What does "pre-packaged and labelled" mean in GST? Loose vs packed

Quick answer

Under GST, pre-packaged and labelled means a commodity meant for retail sale, of not more than 25 kg or 25 litre, packed without the buyer present, whose pack must carry Legal Metrology declarations. Such packs of rice, atta or dal pay 5% from 22 September 2025; the same food sold loose, or above 25 kg, is nil.

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A labelled retail pack next to loose grain weighed at the counter
Ashok SachdevUpdated · 5 min read
On this page · 8
  1. Key facts
  2. What does pre-packaged and labelled mean for GST?
  3. Is a 26 kg rice bag, or a bag my shop packs, taxed at 5%?
  4. Which items have a different GST rate when loose and when packed?
  5. Can loose and packed items go on the same bill?
  6. How do I set up loose and packed items in billing software?
  7. How RichPOS helps
  8. Frequently asked questions

Key facts

  • Notification 9/2025-CT(Rate), Explanation (a)(ii): "pre-packaged and labelled" means all commodities that are intended for retail sale and containing not more than 25 kg or 25 litre, which are "pre-packed" as defined in clause (l) of section 2 of the Legal Metrology Act, 2009, where the package or a label securely affixed to it is required to bear the declarations under that Act and its rules. (Source: Notification 9/2025-CT(Rate), as of Oct 2026)
  • The exemption list, Notification 10/2025-CT(Rate), uses the same definition in its Explanation, so a food item is nil when it is not pre-packaged and labelled (for example rice, S. No. 67; atta, S. No. 70; dal, S. No. 39). (Source: Notification 10/2025-CT(Rate), as of Oct 2026)
  • Legal Metrology Act, 2009, Section 2(l): a pre-packaged commodity is one which, without the purchaser being present, is placed in a package, sealed or not, so that the product in it has a pre-determined quantity. (Source: Legal Metrology Act s.2(l), as of Oct 2026)
  • Rule 3 of the Legal Metrology (Packaged Commodities) Rules, 2011 keeps out of its labelling chapter: packages of more than 25 kg or 25 litre; cement, fertiliser and agricultural farm produce in bags above 50 kg; and packs meant for industrial or institutional consumers (as quoted by the Department of Consumer Affairs, 15 July 2024). (Source: Packaged Commodities Rules, Rule 3, as of Oct 2026)
  • CGST Rule 46A lets a registered seller who sells both taxable and exempt goods to an unregistered buyer issue a single invoice-cum-bill of supply. (Source: CGST Rule 46A, as of Oct 2026)

General information, not tax or legal advice.

What does pre-packaged and labelled mean for GST?

It means a retail pack of 25 kg or 25 litre or less, packed before the customer arrived, that the Legal Metrology law requires to carry a label with its declarations. Three tests, and the pack must pass all three to attract 5%.

The three tests in the GST definition (Notification 9/2025 and 10/2025, Explanation (a)(ii))
TestWhat it asksFails the test when
Retail, up to 25 kg or 25 litreIs the pack meant for retail sale and 25 kg / 25 litre or less?The bag is 26 kg, 30 kg or 50 kg
Pre-packedWas the quantity fixed and packed without the buyer present (LM Act s.2(l))?You weigh the dal into a bag in front of the customer
Labelling requiredMust the pack carry Legal Metrology declarations?The pack is outside the labelling rules, such as a pack for an institutional buyer

Note the word "required". A pack that should carry the declarations but does not (no MRP, no net quantity printed) does not become nil. The test is whether the law requires the label, not whether the label is actually there.

The declarations themselves come from the Packaged Commodities Rules: the name and address of the packer, the common name of the product, the net quantity, the month and year of manufacture and the retail sale price (MRP), among others. If a pack carries these, or the law says it must, treat it as pre-packaged and labelled. This is also why a shop that packs its own pouches should print a proper label: the pouch is taxed at 5% once it is pre-packed, and the label keeps you right under the Legal Metrology law as well. Our note on MRP rules for shops covers the price side.

Is a 26 kg rice bag, or a bag my shop packs, taxed at 5%?

A 26 kg bag is above the 25 kg limit, so it is outside the definition and billed at nil. A 5 kg bag your shop fills in the morning and labels for sale is pre-packed, so it is 5%.

Common kirana cases (rice used as the example; the same applies to atta, dal, poha and the other split items)
CasePre-packaged and labelled?GST
Rice weighed out of an open sack in front of the customerNo: the buyer is present, quantity not pre-determinedNil
Branded 10 kg or 25 kg rice bag with MRP and net weightYes5%
Sealed 26 kg or 50 kg rice bagNo: above 25 kgNil
5 kg bags packed by your shop in advance, with a printed labelYes: packed without the buyer, quantity fixed5%
Plain bag filled and weighed at the counterNoNil
Branded 1 kg packs sold by a wholesaler to a retailerYes: the pack is meant for retail sale, at every stage5%
Pack made for a hotel or canteen kitchen (institutional buyer)Usually no: outside the retail labelling chapterAsk your CA

Based on the definition in Notification 9/2025 and 10/2025-CT(Rate) and Legal Metrology Act s.2(l). A July 2024 draft proposed changing Rule 3 of the Packaged Commodities Rules; the GST definition carries its own 25 kg / 25 litre cap whatever the labelling rules say.

