Rule 27 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 27 requires anyone who pre-packs or imports a commodity for sale, distribution or delivery to register their name and complete address with the Director or the Controller. It fixes the fee, the 90-day deadline, the contents of the application, the fee for alterations, and what the Registering Authority must do within seven working days.
Every individual, firm, HUF, society, company or corporation that pre-packs or imports any commodity for sale, distribution or delivery must apply to the Director or Controller with a fee of Rs 500. The application is due within 90 days of commencement of the Rules (for existing businesses) or of the start of pre-packing or importing (for new ones). An incomplete application must be returned within seven working days; a complete one gets a registration certificate. An alteration costs Rs 100.
Who must register
Rule 27(1) uses the wording "every individual, firm, Hindu undivided family, society, company or corporation who or which pre-packs or imports any commodity for sale, distribution or delivery". The trigger is the activity, pre-packing or importing, and not the legal form of the business. A trader who only sells packs made by others is not within the wording, but may be a dealer under other rules. The Rules came into force on 1 April 2011 (rule 1(2)).
Importers of packaged goods should not confuse this with the importer registration under section 19 of the Act and rule 15 of the General Rules, which deals with the import of weights and measures; see sections 19 and 20 and rule 15 of the General Rules. For an importer of packaged commodities, rule 27 is the relevant rule. If you import packed goods and want help with the application, our legal metrology importer registration service can guide you through it.
Sub-rule by sub-rule
| Sub-rule | Content |
|---|---|
| 27(1) | Application to the Director or Controller for registration of name and complete address, with a fee of Rs 500 |
| 27(1)(i) | Existing pre-packer or importer: within 90 days of commencement of the Rules |
| 27(1)(ii) | New pre-packer or importer: within 90 days from the date of commencing pre-packing or importing |
| 27(2) | Particulars: (a) name of applicant, (b) complete address of the premises where pre-packing or import of one or more commodities is done, (c) name of the commodity or commodities |
| 27(3) | Alteration in the registration certificate: fee of Rs 100 to the Director or Controller |
| 27(4) | The Director or Controller is the Registering Authority: returns an incomplete application within seven working days of receipt; registers a complete one and grants a certificate |
The 90-day clock
The deadline has two limbs. For a business already pre-packing or importing "on the date of commencement of these rules", that is 1 April 2011, the period ran for 90 days from that date. For a business that starts later, the 90 days run from the date on which it "commences such pre-packing" (the text of clause (ii) says "pre-packing" at the end but "pre-packing or importing" at the start; read it as covering both). The rule does not say when the clock stops for an application returned as incomplete, nor does it provide a late fee.
Complete address
Rule 27(2) says "complete address" has the meaning in the Explanation to rule 10(1). Two versions are printed in the consolidation. The older one defines it as the postal address at which the factory is situated and, in other cases, street name, premises number if any, and the city and State or the PIN code. The substituted Explanation 1 says the postal address at which the factory is situated or company or firm is registered, and, in other cases, the street, premises number if any, city and State, and the PIN code, so that a consumer can identify and locate the manufacturer, packer or importer. See rule 10 for the label rule.
What the rule does not say
Rule 27 is silent on several points a business will want to know:
- The form or portal for the application: no form is named in the text.
- Validity and renewal of the registration certificate: nothing is said, unlike the importer registration in the General Rules, which has a five-year period.
- The premises count: the address is of "the premises at which the pre-packing or import ... is made", and the rule does not say how to register several premises.
- Fees beyond Rs 500 and Rs 100: State practice, if any, is under State rules and is not in our sources.
If you are unsure whether multiple premises need separate applications, take advice before filing. Our existing topical guides on packer registration and on how to register as an importer are starting points, but check them against this text.
The Registering Authority's duties
Rule 27(4) puts a clock on the authority, not only on the applicant:
- Incomplete applications must be returned "within a period of seven working days from the date of receipt of the application".
- Complete applications: the authority "shall register the applicant and grant a registration certificate".
Note that the rule says "shall register". It leaves no discretion to refuse a complete application. The text does not say what happens if the authority misses the seven-day limit. The rule says nothing about deemed registration.
Rules 29 and 30 then deal with the register (open to public inspection without fee) and State-wise lists; see rules 28 to 30.
The consequence of not registering
Rule 32 provides a fine for breach of rules 27 and 28. The consolidation shows layers: fine of Rs 4,000 in the 2011 text as narrowed in 2015 to rules 27 and 28, and later a substituted rule 32 under which contravention of any provision of the Rules for which no punishment is provided draws a fine of Rs 5,000. Details, and compounding, are covered in rules 32 and 32A. Because the text is layered, check the gazette for the figure that applies to your case.
Practical examples
Example 1. A company begins packing spices at its factory on 1 June. Under rule 27(1)(ii) it must apply to the Director or Controller within 90 days of that date, with Rs 500, giving its name, the complete address of the factory and the spices packed.
Example 2. A firm imports packed goods for sale under its own name. It is within the wording "imports any commodity for sale" and must apply; the address in the application is that of the premises where the import is made.
Example 3. A registered packer adds a new product line at the same premises. Rule 27(3) speaks of "alteration in the registration certificate" and charges Rs 100. Whether adding a commodity is an alteration is not spelled out; the application must list the commodities (27(2)(c)), so updating the record is the safe course.
Need help with packer or importer registration?
Rule 27 is short, but the application, the address and the commodity list need to be right. Our legal metrology importer registration service can help you prepare the application and check the State-level process.
Key takeaways
- Anyone who pre-packs or imports a commodity for sale, distribution or delivery must apply to the Director or Controller.
- Fee: Rs 500 for registration; Rs 100 for an alteration in the certificate.
- Deadline: 90 days from commencement of the Rules or from the start of pre-packing or importing.
- Incomplete applications must be returned within seven working days; a complete one must be registered.
- The rule is silent on validity, renewal, forms and portals; State rules may add to it.
- Rules as amended up to March 2022; check later amendments.
Read next
- Rules 28, 29 and 30 of the Packaged Commodities Rules, 2011: Shorter address, registration and lists
- Rules 32 and 32A of the Packaged Commodities Rules, 2011: Fine and compounding sums
- Rule 26 of the Packaged Commodities Rules, 2011: Exemptions
- Legal Metrology (LMPC) registration process, step by step
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 rule 27. State Legal Metrology rules, later amendments and notifications change; verify the current position before acting.