Rule 4 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 4 is the gateway rule of Chapter II of the Packaged Commodities Rules. It says no one may pre-pack a commodity for sale, distribution or delivery unless the package, or a securely affixed label, carries the declarations the Rules require. It also carries a factory-premises explanation and a rule for packs grouped together on a promotional offer.
Under rule 4(1), no person may pre-pack, or cause or permit pre-packing of, a commodity for sale, distribution or delivery unless the package bears the declarations required by the Rules, printed on it or on a securely affixed label. Packages without the retail sale price may exist inside the manufacturer's premises, but every package leaving the premises must carry it. When packages are grouped for a promotional offer, every package in the group must comply with rule 6.
Where rule 4 sits
The Legal Metrology Act, 2009 leaves the detail of pre-packaged commodity declarations to delegated legislation. Section 18 of the Act bars dealing in a pre-packaged commodity that lacks the prescribed quantity and declarations, and the Packaged Commodities Rules are the delegated rules made under the rule-making power in section 52. Rule 4 is the first operative rule of Chapter II, which the Rules title "Provisions applicable to packages intended for retail sale". Label teams often pair this rule with food-label checks, which sit under our FSSAI label compliance service. Our article on section 18 of the Act deals with the parent provision; this article deals with the rule.
The text used here is the consolidated Packaged Commodities Rules with amendments up to G.S.R. 226(E) of 28 March 2022. Later amendments are not in it, so check the current text before relying on a detail.
Rule 4(1): the prohibition on pre-packing
The rule opens "On and from the commencement of these rules". The Rules came into force on 1 April 2011 (rule 1(2)). It then says no person shall "pre-pack or cause or permit to be pre-packed any commodity for sale, distribution or delivery" unless:
- the package bears the required declarations on itself; or
- a label bearing them is securely affixed to it.
Three points follow from the wording.
- Who it binds. "No person" covers a manufacturer, a packer, a contract packer and a brand owner who has the goods packed for it. The words "cause or permit" reach the principal who instructs a packer or allows packing to go on, not only the person who runs the machine. Whether a particular person is the manufacturer or the packer is worked out with the definitions in rule 2 (see rule 2).
- What triggers it. The trigger is packing the commodity for sale, distribution or delivery. The rule is about the moment of pre-packing, before the goods move.
- Which declarations. Rule 4 does not list them. It points to "such declarations as are required to be made under these rules", that is, rule 6 and the rules that follow it, which our other articles in this series take one by one.
"Securely affixed" matters in practice. A label that peels off in transit, or a loose insert, is not obviously "securely affixed", and the text gives no test beyond those two words. Where a declaration must be on the principal display panel, rule 7 and rule 8 add requirements of their own.
The Explanation: packages inside the factory
The Explanation to rule 4(1) reads in substance as follows. The existence of packages without the declaration of retail sale price within the manufacturer's premises is not a violation of the Rules. The manufacturer must ensure that all packages leaving the premises for their destination carry the retail sale price declaration required by the rule.
So the Explanation gives limited room on price only. It says nothing that excuses a missing net quantity or a missing manufacturer name on a package that leaves the gate. A typical use is a warehouse that holds unlabelled or part-labelled stock awaiting the final price sticker or print, provided the stock is finished before dispatch.
Rule 4(2): promotional offer packs
Rule 4(2) says that when one or more packages intended for retail sale are grouped together for being sold as a retail package on promotional offer, every package of the group must comply with rule 6.
In plain terms, a "buy one, get one" bundle or a shrink-wrapped twin pack cannot hide a non-compliant pack inside a compliant outer wrap. Each item in the group must carry its own rule 6 declarations. The text does not say that the outer wrap alone can carry them. If the outer wrap is a package in its own right, rule 9(3) on outer containers also applies (see rules 8 and 9).
A note on the source: in the consolidated text the same promotional-offer wording appears twice, once as rule 5(2) (inserted by G.S.R. 427(E) of 5 June 2012) and once as rule 4(2). The footnote attached to rule 4 says "Substituted vide GSR 779(E) dated 2nd November, 2021 w.e.f. 1.4.2022 (now w.e.f 01.10.2022 vide GSR 226(E) dated 28.3.2022)", but the asterisks in the printed text do not make clear which sub-rule it refers to. We therefore do not say exactly which version changed. The substance of rule 4(2) is as stated above. Rule 5 itself is shown as omitted (see rule 5).
At a glance
| Part | What it says | Who is affected |
|---|---|---|
| Rule 4(1) | No pre-packing for sale, distribution or delivery unless declarations are on the package or a securely affixed label | Manufacturers, packers, anyone who causes or permits packing |
| Explanation | Unpriced packages inside the factory are not a violation, but every package leaving must show the retail sale price | Manufacturers |
| Rule 4(2) | Each package in a promotional group must comply with rule 6 | Brands and packers of combo or bundle offers |
What rule 4 does not say
- It does not say which declarations are needed. Read rule 6 and the rules after it.
- It does not set a penalty. Breach of the Rules is dealt with through section 36 of the Act where the package does not conform to the declarations, and through rule 32 and the Act's other penalty sections. See our articles on section 36 and on rules 32 and 32A in this series.
- It does not apply to everything. Rule 3 excludes certain large packages and packages for industrial or institutional consumers from Chapter II, and the text of rule 3 has two versions in the consolidation, the later one being substituted by G.S.R. 629(E) of 23 June 2017 (see rules 1 and 3).
- For food packages, the Rules defer several declarations to the Food Safety and Standards Act, 2006. Explanation III to rule 6(1)(a) says so for the name and address clause, and the provisos to clause (d) say so for dates.
Practical examples
Example 1. A biscuit manufacturer stores finished but un-priced cartons in a bonded corner of its plant while waiting for a revised price to be decided. Under the Explanation, unpriced packages inside the premises are not a violation, but each carton must show the retail sale price before it is dispatched.
Example 2. A soap brand sells a pack of three bars wrapped together as an introductory offer. One of the three bars, packed earlier, carries an old label without the net quantity. Rule 4(2) requires every package in the group to comply with rule 6, so the group should not be sold until that bar is relabelled.
Need help with pre-packing compliance?
If you pack your own goods or use a contract packer, the label file should be checked against the Rules before the first dispatch, not after an inspection. You can start with our FSSAI label compliance service and bring the artwork, the pack and your dispatch process.
Key takeaways
- Rule 4(1) bars pre-packing for sale, distribution or delivery unless the required declarations are on the package or a securely affixed label.
- "Cause or permit" extends the duty beyond the person operating the packing line.
- The Explanation excuses missing price declarations only inside the factory; every package leaving must show the retail sale price.
- Under rule 4(2), every package in a promotional group must meet rule 6.
- The text is as amended up to March 2022; later amendments must be checked.
Read next
- Rule 5 of the Packaged Commodities Rules, 2011: Standard packages and the Second Schedule
- Rule 6 of the Packaged Commodities Rules, 2011: Name, address and country of origin
- Section 18 of the Legal Metrology Act, 2009: Declarations on pre-packaged commodities
- Mandatory declarations on pre-packaged commodities
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 related sections, not rule 4. State Legal Metrology rules, later amendments and notifications change; verify the current position before acting.