Rule 6 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 6(1)(a) says who must be named on a package: the manufacturer, and where the packer is someone else, the packer as well, and for an imported package the importer. Clause (aa) adds the country of origin of imported products. Three Explanations decide who is held responsible when the label is unclear.
Every package must carry a definite, plain and conspicuous declaration of the name and address of the manufacturer; if the manufacturer is not the packer, both; for an imported package, the importer. A company name with no qualifying words is presumed to be the manufacturer. A brand owner shown as a marketer is held responsible, and where several names appear, prosecution is launched against the one named first. Imported products must show the country of origin. Food packages follow the Food Safety and Standards Act, 2006 for this clause.
The lead-in to rule 6(1)
Rule 6(1) begins: "Every package shall bear thereon or on label securely affixed thereto, a definite, plain and conspicuous declaration made in accordance with the provisions of this chapter". Clause (a) is the first declaration on that list. The text used here is the Packaged Commodities Rules as amended up to G.S.R. 226(E) of 28 March 2022.
For the statutory duty behind it, see section 18 of the Act. For the rule on how complete the address must be, see rule 10. The label review that joins these rules to food labelling is part of our FSSAI label compliance service.
Clause (a): who is named
| Situation | Who must be named |
|---|---|
| Manufacturer also packs | Name and address of the manufacturer |
| Manufacturer is not the packer | Name and address of the manufacturer and of the packer |
| Imported package | Name and address of the importer |
The clause reads: "the name and address of the manufacturer, or where the manufacturer is not the packer, the name and address of the manufacturer and packer and for any imported package the name and address of the importer shall be mentioned."
"Manufacturer", "packer" and "dealer" are defined in rule 2. The definition of manufacturer in rule 2(d) includes a person who puts a mark on a package which claims that the commodity was made by that person, even if someone else produced it. So a trading brand that puts its own mark on goods made elsewhere can be treated as a manufacturer. See rule 2.
The three Explanations
The Explanations to clause (a) settle who answers for a label.
Explanation I. If the name and address of a company is mentioned on the label without any qualifying words such as "manufactured by" or "packed by", it is presumed to be that of the manufacturer, and liability is determined accordingly. So a bare company name at the foot of a label is treated as the manufacturer's name.
Explanation II. If the brand name and address of the brand owner appear on the label "as a marketer", the brand owner is held responsible for any violation of the Rules, and action is initiated against the "deemed manufacturer". Where more than one name and address appear on the label, prosecution is launched against the manufacturer indicated in the first place on the label, and not against all of them.
Explanation III. For packages containing food articles, the provisions of the clause do not apply; the Food Safety and Standards Act, 2006 and the rules made under it apply instead. The printed text shows two versions. The first version said "this sub-rule" and referred to the Prevention of Food Adulteration Act, 1954, which G.S.R. 427(E) of 5 June 2012 replaced by the 2006 Act. The second version, substituted by G.S.R. 629(E) of 23 June 2017 with effect from 1 January 2018, says "this clause" and refers to the 2006 Act. We follow the later wording: the carve-out for food is for clause (a), not for the whole of rule 6(1). We do not state the food label rules themselves; they are not in the sources.
Clause (aa): country of origin
Clause (aa), shown as substituted by G.S.R. 629(E) w.e.f. 1 January 2018, says: "The name of the country of origin or manufacture or assembly in case of imported products shall be mentioned on the package."
Points to note:
- It applies to imported products. It does not add a country-of-origin line to goods made and packed in India.
- The three choices are origin, manufacture or assembly. The text does not say which to use where they differ; the declaration must be accurate for the product.
- It sits beside the importer's name and address in clause (a). Importers also register under section 19 of the Act; see our article on sections 19 and 20 and our importer registration service.
Rule 6(9) separately allows an importer to affix a label on imported packages to make the declarations. See the rule 6(5) to (9) article.
The consequence of a wrong name
The Explanations are about liability. If a brand owner appears on the label as a marketer, it is the deemed manufacturer. If the label carries two names, the one in first place is prosecuted. A business that wants a contract manufacturer to bear the risk should check how the label reads, since the words on the pack, not the contract, decide whom the Explanations point to. The Explanations do not stop a separate claim between the parties under their contract.
The penalty for a package that does not conform to the prescribed declarations is under section 36 of the Act, as amended by the Jan Vishwas Acts. See section 36 for the layers.
Practical examples
Example 1. A skincare brand buys bulk cream from a factory and packs it under its own brand. The label carries only "XYZ Cosmetics Pvt Ltd, Mumbai". With no "manufactured by" or "packed by", Explanation I presumes XYZ to be the manufacturer, and it is held liable accordingly.
Example 2. A label names "Marketed by ABC Brands" first and, below, "Manufactured by PQR Industries". Under Explanation II, ABC as brand owner is held responsible and action is initiated against the deemed manufacturer; if several names appear, prosecution is against the one named first.
Example 3. An imported toy is brought in by an Indian company. The package must show the importer's name and address and the country of origin, manufacture or assembly.
Need help with manufacturer and importer declarations?
If you market under your own brand, use contract packers or import finished goods, the wording on the label decides who carries the liability. Our FSSAI label compliance service can review the address block, the "manufactured by" lines and the origin declaration against the Rules before printing.
Key takeaways
- Clause (a) requires the manufacturer, and where different, the packer, and for imports the importer, to be named with address.
- A company name without qualifying words is presumed to be the manufacturer's.
- A brand owner shown as marketer is held responsible; with several names, the first-named is prosecuted.
- Clause (aa) requires the country of origin, manufacture or assembly on imported products.
- Food packages follow the Food Safety and Standards Act, 2006 for clause (a).
Read next
- Rule 4 of the Packaged Commodities Rules, 2011: Regulation of pre-packing and sale
- Rule 6 of the Packaged Commodities Rules, 2011: Generic name, net quantity and dimensions
- Rule 10 of the Packaged Commodities Rules, 2011: Name and address of manufacturer, packer, importer
- 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 sections, not rule 6. State Legal Metrology rules, later amendments and notifications change; verify the current position before acting.