3 Real Compliance Requirements for Packaging Exported to India — FSSAI Food Labels / Legal Metrology Mandatory Declarations / BIS Material Certification: The 3 Compliance Lines Printers Must Distinguish When Accepting Indian Orders
💡 💡 At a Glance
Indian packaging compliance consists of 3 distinct, non-substitutable lines: ① FSSAI food labels under the FSS (Labelling and Display) Regulations 2020 govern content, including the ingredients list, nutrition facts table, shelf life, allergens, vegetarian identification, FSSAI license number, and logo. The responsible party is the FBO, while the printer only typesets the content and is not responsible for its accuracy. ② The Legal Metrology (Packaged Commodities) Rules 2011 govern which mandatory declarations must appear on the package, including the manufacturer and Brand Owner’s complete address, with the Brand Owner identified as “Marketed by” or “Brand Owner”; net quantity; MRP including all taxes; unit price; and consumer complaint channel. These declarations must appear on the PDP, and minimum font sizes apply. The Brand Owner is responsible, while the printer must ensure that every required field is present. ③ Mandatory certification under the BIS Act 2016 and relevant QCO uses the ISI mark for Indian manufacturers and the CRS registration mark for importers; the 2 cannot be interchanged, and use of the ISI mark without a valid license is a criminal offense under Section 29. Key material standards include packaging paper IS 1397, where paper in direct contact with food must not use recycled paper; plastics IS 9833 / IS 10146; and metal cans IS 9396, which must not use lead-based solder. Certification must be completed before clearance of the first shipment. There are 3 practical boundaries: first, the 3 lines have different responsible parties and cannot substitute for one another, making “FSSAI is enough” the most common cause of failure; second, PDP identification is often ambiguous, because gift box clients usually mean the inner-box front visible after opening, while channel auditors check the face displayed on the shelf, so a separate PDP confirmation field is required; third, space on the PDP is limited because the logo, product name, Devanagari mandatory declarations, net quantity, MRP, and FSSAI and BIS marks must all fit. Font sizes must be finalized at prepress: 1.0mm for ≤100g / 100ml and 1.5mm for >200g. Packages below 100cm² may omit the ingredients list, batch number, and nutrition facts table, while packages below 30cm² may omit the production date and shelf life, but gift boxes do not qualify. Before accepting an order, obtain 3 items: a client-signed schedule of mandatory declarations containing the complete address with PIN code and tax-inclusive MRP; Devanagari copy or layout authorization, which must not be replaced with English; and a copy of the BIS certificate after verifying the standard number, material supplier, and mark number.
In April 2026, a baking brand specializing in Indian chestnut crisps approached us to produce 20,000 gift boxes. The design files were complete: brand logo, net weight 400g, product name, ingredients list, nutrition facts table, production date field, and barcode.
The client wrote courteously in an email: “Our previous printer printed it this way too. We shipped 60,000 sets last year without any problems.”
During our prepress compliance review, we found that the artwork contained not a single rupee.
The information required on packaging in India does not follow the same system as the “net weight + ingredients list + barcode” format we are accustomed to. India’s Legal Metrology (Packaged Commodities) Rules, 2011 require pre-packaged commodities to display the following on the Principal Display Panel: the name and complete address of the manufacturer, packer, or importer; net quantity; Maximum Retail Price including taxes (MRP); and a consumer complaint channel. Its definition of the “responsible party” is also broader than in most countries: the Brand Owner itself must be named on the label, and printing only the factory name is insufficient.
This was not our greatest concern. The second compliance line caused us the most concern.
We returned the artwork and the client asked: “Wouldn’t it be enough to add the MRP?”
This article covers 3 things: what each of the 3 compliance lines governs, which 3 documents printers must obtain from clients before production, and how to arrange the column-within-column layout structure of Indian labels without triggering rework.
The First Boundary: The 3 Lines Do Not Substitute for One Another; the Most Common Printer Error Is Assuming That 1 Line Is Enough
Let us first lay out the 3 lines. These are not 3 parallel regulations. They are 3 lines governing different subjects:
| Line | What It Governs | Basis | What the Printer Must Do |
|---|---|---|---|
| FSSAI Food Labels | Content on food packaging: product name, ingredients list, nutrition facts table, shelf life, allergens, vegetarian / non-vegetarian identification, FSSAI license number, and logo | FSS (Labelling and Display) Regulations, 2020 | Typeset according to the client-provided FSSAI label artwork and is not responsible for the accuracy of the content |
| Legal Metrology Mandatory Declarations | The “mandatory declarations on the package” for pre-packaged commodities: manufacturer address, net quantity, MRP, unit price when sold by quantity, and consumer complaint channel | Legal Metrology (Packaged Commodities) Rules, 2011 | Ensure that all these fields are present on the Principal Display Panel |
| BIS Material / Product Certification | Mandatory certification for certain materials and products: packaging paper IS 1397, plastics IS 9833 / IS 10146, metal cans IS 9396, and compulsory CRS registration for certain products | BIS Act 2016 + relevant QCO | Confirm that the client has obtained a valid certificate and the correct mark; the printer only prints the mark |
Each line has its own logic for determining who is responsible. This is the most counterintuitive feature of the Indian market:
- The responsible party under FSSAI is the Food Business Operator (FBO), meaning the company conducting food business in India. The FSSAI license number must appear on the Principal Display Panel, and the logo must be printed in a contrasting color.
