Unbranded goods are not automatically prohibited on GeM. The important distinction is between an accountable manufacturer-linked catalogue and an unsupported placeholder. This guide separates catalogue permissions, brand approval and buyer purchasing rules rather than treating them as one approval.
Reviewed on 6 October 2026. The sources below include historical training material, clearly identified as such. Seller notices and subsequent amendments must be checked for the particular transaction.
What this assessment confirms—and what it does not#
GeM’s official documents recognise manufacturer-linked unbranded products. An alleged removal of an “NA” placeholder does not, by itself, establish a ban on every unbranded product.
The official documents accessed for this review do not establish a universal 12 January 2026 purge deadline or a universal five-day correction period. This guide therefore does not present those claims as verified directives. If your account has received a notice, retain the full notice, its issue date, affected catalogue IDs and the action requested.
This review directly retrieved GeM’s Brand and Product Approval Policy version 2.0, its VA/VAE undertaking docket, and General Terms and Conditions version 1.29, dated 25 March 2026. Their provisions are discussed below. These documents do not substantiate every claim in circulated seller summaries: a single permitted revival, universal category exclusivity and an unconditional ban on auto-approval are not established here.
CMS 3.0: catalogue creation and pairing are different#
The official CMS policy allocates responsibilities by quadrant. Creating a product catalogue and pairing a seller offer with an existing catalogue are separate actions.
| Quadrant | Catalogue and reseller position |
|---|---|
| Q1 | Validated OEMs offer products; reseller pairing is unavailable. |
| Q2 | OEMs create catalogues; authorised resellers pair with them. |
| Q3 | Authorised resellers may create missing catalogues; dashboard approval governs relevant requests. |
| Q4 | Existing OEM catalogues support reseller pairing without further OEM endorsement. |
For new reseller catalogues in Q3/Q4, the policy specifies OEM approval or reasoned rejection within 72 hours. Inaction can hold up the OEM’s own uploads; it is not automatic reseller approval.
Q5 is a separate SHG route: brands are created by the platform, sellers upload as resellers, and there is no OEM dashboard.
Unverified-reseller undertakings cover authorised sourcing, chain documents at delivery and genuine replacement supplies when challenged. These are sourcing commitments, not proof that every offered product is domestic.
Source: GeM CMS 3.0 policy, sections A–G and Annexure 1.
Brand approval: five requests with different purposes#
GeM’s version-2.0 policy identifies five request types, rather than four universal product classes. Select the request matching your ownership and manufacturing position; an approved brand name and recognised OEM status answer different questions.
| Request | What the request establishes | Important documentary distinction |
|---|---|---|
| Registered Brand Only | Approval of a registered brand | Trademark authenticity and relevant class must be checked. |
| Registered Brand + OEM | Registered-brand approval together with OEM recognition | Ownership must be supported by the certificate or enabling documents. |
| Unregistered Brand + OEM | OEM route for a name without registered protection | The name must not already be registered in the relevant class; the prescribed undertaking must be signed, stamped, notarised and attested on every page. |
| Unbranded + OEM | Manufacturer-linked listing without a brand | This is a recognised request type, not permission to use an unsupported generic identity. |
| OEM Only | OEM request for a registered brand already present in the GeM category | Ownership or enabling evidence remains relevant. |
A pending trademark application is not a granted registration. Do not select a registered-brand request merely because an application number exists. Conversely, the version-2.0 checklist should not be expanded into a claim that every unregistered-brand applicant must possess a pending application.
