Rule 4

Rule 4: pre-packing and sale of packaged commodities

Rule 4 connects the act of pre-packing with the declarations required on the package or a securely affixed label. Its May 2026 amendment permits qualifying importers to make mandatory declarations in specified bonded warehouses, provided each retail pack is complete before it leaves.

Need advice on Rule 4?

This article is for general information. Check the notified Rules and later amendments. For advice specific to your business, contact Bizeneed.

Introduction

For a commodity pre-packed for sale, distribution or delivery, first check whether Chapter II applies to the package. Rule 4(1) then requires the declarations specified elsewhere in these Rules to be on the package or a securely affixed label. It does not itself list every declaration.

The 2026 Explanation-2 addresses a particular import workflow: mandatory declarations may be made in the bonded warehouse of an Authorised Economic Operator (AEO) Tier-2 or Tier-3 certified operator in India. All required declarations must be on the retail package before it leaves that warehouse.

Key takeaways

Label the covered package

Before a covered commodity is pre-packed for sale, distribution or delivery, identify the declarations required under the applicable Packaged Commodities Rules and place them on the package or a securely affixed label.

Check each pack in a promotional group

Rule 4(2) requires every retail package grouped for a promotional offer to comply with Rule 6; an outer promotional wrap alone is not the answer.

AEO warehouse timing is conditional

The May 2026 Explanation-2 allows importers to make mandatory declarations at AEO Tier-2 or Tier-3 certified operators' bonded warehouses, but the retail packages must carry all mandatory declarations before leaving.

Do not infer an exemption

The warehouse clarification changes where declarations may be made in that qualifying workflow; it does not waive the underlying package declarations.

Check the package and sale channel

Determine whether the commodity is pre-packed for sale, distribution or delivery and whether Chapter II applies. Identify any product-specific label rules before approving artwork.

Prepare the required declarations

Use the current declaration rules for the product and package. Rule 4 requires those declarations on the package or a securely affixed label. Its Explanation-1 clarifies that packages without retail sale price inside the manufacturer's premises are not by that fact a violation, but packages leaving those premises must carry the required price declaration.

Handle promotional groups pack by pack

Where retail packages are grouped for a promotional offer, verify each constituent package against Rule 6. Keep the individual-pack and grouped-pack artwork in the release record.

Apply the 2026 import warehouse clarification

For an importer using a bonded warehouse of an AEO Tier-2 or Tier-3 certified operator in India, verify that the facility and operator meet the stated condition. Complete and inspect all mandatory declarations on every retail package before it leaves that warehouse; retain a release checkpoint record.

Practical checklist

Do

Identify the current declarations applicable to each commodity and package format.
Inspect each retail pack in a promotional group.
For the qualifying AEO warehouse workflow, retain evidence that labels were complete before dispatch.

Avoid

Do not treat a promotional outer pack as a substitute for Rule 6 compliance by its constituent retail packs.
Do not describe any bonded warehouse as automatically covered by Explanation-2.
Do not release a qualifying imported retail pack from the bonded warehouse with missing mandatory declarations.

FAQs

Can an importer label goods after customs arrival?

The 2026 Explanation-2 permits mandatory declarations at bonded warehouses of AEO Tier-2 or Tier-3 certified operators in India, with all mandatory declarations on retail packs before they leave those warehouses. Other workflows require a separate check.

Does a promotional combo need declarations on each component?

Rule 4(2) says every retail package grouped for a promotional offer must comply with Rule 6.

Official sources

Need help applying this rule?

Discuss packaged-commodity labels