- The responsible party under Legal Metrology is the Brand Owner. The regulations explicitly require the Brand Owner’s name and address to appear on the package, using wording such as “Marketed by” or “Brand Owner.” If the printer does not print this information, it is effectively helping the client omit a mandatory statutory declaration.
- The responsible party under BIS is the manufacturer or importer. There are 2 forms of the mark: Indian manufacturers use the ISI mark, consisting of the ISI letters within a circle plus the license number, while importers participating in the Compulsory Registration Scheme use the CRS registration mark. Applying the ISI mark in India without a valid license constitutes a criminal offense under Section 29 of the BIS Act 2016, not merely an administrative penalty.
There is also a structural issue specific to India: the regulations require information in “English or Devanagari”. Printers therefore frequently encounter bilingual copy, with the brand name and marketing text in English while mandatory declarations must also be provided in Devanagari. Many Chinese design files contain no Devanagari font at all, and the issue is often discovered only at prepress. The printer then has to source a font at the last minute or leave the Devanagari position blank and print English instead. The latter is non-compliant in India.
Our current approach is to make the first item on the prepress checklist for Indian orders read “Who will provide the Devanagari mandatory declarations?” If the client provides them, we typeset them as supplied. If the client does not provide them, we reserve the position and mark the artwork in red with “DEVANAGARI REQUIRED HERE.” We never substitute English text.
The Second Boundary: Legal Metrology Requirements for “Printed on the Principal Display Panel” and Font Size Are Stricter Than Most People Expect
This is the most important practical section of the article because it concerns printer responsibility. Errors in FSSAI content are the client’s responsibility, but if a Legal Metrology declaration is omitted, the printer will face the complaints.
First: Principal Display Panel (PDP). These declarations required by law must appear on the Principal Display Panel: the name and complete address of the manufacturer, packer, or importer; net quantity; MRP including all taxes; unit price when sold by quantity; and the consumer complaint channel, by telephone or email.
Our current practice is to include “PDP Face Confirmation” as a separate field on the prepress checklist rather than combining it with “Layout Confirmation.” When a client answers “front,” they are usually thinking of the front seen when the box is opened, whereas the regulations refer to the face displayed and visible on the retail shelf. If this ambiguity is not clarified, the printer bears the cost of rework.
Third: How net quantity must be expressed. This is a challenge specific to India. Net quantity must be expressed in standard measurement units: solids by weight and liquids by volume, using units of g / kg / ml / L. The regulations permit the use of symbols such as “1 N” or “1 U” to declare net quantity when used with a measure word such as number, piece, or pair, but this is an additional form of usage and cannot replace the standard units.
Another question clients frequently ask is: the MRP must be the price “including all taxes.” In other words, the rupee figure printed on the package is the retail price after tax, not the ex-factory price or the price before GST. The printer does not need to calculate this figure, but must clarify it. If the client’s internal quotations to the sales team use tax-inclusive or tax-exclusive prices, the difference is 18% GST. An error means every label in the entire production run is unusable.
- Packaging surface area below 100 cm²: the ingredients list, batch number, nutrition facts table, and directions for use may be omitted.
- Packaging surface area below 30 cm²: the production date, shelf life, and expiry date may be omitted.
Therefore, small seasoning packets and individually wrapped candies in the Indian market can have much simpler labels than those required for comparable domestic export orders. Gift boxes are not included in this exemption. Gift boxes are large, contain multiple items, and are sold at retail, so not a single mandatory declaration may be omitted.
The Third Boundary: On the BIS Line, Printers Must Monitor the “Form of the Mark” and “Applicable Products”
The printer bears the least responsibility under the BIS line, but must monitor the most details because an incorrectly printed mark can result in criminal-level consequences.
There is also a firm requirement: the mark must appear on the product or packaging, and its position and minimum dimensions must comply with BIS requirements. Many clients treat this mark as a decorative element in the design, shrinking it, placing it over a busy background, or overlapping it with the brand logo. The BIS mark must be clearly legible and must not be obscured or distorted.