Approval timelines, deficiencies and revival#
| Process | Stated processing time | Conditions and outcomes |
|---|---|---|
| Brand request | Four working days, excluding submission day | Approved, notified for clarification or rejected; workload and other exigencies may extend processing. |
| Product catalogue request | Three working days, excluding submission day | Category, images, technical evidence and other checks apply; the period may be extended. |
| Product resubmission | Three working days, excluding resubmission day | A complete response is necessary; repeated missing information can lead to rejection. |
| MRP update | Three working days, excluding submission day | Evidence is reviewed; the request may be approved or rejected and processing may take longer. |
For brand approval, the policy limits requests to three attempts per category and treats the third notification as rejection. A rejected applicant may seek Brand Revival through the GeM helpdesk with necessary documents. The policy does not establish the draft’s claimed “one revival only” restriction. Do not equate an ordinary clarification response with an unrestricted fresh application.
These are conditional processing targets, not guaranteed activation dates. Plan a tender submission around confirmed approval and visibility, rather than adding four and three calendar days to an application date.
Source: GeM Brand and Product Approval Policy v2.0, pages 1–6.
Vendor assessment and exemption: recognition requires its own evidence#
For the current September 2026 validation policy, assessment/exemption eligibility, fees, renewal and dashboard steps, read the GeM OEM registration guide.
Under GTC v1.29, clause 2(g), OEM recognition requires assessment by a designated agency unless an exemption applies under GeM’s VA policy. Documentary evidence and demonstration of manufacturing facilities or capabilities form part of the notified process. A seller account, trademark application or uploaded catalogue does not substitute for this recognition.
Avoid describing the process as exclusively a QCI assessment. GeM’s August 2024 overview identifies RITES in its vendor-assessment workflow, while the current GTC uses the broader wording “designated agency”. Use the agency and process assigned by the current portal.
Sources: GeM GTC v1.29, page 3, GeM overview, August 2024, page 21.
What the official VA/VAE docket contains#
The docket expressly directs applicants to the latest Vendor Validation Policy and VAE guidelines. Its templates support applications; they are not a complete exemption-eligibility list, nor does possession of a template confer exemption.
| Docket annexure | Evidence or undertaking | How to use it |
|---|---|---|
| I | Beneficial ownership | Required for VA/VAE applicants; identify actual ownership and control using the prescribed definitions. |
| II | Shareholding and directors | Required for VA/VAE; disclose the relevant ownership chain and use the applicable execution method. |
| III | Government-entity OEM undertaking | Supports the relevant VAE route; government ownership must be documented. |
| IV | Buyer-organisation recommendation | Applies to the buyer-specific category route described in the form. |
| V | Directors’ roles | Supply where the applicable control/land-border review requires it. |
| VI | Drug or medicine manufacturer/importer undertaking | Category-specific licensing and prescribed evidence apply. |
| VII | Manufacturer Authorisation Form | For the stated reseller VA/VAE scenario involving an OEM already on GeM in the category. |
| VIII | Raw-material supplier list | Supports VA manufacturing evidence. |
| IX | Deemed-OEM undertaking | Relates to an overseas actual OEM; does not override the brand policy’s separate restriction. |
Ownership thresholds serve different purposes. Annexure II traces shareholding at the specified 5% disclosure level. That is not interchangeable with Annexure I’s beneficial-ownership test, which also considers control. Applying one percentage to both forms can produce an incomplete submission. Follow the definitions and signature/notarisation options in each annexure rather than combining them into a home-made declaration.
The medical-device exception is narrow#
Version 2.0 disallows combining a VAE with a Deemed-OEM letter, except for medical-device importers holding a valid import licence from the issuing licensing authority and an overseas actual OEM’s letter in their favour. This is not a general exception for every importer, medical reseller or pharmaceutical business. The drug/medicine template in Annexure VI also does not independently expand that exception.
Source: Official VA/VAE undertaking docket, Annexures I–IX, Brand Policy v2.0, page 6, check 4.
Product approval: price, model and certification checks#
An approved brand is only one input to catalogue review. Version 2.0 checks category relevance, consistency of the brand with photographs/brochures, image compliance, MRP, model identity, technical parameters, applicable certifications and country of origin. Seller information must not be inserted into product-approval fields.
MRP evidence must match the product and unit#
Where packaging applies, provide a real packaging photograph showing legally compliant MRP. A typed price on letterhead is not a universal substitute.
