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IndiaLegal Metrology / COO

# Country of Origin Labeling in India: Rules for Imported Products

Country of origin (COO) labeling in India intersects three separate legal frameworks: Legal Metrology rules for consumer product labels, Consumer Protection (E-Commerce) Rules for online listings, and customs Rules of Origin for FTA duty preferences. Getting COO wrong affects both market compliance and import duty calculations.

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At a glance

COO requirement sources

4

COO determination scenarios

4

FAQ items

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## COO legal requirements in India

### Legal Metrology (Packaged Commodities) Rules 2011, Rule 6(1)

Country of origin must be declared on every pre-packaged commodity sold in India

**Format:** 'Made in \[Country\]' or 'Manufactured in \[Country\]' or 'Country of Origin: \[Country\]'

**Applies to:** All pre-packaged consumer goods

### Consumer Protection (E-Commerce) Rules 2020, Rule 6(1)(d)

Country of origin must be displayed on every product listing on e-commerce platforms

**Format:** Platform product page must show country of origin before purchase decision

**Applies to:** All products listed on Indian e-commerce platforms

### Public Procurement Order (PPO) 2017 and 2020 Amendment

For government procurement: preference to 'Class I local suppliers' (50%+ local content) and 'Class II local suppliers' (20-50% local content). Non-local suppliers from 'designated countries' may be restricted from certain bids.

**Format:** Local content percentage declaration by bidder

**Applies to:** Government procurement; defence procurement (separate rules)

### Customs Rules of Origin (under FTAs)

Country of origin determines import duty rate under Free Trade Agreements. Products must meet Rules of Origin criteria to claim preferential FTA duty rates.

**Format:** Certificate of Origin from authorized issuing body in exporting country

**Applies to:** Imports claiming FTA duty preference

## How country of origin is determined

### Wholly obtained products

Straightforward — product must be entirely produced in the declared country. E.g., agricultural products grown in India.

Fresh vegetables, minerals, unprocessed natural products

### Substantially transformed products

Country where the last substantial transformation occurred is the country of origin. Substantial transformation typically means a change in tariff classification (CTC) at HS chapter or heading level.

Electronic products assembled in Vietnam from Chinese components: if CTC test is met, COO is Vietnam

### Products assembled from imported components

Simple assembly operations (screwing, packing, cutting to length) generally do NOT constitute substantial transformation. The COO remains the country of origin of major components.

Products assembled in India from 100% imported kit: may still be COO = source country if assembly is simple

### Value addition criteria (some FTAs)

Certain FTAs use Regional Value Content (RVC) criteria — minimum % of value must be added in the FTA member country for COO to be that country.

ASEAN FTA: typically 40% RVC required; SAARC FTA: 40% RVC or CTSH

## Frequently asked questions

### Can I label a product 'Made in India' if components are imported?

India does not have a formal 'Made in India' standard for consumer product labeling (unlike 'Make in India' which is a policy programme). The country of origin declaration on consumer labels follows the substantial transformation principle — the country where the last significant manufacturing or processing occurred that changed the product's tariff classification. Products assembled in India from imported kits may or may not qualify as 'Made in India' depending on the degree of value addition. For government procurement, 'local content' thresholds are specified under the Public Procurement Order.

### Does country of origin labeling affect customs duty at Indian ports?

Yes — country of origin directly determines customs duty rate when the importer claims preferential duty under a Free Trade Agreement. India has FTAs with ASEAN, South Korea, Japan, UAE, and others. A valid Certificate of Origin from an authorized issuing body in the exporting country is required to claim the FTA preferential rate. Incorrect COO declaration is customs fraud and can result in penalty, duty demand, and goods seizure.

### What is the penalty for incorrect country of origin on an Indian e-commerce listing?

Consumer Protection (E-Commerce) Rules 2020 require accurate country of origin on every product listing. Violations can attract Consumer Protection Act 2019 penalties, including fines and product delisting. E-commerce platforms themselves can be held liable for facilitating inaccurate listings. DPIIT and state consumer affairs departments have issued notices to platforms for COO non-compliance, particularly following 2020 regulations that were introduced amid 'boycott Chinese goods' sentiment.

**Disclaimer:** Country of origin rules span multiple laws. FTA Rules of Origin are agreement-specific and updated through amendment protocols. Always verify current rules with your customs broker or legal advisor for specific product and trade scenarios.

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