REGULATORY UPDATE – Legal Metrology Rules amend Labelling Framework for Cosmetics & Toiletries

The Ministry of Consumer Affairs, Food and Public Distribution, through the Legal Metrology (Packaged Commodities) Fourth Amendment Rules, 2026, has amended the labelling framework applicable to soap, shampoo, toothpaste and other cosmetics and toiletries. The amendment has been notified vide G.S.R. 826(E) dated 21 September 2026 and is effective from the date of its publication in the Official Gazette.

Key Amendment:

The Central Government has inserted Clause (d) under Rule 6(4A) of the Legal Metrology (Packaged Commodities) Rules, 2011.

Under the amended provision, packages of soap, shampoo, toothpaste, other cosmetics and toiletries are required to carry:

• A red or brown dot for products of non-vegetarian origin; and
• A green dot for products of vegetarian origin.

The prescribed symbol is required to be displayed at the top of the principal display panel of the package.

Omission of Rule 6(8):

The amendment simultaneously omits Rule 6(8) of the 2011 Rules.

Prior to the amendment, Rule 6(8) expressly provided that every package containing soap, shampoos, toothpastes and other cosmetics and toiletries “shall bear” the prescribed red/brown or green dot at the top of the principal display panel. The Delhi High Court reproduced the text of the erstwhile Rule 6(8) in Reckitt Benckiser (India) Ltd. v. Union of India.

The 2026 amendment therefore does more than merely relocate the provision. While the erstwhile Rule 6(8) contained a mandatory “shall bear” formulation, the corresponding declaration has now been placed under Rule 6(4A), which governs additional declarations that may be made by manufacturers, packers and importers.

Regulatory Context:

The amendment follows a regulatory issue that was considered by the Delhi High Court earlier in 2026.

In Reckitt Benckiser (India) Ltd. v. Union of India, the Court noted the inconsistency between the mandatory position under the Legal Metrology Rules and the Drugs Technical Advisory Board (“DTAB”)’s position that the indication could be voluntary. The Court directed the Director, Drug Controller General of India and the Director, Legal Metrology to undertake a joint consultation, including stakeholder consultation, and arrive at a comprehensive decision on whether the indication should be mandatory or voluntary.

Against this background, the amendment is significant because it removes the erstwhile Rule 6(8) and places the corresponding declaration within Rule 6(4A), which deals with additional declarations on packages.

Compliance Considerations for Industry:

Manufacturers, packers and importers dealing with the specified products should:

• review existing packaging and labelling practices in light of the amended Rule 6;
• assess whether the vegetarian/non-vegetarian declaration is made on their products and, where such declaration is used, ensure that the prescribed symbol and placement requirements are followed;
• update internal regulatory checklists and SOPs to reflect the omission of Rule 6(8) and insertion of Rule 6(4A)(d); and
• consider the interaction with applicable requirements under the Cosmetics Rules, 2020, where relevant.

Key Compliance Considerations:

The Legal Metrology (Packaged Commodities) Fourth Amendment Rules, 2026 omit the erstwhile Rule 6(8) and introduce the corresponding vegetarian/non-vegetarian declaration under Rule 6(4A)(d).

Importantly, the new provision is situated within Rule 6(4A), which deals with additional declarations on packages, rather than retaining the earlier “shall bear” formulation of Rule 6(8). Accordingly, the amendment is not merely a renumbering exercise; it changes the statutory provision and framework under which the declaration is made.