be seized in accordance with the provisions of the Act."
What it means.
- The Rules do not define "export package". Read it in the ordinary sense of a package made up for shipment abroad, and expect the officer to read it the same way.
- Chapter II is the regular regime for pre-packaged commodities: declarations (rule 6), display (rules 7 to 9), quantity (rules 11 to 13), and standard packages (rule 5). An export label that does not meet these cannot be used in India.
- The obligation falls on the manufacturer or packer to repack or relabel. A trader who buys such goods and sells them without relabelling is exposed to seizure of the goods under the Act.
- The rule says "liable to be seized". It does not itself create an offence or set a fine; action for the non-conforming declarations goes through section 36 of the Act (see section 36).
The export side in the Act
Rule 25 is about the Indian market. On the export side, the Act carves out exports in a few places: section 8(4)'s proviso exempts manufacture of weights or measures done exclusively for export from the standards in section 8; section 11(2) says section 11(1) on quoting in standard units does not apply for export of goods, things or services; and section 55(c) says the Act's verification and stamping provisions do not apply to a weight or measure manufactured exclusively for export. The Packaged Commodities Rules, in the consolidated text we hold, do not contain a general export exemption from Chapter II. For weights and measures made exclusively for export, the General Rules have their own chapter; see rules 16 to 18 of the General Rules.
If your business exports and also sells surplus or rejected lots at home, the registration and documentation for the export side are a separate matter; our IEC registration service covers the export code and not the labelling rules discussed here.
Practical examples
Example 1. A manufacturer ships cartons of 24 retail packs to a distributor. The carton shows the manufacturer's name and address, the product name and "24 packs of 100 g". That meets rule 24(a), (b) and (c). The retail packs inside must themselves meet Chapter II.
Example 2. A packer has a lot of snack packs labelled for an overseas buyer, with no MRP and with the quantity in ounces. The buyer cancels. Before any of it is sold in India, rule 25 requires the packer to repack or relabel the commodity to Chapter II, meaning declarations such as MRP and net quantity in standard units. Selling it as is makes the packs liable to seizure.
Need help with wholesale or export labels?
Carton marking and the relabelling of goods meant for export raise questions under both the Rules and sector laws. Our FSSAI label compliance service can check your retail and wholesale labels together, and our IEC registration service covers the export code for exporters.
Key takeaways
- A wholesale package needs three declarations: manufacturer or importer or packer, identity of the commodity, and the number of retail packs or net quantity.
- Rule 24 does not apply where another law requires similar wholesale declarations.
- An export package cannot be sold in India unless repacked or relabelled to Chapter II.
- Unrelabelled export packages sold in India are liable to seizure under the Act.
- The Act's export carve-outs (sections 8(4), 11(2), 55(c)) do not override rule 25.
- Rules as amended up to March 2022; check later amendments.
Read next
- Rule 5 of the Packaged Commodities Rules, 2011: Standard packages and the Second Schedule
- Rule 26 of the Packaged Commodities Rules, 2011: Exemptions
- Rule 18 of the Packaged Commodities Rules, 2011: Wholesale and retail dealers
- Legal Metrology (Packaged Commodities) Rules 2011: overview
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 and procedure sections, not sections 8, 11 or 55 or rules 24 and 25. State Legal Metrology rules, later amendments and notifications change; verify the current position before acting.