Govt Eases MRP Revision Rules for Medical Devices Post GST Cut, Stickering Made Voluntary
New Delhi: Responding to industry appeals for easing compliance requirements following a revision in Goods and Services Tax (GST), the Union Consumer Affairs Ministry has relaxed provisions of the Legal Metrology (Packaged Commodities) Rules, 2011, to simplify the process of revising the Maximum Retail Price (MRP) on pre-packaged goods.
On September 11, the Association of Indian Medical Device Industry (AiMeD), along with other trade bodies, urged the government to provide a smooth transition mechanism in light of GST reduction, especially for low-cost, high-volume medical disposables. The industry sought exemption from physical relabelling, flexibility in using old packaging material, and waiver of mandatory newspaper advertisements for revised prices.
Seeking a Smooth Transition Mechanism that is reasonable and implementable, the Association of Indian Medical Device Industry (AiMeD) urged,
(i) To prevent supply chain disruptions in the critical healthcare sector in case of a GST reduction, we thank the Government of India for considering allowing a 3-month transition period till December 31st for relabelling; however, we seek additional exemption of physical relabelling where it's difficult for low-priced, high-volume medical disposables.
(i) This would enable the sale or use of existing pre-printed packaging and stock with prior MRPs without requiring relabeling Since it is not feasible to apply stickers to billions of low- priced disposable Medical Devices, manufacturers could post revised, lower MRP rates on their websites and issue circulars to dealers and trade channel partners Retailers could then be requested to sel products at the reduced MRP based on the new GST rate (AlOCD has assured)
(ii) Alternatively, some of us who can apply labels or posters at pharmacies, announcing a reduction of GST from 12% to 5%, will do so, and in some cases, some manufacturers will also share their QR Code on these posters so that consumers can connect to the weblink of the revised MRP on the manufacturer's website
(iv) We also request exemption from advertisement from the manufacturer in case they are unable to upload the complete, lengthy list of Medical Devices in a single advertisement. Kindly keep this requirement on a voluntary basis or on a basis of printing the QR Code of the revised MRP weblink on the advertisement, or
(v) Alternatively. The manufacturer may share the revised MRP or a Statement of the revision of the GST on their invoice, with a request to retailers to reduce the prices to the consumers by a minimum of 6.25%, where GST has been reduced from 12% to 5%.
Association of Indian Medical Device Industry (AiMeD) further requested, "We humbly request your kind revised labelling guidelines on a voluntary basis as per any of above alternatives as different solution may be feasible for different tevels of manufacturer. This will safeguard the competitiveness of Indian medical device manufacturing. ensuring that health sector reforms also drive industry growth and lower cost gains by Consumers."
Acting on these representations, the Department of Consumer Affairs on September 18 issued a circular allowing manufacturers, packers, and importers to voluntarily affix revised price stickers on unsold stock manufactured before September 22, 2025. The ministry clarified that affixing such stickers is not mandatory as long as the original price remains visible.
The circular read,
" After considering the concerns of the industry and in supersession of earlier advisory dated 09.09.2025, the Central Government, has decided to allow such manufacturers/ packers/ importers/ their representatives who may like to voluntarily affix additional revised price sticker, on unsold packages manufactured before 22nd September, 2025 and are lying with them, provided the original price declaration on the package is not obstructed .In this context, it is underlined that extant Rules do not mandate affixing revised price sticker by manufacturer/packer/ importer/ their representatives on unsold packages manufactured before 22nd September, 2025 and are lying with them."
Further, the government waived the requirement under Rule 18(3) to advertise revised MRPs in two newspapers, instead allowing companies to inform dealers and retailers through circulars. A copy of such circulars must also be endorsed to the Director, Legal Metrology of the Central Government and Controllers of Legal Metrology in all States/UTs to ensure price compliance at the retailer level.
In line with this, the circular reads,
"Apart from above, by virtue of powers vested under Rule 33 of the Legal Metrology (Packaged Commodities) Rules, 2011, the Central Government, has decided to waive off the requirement in Rule 18(3) to issue Advertisement, about revised prices in two newspapers by manufactures and importers."
Furthermore, the ministry has directed manufacturers and importers to take immediate measures to sensitise dealers, retailers, and consumers about GST rate revisions through electronic, print, and social media.
In a major relief, it has also been clarified that packaging material or wrappers printed before the GST revision can continue to be used until March 31, 2026, or until existing stock is exhausted, provided corrected MRPs are stamped, stickered, or printed at any place on the package. Importantly, declaring the revised unit sale price on unsold pre-packaged commodities or unused packaging material with pre-printed MRP has been made voluntary, not mandatory.
The circular read,
"However, the manufacturers/ packers/_importers shall take immediate measures to sensitise dealers/ retailers/ consumers about revision in GST rates through all possible channels of communication, including electronic, print, and social media.It is also clarified that any packaging material or wrapper which could not be exhausted by the manufacturer or packer or importer prior to revision of GST, may be used for packing of material upto 31st March, 2026 or ill such date the packing material or wrapper is exhausted, whichever is earlier, after making corrections required in retail sale price (MRP) on account of implementation of GST by way of stamping or putting sticker or online printing as the case may be, at any place on the package.Further to Para-6 above, it is informed that the declaration of the revised unit sale price on unsold pre-packaged commodities/ unused packaging material or wrapper bearing 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."
Commenting on the development, Rajiv Nath, Forum Coordinator of AiMeD, told Medical Dialogues
"We are very thankful to the empathetic and timely response by the Department of Consumer Affairs in granting us manufacturers permission to sell existing stocks of finished goods and unused packaging materials with old mrp wherever stickering or online inkjet printing could not be feasible.
Without this clarity and permission, the dispatches ex Factory/ warehouses would have come to a standstill and all manufacturers were worried. We had requested both DoCA and NPPA for their kind permission and sought seek this transition support, without which next week's supplies would have been disrupted."