To discuss applicable products again, this is what printers should ask about first. Mandatory BIS certification is listed product by product, rather than applying to all packaging. The categories that directly affect printers mainly include:
- Food- and drinking-water-contact materials: packaging paper IS 1397 (paper in direct contact with food must not use recycled paper), plastics IS 9833 and IS 10146 (polyethylene containers for drinking water), and metal cans IS 9396 (tinplate steel sheet, which must not use lead-based solder).
- Certain products subject to compulsory registration: packaged drinking water, packaged natural mineral water, certain food additives, and certain packaging materials require registration certificates to be obtained before clearance of the first shipment.
First, does the IS standard number on the client’s certificate match the material actually used for this order? A common situation is that the client’s paper supplier holds an IS 1397 certificate, but the paper purchased for this order was switched to another supplier. The new supplier’s paper has no certification, while the artwork still displays the mark. If there is an incident, no party in the supply chain can clearly establish responsibility.
Second, does the number beneath the mark match the number on the certificate? The string of numbers beneath the BIS mark is the license or registration number. Printing the wrong number is equivalent in substance to not printing the mark at all.
Our current practice for Indian orders is to require a copy of the certificate before printing and verify 3 points: the standard number on the certificate, the material supplier’s name, and the mark number. If any of the 3 do not match, we do not print the mark. We reserve the position and record the reason in the order notes. This is far less costly than being discovered by an authority after the fact.
The 3 Documents to Request from Clients When Accepting Indian Orders
At the operational level, before starting production for an Indian order, our printer must obtain the following 3 items. If any one is missing, layout work is suspended:
- First: a schedule of mandatory declarations (the Legal Metrology set), confirmed item by item and signed by the client. It must include at least: the Brand Owner’s complete postal address, including the PIN code; manufacturer or importer information; net quantity; MRP including taxes; consumer complaint telephone number or email address; and identification of the PDP face. Every field in this schedule must be supplied by the client. The printer cannot fill in the MRP on the client’s behalf or decide the Brand Owner’s address. Our standard response is: “We will print these numbers and names exactly as provided, without changing a single character. However, you must provide us with a signed schedule because, if one of India’s 3 compliance lines is missed, the goods will be detained at a distribution warehouse, which is beyond what we can change.”
- Second: Devanagari copy or clear authorization for the Devanagari layout. If the client asks us to provide the Devanagari text, we typeset it according to the font-size and layout requirements of FSSAI and Legal Metrology. If the client supplies the text, we must confirm that the font covers Devanagari characters. Both scenarios must be settled before proofing and cannot be deferred until mass production.
- Third: a copy of the BIS certificate and confirmation of mark use. This must include the IS standard number, material supplier, mark number, and confirmation that the material actually used for this order is consistent with the certificate. Without this document, we do not create a position for the mark. It is better to leave it blank than to print a mark that may be invalid.
Further Reading
- 3 Special Requirements for Food Packaging Exports to Southeast Asia: Halal/Vietnamese TCVN/Indonesian SNI — Southeast Asian and Indian labeling systems both fall into the category of “multilingual + importer responsibility,” but their approaches to mandatory certification are completely different.
- 4 Categories of Compliance Requirements for Packaging Exports to the EU: REACH/EC 1935/2004/94/62/EC/EN 13427 — the EU framework consists of 2 lines, “materials + responsible party,” and comparing it with India’s 3 lines makes the distinctions clearer.
- 4 Categories of Actual Compliance Requirements for Packaging Exports to the United States: FDA/UL/Prop 65/CPSIA — this also follows the structure in which the printer only prints the mark while the client is responsible for the content, making the division of responsibilities easy to compare.
- 3 Practical Boundaries of Metrological Guarantee Capability for Prepackaged Commodities — net quantity is also subject to strict requirements in China, and the Indian system developed from this foundation.
- 6 Types of Mandatory Food Packaging Identification: Ingredients/Allergens/Shelf Life/Nutrition Facts/Net Quantity/Origin — a comparison between the content covered by the FSSAI line and China’s GB 7718.
FAQ
Is the MRP on Indian packaging a tax-inclusive or tax-exclusive price, and what happens if it is printed incorrectly?
It must be the price including all taxes. Legal Metrology (Packaged Commodities) Rules, 2011 explicitly defines MRP as the maximum retail price inclusive of all taxes, and the standard format is “MRP ₹” followed by the number. The printer is not responsible for calculating this figure, but must clarify it because client quotations to the sales team commonly use tax-exclusive pricing, while GST is 18%. The difference between tax-inclusive and tax-exclusive prices is 18%, and an error means every label in the entire production run is unusable, while labels already printed cannot be changed. Because the client’s procurement and finance departments may use different pricing bases, the client must confirm this once in writing.
If an FSSAI label is already in place, are the Legal Metrology declarations still required?
