Private-label product imports are goods made by someone else to your specification and sold under your own brand. The logistics start earlier than for catalogue buying, because you decide the materials, the packaging and the label, and they finish later, because the brand on the box makes you answerable for what is inside it. A factory in China may make the product, but Indian law looks to the brand owner and the importer. This guide sets out what changes when the brand is yours and walks through seven steps: the specification, samples, compliance, packaging and labelling, the shipping plan, customs and duty, and quality control.
For the supplier side, see how to find reliable suppliers in China. For the e-commerce rules, see how Indian e-commerce brands can import products from China.
What Changes When the Brand Is Yours
The Legal Metrology (Packaged Commodities) Rules, 2011, as published with their amendments on the Department of Consumer Affairs site, say that a company name and address on a label without qualifying words is presumed to be the manufacturer's, and that if the brand name and address of the brand owner appear on the label as a marketer, the brand owner is held responsible for any violation of the Rules and action is initiated against the deemed manufacturer. For an imported package the importer's name and address must be shown. In a private-label business the brand owner and the importer can be the same business, in which case the responsibility sits with you.
The same is true of product information on your listings. The Consumer Protection (E-Commerce) Rules, 2020, on the Department's site, require marketplace sellers to give relevant details including country of origin and the name and details of the importer, and a PIB release says the 2026 amendment, in force from 1 January 2027, requires importer details and country of origin to be disclosed for imported goods.
Step 1: Write the Specification
A vague brief produces a vague product. Write down:
- the materials, dimensions, tolerances and colours;
- the performance and safety requirements, and the standards the product must meet;
- the packaging: inner pack, carton size, carton marks and any pallet pattern;
- the label: the declarations Indian law requires, your brand and the artwork;
- the documents the supplier must provide with each shipment; and
- what happens when the goods do not match the specification.
Attach the specification to the contract. The Embassy of India in Beijing's advisory for Indian SMEs advises signing a proper contract with an arbitration clause and naming the documents needed for customs clearance.
Step 2: Samples and Pre-Production Approval
Approve a reference sample against the specification, and keep it. Treat later production as a separate transaction. The advisory warns that small initial orders and good samples have been followed by sub-standard goods in larger orders, and says to make no compromise on documentation or scrutiny even when earlier dealings went well. Agree how changes are approved, so that the factory cannot substitute materials or packaging without your written consent.
Step 3: Check Compliance Before You Order
India's Foreign Trade Policy 2023 applies domestic technical specifications and safety norms to imports. DGFT's general notes on import policy say that products under mandatory BIS standards must comply and that manufacturers and exporters of those products to India must obtain a BIS licence for the Standard Mark. They also say that electronics notified under the 2012 Compulsory Registration Order are prohibited unless BIS-registered and labelled, and that toys are governed by BIS standards. For a private-label product, the BIS evidence has to cover the product as you will sell it, so ask the manufacturer for it and check it against the BIS lists before the first production run. See how product classification affects import duties and compliance.
Step 4: Design Packaging and Labels for Logistics and for India
Packaging is a logistics decision as well as a marketing one.
- Carton size and weight. Air carriers charge on the higher of actual and volumetric weight, and IATA gives the general rule as volume in cubic centimetres divided by 6,000, so a carton that is bigger than the product needs makes air freight dearer. For sea freight, carton dimensions decide how well a container fills.
- Wooden packaging. If pallets or crates are made of raw wood, the international standard ISPM 15 requires approved treatment, such as heating to at least 56 °C for 30 continuous minutes, and a mark. Ask the supplier to confirm it.
- Declarations. Rule 6 of the Legal Metrology Rules requires, on an imported retail package, the importer's name and address, the country of origin, the common or generic name, the net quantity and the maximum retail price inclusive of all taxes in Indian currency. The Rules say it is permissible to affix a label on imported packages to make the declarations, so decide whether the label is applied at the factory or after arrival, and have the artwork approved first.
Step 5: Plan the Shipping
A private-label product is made in a production run and may carry a minimum order quantity, so the first shipment is a decision about volume. Use the guides on international shipping solutions for e-commerce businesses and bulk shipping vs individual parcel shipping, and agree the trade term, as EXW vs FOB vs CIF explains. Ask the supplier for the commercial invoice, packing list and transport document, and check them against each other before the cargo leaves.