Two things often surprise shop owners. First, the wholesaler charges 5% on a carton of 1 kg packs even though nobody in that sale is a household buyer: the pack is meant for retail sale. Second, packing loose stock into your own labelled pouches to sell faster at Diwali changes the rate on those pouches from nil to 5%.

Which items have a different GST rate when loose and when packed?

Mainly cereals, flours, pulses and a few staples: 5% when pre-packaged and labelled, nil when loose. Some lookalike items do not have this split, so check the list before you set rates.

Packed vs loose rule by item (rates in force from 22 September 2025)
ItemHSNPre-packaged and labelledLoose
Rice10065%Nil
Wheat, atta, maida, suji, dalia, jowar, bajra, ragi1001 / 1101 / 1103 / 10085%Nil
Dal and pulses, besan0713 / 11065%Nil
Poha, murmura19045%Nil
Gur (jaggery), khandsari17015%Nil
Makhana085%Nil
Honey04095%Nil
Curd, lassi, buttermilk04035%Nil
Tender coconut water20095%Nil
Salt2501NilNil
Milk0401NilNil
Paneer0406NilNil
Sugar17015%5%
Namkeen, bhujia2106 905%5%
Badam, pista, akhrot08025%5%

From the RichPOS GST rate list (Notification 9/2025 and 10/2025-Central Tax (Rate)). Flavoured yoghurt is 5% packed or not.

Can loose and packed items go on the same bill?

Yes. A registered shop can put nil and 5% lines on one tax invoice; selling taxable and exempt goods to an unregistered customer, it may issue one invoice-cum-bill of supply (CGST Rule 46A).

What matters is that each line carries the right rate, so the tax summary at the bottom of the bill splits nil and 5% sales. Those totals flow into GSTR-1 and GSTR-3B, where exempt and nil-rated sales are reported apart from taxable ones. A bill made of loose items only, with no taxable line, is a bill of supply; see bill of supply vs tax invoice.

How do I set up loose and packed items in billing software?

Make two items, not one: the same HSN, different GST rate. Then the counter cannot bill packed dal at nil or loose dal at 5% by mistake.

  1. Create the loose item Name it clearly, e.g. "Toor dal loose (kg)", HSN 0713, GST 0%, sold by the kg.
  2. Create the packed items One item per pack or brand, e.g. "Toor dal 1 kg pack", HSN 0713, GST 5%, unit piece, with its own barcode.
  3. Keep stock apart Buy loose dal into the loose item and branded packs into the packed item, so stock and GST both stay right.
  4. If you repack When you pack loose stock into labelled pouches, move the quantity from the loose item to a packed item; the pouches now carry 5%.
  5. Check the GST report At month end, the sales report by HSN and rate should show 0713 at both nil and 5%. That is what your CA needs.
Above 25 kg, label the item for what it is, e.g. "Rice 26 kg bag", at nil. Do not let a cashier pick the 25 kg item for it.

How RichPOS helps

RichPOS keeps the GST rate on each item, so a loose item and its packed twin can sit side by side with different rates and never get mixed up at the counter.

  • HSN code and GST rate saved on each item and applied on every bill, with an HSN column on A4 GST invoices
  • Unit conversion (box to piece) for items bought in one unit and sold in another
  • Barcode labels printed from the app for your own packed items
  • GSTR-1 and sales/purchase GST reports by HSN for your CA

What RichPOS does not do: RichPOS does not decide whether your pack is pre-packaged and labelled or give tax advice; your CA confirms that. It does not connect to a weighing scale and needs an internet connection to bill.

FAQ

Frequently asked questions

What is pre-packaged and labelled under GST?

A commodity meant for retail sale, of not more than 25 kg or 25 litre, packed without the buyer present so the quantity is fixed in advance, whose pack must carry Legal Metrology declarations (Notification 9/2025-CT(Rate), Explanation (a)(ii)).

Is GST charged on a 26 kg rice bag?

No. The definition covers packs of not more than 25 kg, so a 26 kg bag is outside it and billed at nil, like loose rice.

My shop packs rice into 5 kg bags with a label. Is that 5%?

Yes, if you pack them before the customer comes and the pack must carry the Legal Metrology declarations. Weighing into a plain bag in front of the customer is a loose sale at nil.

If a pack has no MRP label, is it nil?

No. The test is whether the law requires the declarations, not whether they are printed. A retail pack that should carry a label is still pre-packaged and labelled.

Does a wholesaler charge 5% on packed atta?

Yes. A 1 kg or 10 kg pack is meant for retail sale, so the 5% applies when the wholesaler sells cartons to a retailer too.

Is salt exempt or nil rated?

Salt is nil whether loose or packed (Notification 10/2025, S. No. 109). The salt page explains how nil-rated and exempt are reported.

Is loose sugar exempt from GST?

No. Sugar is 5% whether loose or packed. Gur and khandsari are the ones with a loose exemption.

Free toolHSN and GST rate finder →Search any kirana item to see its packed and loose GST rate and the CBIC source.
Written by Ashok Sachdev

Founder, RichPOS Software. We build RichPOS for Indian shops and write these guides from questions shop owners ask us. Tax rules are quoted from official sources with the date we checked them; confirm your own case with your CA.

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Intro offerRegular price ₹199₹99/monthfirst 3 months · then ₹199