New GST Rate: Manufacturers allowed to use old packaging until March 31, 2026

In a major relief to manufacturers, importers, and packers, the Ministry of Consumer Affairs has issued a fresh circular under the Legal Metrology (Packaged Commodities) Rules, 2011, allowing businesses to skip mandatory re-packaging, re-labelling, and re-stickering of unsold stock following recent GST rate cuts. The circular also extends the use of old packaging material until March 31, 2026, providing an additional three months beyond the earlier deadline.

The move comes just days after the September 9, 2025, advisory, which had left several procedural requirements intact and raised concerns across industry segments about potential supply disruptions, increased compliance costs, and operational bottlenecks.

Key relaxations and benefits for manufacturers

The new circular, dated 18th September 2025, addresses the challenges flagged by industry bodies:

• Re-stickering and re-labelling are voluntary: Businesses no longer need to affix revised price stickers on unsold pre-GST stock. Any updates are voluntary, provided the original MRP remains visible.


• Newspaper advertisement requirement waived: The Rule 18(3) mandate to publish revised prices in two newspapers has been removed. Companies may now send circulars to wholesale dealers and retailers and use electronic, print, and social media channels to communicate revised prices.


• Extended use of existing packaging: Old packaging material can be used until March 31, 2026, instead of the earlier December 31, 2025, deadline, with price corrections applied via stamping, stickers, or online printing.


• Simplified compliance: Businesses are required only to send circulars to trade partners, with copies endorsed to central and state Legal Metrology authorities, ensuring price compliance at the retailer level.

These relaxations are expected to help goods manufacturers avoid operational disruption, reduce compliance costs, and prevent inventory write-offs, particularly for FMCG, pharmaceutical, and packaged goods sectors that often hold large stocks of pre-printed packaging.

How will consumers know the revised prices

While mandatory newspaper advertisements have been waived, the government has emphasised that manufacturers must sensitise distributors, retailers, and consumers about the revised prices through circulars and all available communication channels, including electronic and social media. This ensures transparency and allows consumers to be aware of GST rate reductions without delays.

Comparison with the September 9 advisory

The September 9 advisory had kept several conditions in place, including mandatory newspaper advertisements and no clear extension for old packaging usage, which could have led to logistical and compliance challenges. The September 18 circular supersedes this by introducing:

• Waiver of compulsory re-stickering/re-labelling


• Extended packaging usage till March 31, 2026


• Flexibility in consumer communication through modern channels


• Emphasis on voluntary price stickers


• Industry insiders see this as a practical step that balances regulatory compliance with operational feasibility.

Industry welcomes the relief

Rajiv Nath, Forum Coordinator, AiMeD, welcomed the circular and said, "We are very thankful to the empathetic and timely response by the Department of Consumer Affairs in granting 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, dispatches ex-factory and from warehouses would have come to a standstill. We had requested both DoCA and NPPA for this transition support, without which next week’s supplies would have been disrupted."

Expert perspectives

Experts have described the circular as timely and pragmatic, noting that it protects industry interests while ensuring consumer awareness.

Saurabh Agarwal, Tax Partner, EY, feels, "The clarification that there will be no mandatory requirement for repackaging, relabelling, and restickering is a great relief to the industry and will help avoid significant costs and disruptions. Extending the timeline to use existing packaging material until March 31, 2026, prevents inventory write-offs. Circulars to distributors and retailers ensure price reductions reach the consumer efficiently."

Abhishek Jain, Indirect Tax Head & Partner, KPMG, says, "This clarification resolves ambiguities the industry was facing and will support GST 2.0 in becoming a win-win for both businesses and consumers."

Rajat Mohan, Senior Partner, AMRG & Associates, too quips that "By waiving mandatory newspaper ads and allowing voluntary revised price stickers, the government has eased compliance while safeguarding consumer interests. Extended packaging use till March 31, 2026, reduces wastage and supports sustainability while ensuring transparency."

Legally speaking, Abhishek A Rastogi, Founder, Rastogi Chambers, says, "The advisory provides much-needed relief to businesses navigating GST revisions. Simplified rules — no mandatory re-stickering and extended packaging usage — save both time and costs, reduce risk of penalties, and provide operational flexibility. This pragmatic approach helps ensure GST benefits reach the consumer efficiently."

Ease of doing business and consumer benefit

The September 18 circular underscores the government’s intent to improve the ease of doing business while ensuring GST benefits are passed on to end consumers promptly. By providing operational flexibility, extending packaging timelines, and allowing modern communication channels, manufacturers can manage inventories effectively without disrupting supply chains, while consumers are kept informed of revised prices in a transparent manner.

The updated circular demonstrates a balance between regulatory oversight and practical business realities, providing clarity to the industry and reinforcing the government’s commitment to supporting both businesses and consumers during transitions arising from GST rate revisions.

"The government’s latest clarification comes as a major relief for industry and trade. By making re-labelling of unsold stock optional, extending the use of existing packaging material till March 31, 2026, and doing away with the earlier requirement of publishing revised MRPs in newspapers, compliance has been simplified significantly. Instead, manufacturers and importers can now inform trade channels and authorities through circulars—a far more practical and cost-efficient approach. This balanced framework reduces compliance costs and operational challenges, while still ensuring transparency for consumers at the retail level. It is a welcome move that acknowledges on-ground realities, offering businesses greater flexibility without compromising consumer protection," said Manoj Mishra, Partner and Tax Controversy Management Leader, Grant Thornton Bharat.