22-Sep-2025 MRP GST Compliance - Revised Instructions

#compliance #gstupdate #govtnotification #packagedcommodities
CA Pratik Mehta

The Government’s advisory dated 18.09.2025 allows voluntary revised price stickers on unsold packs made before 22.09.2025, waives newspaper ads under Rule 18(3), permits use of old packaging till 31.03.2026 with corrected MRP, and requires only dealer circulars to be sent to Legal Metrology authorities.

The Central Government has issued a revised advisory dated 18.09.2025, clearly superseding the earlier advisory dated 09.09.2025. This new directive brings in specific relaxations under Rule 33 of the Legal Metrology (Packaged Commodities) Rules, 2011, particularly in relation to Rule 18(3), with the objective of easing compliance requirements for manufacturers, packers, and importers in light of the recent GST revision.

The Government of India’s Ministry of Consumer Affairs, Food and Public Distribution, Department of Consumer Affairs, Weights and Measures Unit, has issued a crucial letter dated September 18, 2025, regarding the GST revision and granting permission by the Central Government under Rule 33 of the Legal Metrology (Packaged Commodities) Rules, 2011, to relax provisions related to Rule 18(3)-reg. Specifically, the government has decided to allow manufacturers, packers, and importers to voluntarily affix an additional revised price sticker on unsold packages manufactured before September 22, 2025, which are currently lying with them, provided the original price declaration is not obstructed. 

The communication also confirms the waiver of the requirement in Rule 18(3) for manufacturers and importers to issue advertisements about revised prices in two newspapers. Furthermore, it is clarified that pre-printed packaging material prior to the GST revision may continue to be used until March 31, 2026, or until the material is exhausted, whichever is earlier, after making corrections to the retail sale price (MRP).

 

The following actions and relaxations are now applicable to manufacturers, packers, and importers (or their representatives):

 

1. Affixing Revised Price Stickers (Voluntary Action)

• The Central Government has allowed you to voluntarily affix additional revised price stickers on unsold packages.
• This applies only to packages manufactured before September 22, 2025, and currently lying with you.
Crucial Condition: The original price declaration on the package must not be obstructed by the revised sticker.
Note on Mandate: It is underlined that extant Rules do not mandate affixing a revised price sticker on unsold packages manufactured before September 22, 2025, and currently lying with you.
 

2. Waiver of Newspaper Advertisement Requirement

• The Central Government has decided to waive off the requirement in Rule 18(3) of the Legal Metrology Rules, 2011, which required issuing an Advertisement about revised prices in two newspapers. This waiver is granted by virtue of powers vested under Rule 33 of the LMPCR.
 

3. Communication Requirements (Mandatory Action)

Targeted Circulars Only: Manufacturers/packers/importers are now required to send circulars solely to wholesale dealers/retailers, etc., concerning the revised prices.
• A copy of these circulars must be simultaneously endorsed (sent) to the Director, Legal Metrology of the Central Government and the Controller, Legal Metrology of All States/UTs.
• This step is essential to ensure price compliance at the retailer level.

 

Instructions Regarding Packaging Material and Retail Price Declarations

 

4. Usage of Old Packaging Material

• Any packaging material or wrapper that was printed prior to the GST revision and could not be exhausted may be utilized.
• This material can be used for packing material until March 31, 2026, or until the date the packaging material or wrapper is exhausted, whichever occurs earlier.
 

5. Corrections to Retail Sale Price (MRP)

• Upon implementation of GST, corrections to the Retail Sale Price (MRP) on account of the rate change must be implemented by stamping, putting a sticker, or online printing.
• This correction must be made at any place on the package.
 

6. Revised Unit Sale Price Declaration (Voluntary)

• The declaration of the revised unit sale price on unsold pre-packaged commodities or on unused packaging material/wrapper that already bears a pre-printed MRP is not mandatory.
• However, manufacturers/packers/importers/their representatives may declare the revised unit sale price voluntarily, if they so desire.
 

7. Sensitization Measures
 

• Manufactures/packers/importers must take immediate measures to sensitise dealer/retailers/consumers about the revision in GST rates.
• This sensitization should be done through all possible channels of communication, including electronic media, print media, and social media.

 

📄 The enclosed PDF contains the official advisory for your reference

👉 View / Download: Click Here

 

For any clarification or support in complying with these changes, please feel free to reach out to us at pratik@apmh.in.

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