Step 6: Customs and Duty
Your product is classified on its own facts, and the duty and IGST depend on the classification. Work out the landed cost, including freight, insurance, duty and IGST, before you commit to the first run. See how to calculate the landed cost of imported goods. Hold an active Importer Exporter Code, and agree who files the bill of entry. Our guide to customs clearance in India step by step sets out the sequence.
Step 7: Quality Control and Release
Arrange an independent inspection before shipping, as the advisory recommends, and release the balance payment only after the quality and quantity have been checked. Compare the goods with the approved reference sample, and inspect the labels and packaging as well as the product. See quality control inspection before shipping from China.

A Launch Sequence
| Stage | What happens | The output |
|---|---|---|
| Brief | Write the specification and the packaging and label brief | An approved specification |
| Supplier | Verify the manufacturer and agree the contract | A signed contract |
| Sample | Approve a reference sample | A golden sample |
| Compliance | Check import policy, BIS evidence and labelling | A compliance file |
| Production | Produce the first run against the contract | Finished goods |
| Inspection | Inspect independently before shipping | A pass or fail report |
| Shipping | Book the route, prepare documents and duty cash | A booked shipment |
| Clearance and launch | Clear customs, check the goods and publish listings with importer and origin details | Goods in stock and compliant listings |
Risks Specific to Private Label
- A supplier that sells your design or your specification to others. Take legal advice on who owns designs and tooling, and put it in the contract.
- Labels that carry the wrong declarations, which can put the brand owner in breach.
- A product that passed its sample test and fails in production.
- A minimum order quantity that ties up more cash than demand justifies.
A Private-Label Checklist
- The specification is written and attached to the contract.
- A reference sample is approved and kept.
- Import policy, BIS evidence and labelling have been checked for the finished product.
- Packaging is designed for freight and for India's declarations.
- The shipping route, trade term and landed cost are set.
- An independent inspection is arranged before the balance payment.
- Listings carry the importer details and country of origin.
Launch Your Brand With RR Brothers and Logistics
RR Brothers and Logistics ships private-label goods from China to India by sea and air, supports e-commerce logistics and handles customs clearance. Tell us about your product and your first run and we will help you plan the shipment and the documents.
Frequently Asked Questions
Goods made by a third-party manufacturer to your specification and sold under your own brand. The brand on the label makes you responsible for compliance as well as for sales.
Under the Legal Metrology Rules, if the brand owner appears on the label as a marketer, the brand owner is held responsible for any violation, and an imported package must show the importer's name and address.
DGFT's notes say electronics notified under the 2012 Compulsory Registration Order are prohibited unless BIS-registered and labelled. Check the BIS list for your finished product.
Materials, dimensions and tolerances, performance and safety requirements, packaging, the label and artwork, the documents to be supplied and the remedy if goods do not match.
Air carriers charge on the higher of actual and volumetric weight, so oversized cartons raise the bill. Carton dimensions also decide how well a container fills.
Under the 2020 E-Commerce Rules, marketplace sellers give details including country of origin and importer details. The 2026 amendment, in force from 1 January 2027, requires importer details and country of origin for imported goods.
Sources
- Department of Consumer Affairs: Legal Metrology (Packaged Commodities) Rules, 2011, with amendments
- Department of Consumer Affairs: Consumer Protection (E-Commerce) Rules, 2020
- PIB: Government amends E-Commerce Rules (10 September 2026)
- Embassy of India, Beijing: Updated advisory for Indian SMEs doing business with Chinese companies
- DGFT: Foreign Trade Policy 2023, Chapter 2 (para 2.03)
- DGFT: General notes regarding import policy (ITC (HS) 2022, Schedule 1)
- IATA: Air cargo tariffs and rules (volumetric weight)
- IPPC/FAO: ISPM 15, Regulation of wood packaging material in international trade (2018)
This article is general information, not legal, tax or customs advice. Rules, rates and procedures change; confirm current requirements with the relevant authority or a licensed customs professional before you ship. Regulatory references were checked against the official sources listed above on 26 October 2026.
Image credits: header photo by GB The Green Brand on Unsplash; photo by Jakub Żerdzicki on Unsplash. Used under the Unsplash License.
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