Yes. These are 2 independent lines, and neither can replace the other. FSSAI governs the “content” on food packaging, including the product name, ingredients list, nutrition facts table, shelf life, allergens, vegetarian / non-vegetarian identification, FSSAI license number, and logo. Legal Metrology governs “which declarations must appear on the package,” including the manufacturer or Brand Owner’s name and complete address, net quantity, tax-inclusive MRP, unit price, and consumer complaint channel. A client saying “FSSAI is enough for us” is the most common cause of failure because Legal Metrology declarations are not included in FSSAI templates. Both lines also occupy the Principal Display Panel, so their layouts must be planned together.
Which face is the Principal Display Panel (PDP) on Indian packaging? Should gift box declarations be printed on the gift box or the inner box?
The regulations refer to “the first face the consumer sees,” meaning the face displayed and visible on the retail shelf. Gift boxes are the most common source of ambiguity. When clients say “front,” they usually mean the front of the inner box seen after opening the package, while channel auditors look at the face of the gift box displayed on the shelf. If the mandatory declarations appear only on the inner box and the exterior of the gift box carries only the brand name, the package may be judged non-compliant. The printer’s approach is to include “PDP Face Confirmation” as a separate field on the prepress checklist rather than combining it with layout confirmation, because what the client means by “front” often differs from what the regulations require.
How small can the font be on an Indian order? What does 1.5mm look like?
Legal Metrology establishes minimum heights for numbers and letters in mandatory declarations and explicitly states that they may be larger but must not be smaller. The FSSAI line has size bands based on package specifications: packages of ≤100g or ≤100ml require a declaration font size of no less than 1.0mm; packages in the 100-200g range require no less than 1.0mm; and packages of >200g require no less than 1.5mm. In an actual layout, 1.5mm is slightly more than 4pt. For a small package such as 400g, the mandatory declaration area must therefore occupy a substantial proportion of the artwork. Font sizes for Indian orders must be finalized at prepress because discovering that the declarations do not fit only after printing is too late. When space is insufficient, sacrificing compliant declarations is usually the result, which is the wrong priority.
Can packaging with a small surface area omit some information? Do gift boxes qualify?
Some information may be omitted, but clear area thresholds apply. For packaging with a surface area below 100 cm², the ingredients list, batch number, nutrition facts table, and directions for use may be omitted. For packaging below 30 cm², the production date, shelf life, and expiry date may be omitted. This is one of the few areas where Indian label design offers some simplification, allowing small seasoning packets and individually wrapped candies to use labels much simpler than comparable domestic export orders. Gift boxes do not qualify for these exemptions because they have a large surface area, contain multiple items, and are sold directly at retail, so not a single mandatory declaration may be omitted.
Can we print a BIS mark supplied by a client on behalf of another company?
No, or at least it cannot be printed directly. Indian manufacturers use the ISI mark, consisting of the ISI letters within a circle plus the license number, while importers participating in the compulsory registration system use the CRS registration mark. The 2 cannot be interchanged. More importantly, the number beneath the mark must match the number on the certificate actually held by the client, and the IS standard number and material supplier covered by the certificate must correspond to the material actually used for this order. A common situation is that the client’s previous paper supplier held an IS 1397 certificate, but the client switched paper suppliers while the artwork still displays the mark. If an incident occurs, no party in the supply chain can clearly establish responsibility. The printer’s approach is to require a copy of the certificate and verify the standard number, material supplier, and mark number. If they do not match, the mark position is not created, even if it must be left blank.
What are the consequences of printing the ISI mark on Indian packaging without a valid license?
The consequences go beyond a fine. Section 29 of the BIS Act 2016 classifies the use of an ISI mark without a valid license and the use of a counterfeit ISI mark as criminal offenses. There is also a separate requirement concerning the form of the mark: it must appear on the product or packaging in compliance with BIS requirements for position and minimum dimensions, and must not be obscured, distorted, or overlapped with the brand logo. Many clients treat the mark as a decorative element in the design, shrinking it or placing it over a busy background, which is precisely the approach most likely to cause serious problems.
Are BIS certification and an FSSAI license the same thing? Can one cover the other?
No. They are independent systems. BIS is the Bureau of Indian Standards’ product and material standards certification system. It determines whether a product or material complies with a specified IS standard, and uses the ISI mark or CRS registration mark. The certification obligation must be completed before clearance of the first shipment. FSSAI is the Food Safety and Standards Authority of India’s food business licensing system. It governs food operator qualifications and label content compliance, using the FSSAI logo together with the license number, and is checked when products circulate in the market. A client saying “We have an FSSAI license, so our materials are compliant too” is one of the most common misconceptions. The parts of BIS certification most directly relevant to printers concern materials and certain products: packaging paper IS 1397, where paper in direct contact with food must not use recycled paper; plastics IS 9833 / IS 10146; and metal cans IS 9396, which must not use lead-based solder.
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