Where packaging does not apply—and GeM’s decision on that point is final—the policy permits either:
- The prescribed Annexure-1 OEM MRP declaration on official letterhead, no older than one year, with issue date, ink or digital signature and company stamp.
- An OEM-issued price/rate list no more than one year old.
GeM may compare MRP with the company website or e-commerce information. The catalogue price must also align with the category’s unit of measurement. A price for a carton cannot silently be presented as a price for one unit.
“NA” in a model field is a different issue#
The same policy permits NA for the model field when a model is not applicable. Therefore, a statement that “GeM bans NA everywhere” is inaccurate. Identify the actual field and deficiency: brand identity, manufacturer identity and model number have different rules.
Certifications and origin remain the seller’s responsibility#
Where the category requires BIS evidence, relevant licence/registration details must match the product and supporting records. The policy identifies checks for certificates such as BIS, BEE and MTCTE, while noting that buyers may independently verify other certificates. Do not market catalogue approval as certification of every claim.
Country-of-origin details must agree with supporting evidence. Approval, including OEM auto-approval where available, does not transfer final responsibility for catalogue correctness away from the OEM or reseller. The policy explicitly recognises some currently auto-approved catalogue types and reserves GeM’s power to require approval later; it does not establish a universal ban on auto-approval.
Source: Brand and Product Approval Policy v2.0, pages 1–4 and Annexure 1.
Buyer rules: the January 2026 GFR thresholds#
The GFR compilation updated through 31 January 2026 gives these ordinary Rule 149 limits:
| Purchase value | Ordinary route |
|---|---|
| Up to ₹50,000 | An available supplier meeting quality, specification and delivery requirements. |
| Above ₹50,000, up to ₹10 lakh | Lowest price among eligible sellers from at least three different manufacturers. |
| Above ₹10 lakh | Mandatory online bidding or reverse auction. |
Specified scientific and research bodies have a ₹1 lakh direct-purchase threshold. Automobiles have a separate exception. Buyers must check applicability and subsequent amendments.
Rule 144 calls for objective specifications and generally avoids naming a particular brand. Rule 166 permits specified single-source cases; PAC applies to its proprietary and standardisation grounds, not to ordinary brand preference. Rule 149 also prohibits splitting demand to avoid the required procedure.
Source: Official government-hosted GFR compilation, Rules 144, 149 and 166.
Practical inference: three sellers carrying the same manufacturer’s goods do not represent three different manufacturers. Brand approval is also not a substitute for the buyer’s procurement procedure.
Push Button Procurement: use the current procedure#
GTC v1.29, clause 30, sets out PBP as an optional, automated bidding procedure. It is not a synonym for ordinary direct purchase or L1 comparison.
- Procurement value must not exceed ₹5 lakh inclusive of taxes.
- PBP operates through bidding; direct purchase, L1 and custom-bid PBP are not permitted.
- At least five bids must be received; otherwise procurement restarts through the usual method.
- The category must have at least ten listed sources.
- Requirements must not be split to fit the procedure.
- When the required participation condition is met, contract placement occurs without human intervention.
The January 2023 training illustrates unbranded products being treated as one brand. That historical illustration must not be extrapolated into a universal current comparison algorithm. The current GTC’s PBP conditions and the live workflow should guide the purchase.
Sources: GTC v1.29, clause 30, pages 52–54, dated PBP training, pages 27–29.
Buyer conditions, custom bids and OEM authorisation#
A standard category, a custom/BOQ workflow and a proprietary purchase require separate analysis. This review does not establish the draft’s blanket claim that every custom or BOQ bid involving an existing category is prohibited. Establish category availability, suitability and the applicable current workflow before choosing the route; a custom format does not itself justify exclusion of compliant products.
Current GTC rules provide more specific, verifiable safeguards:
| Issue | Verified requirement | Practical implication |
|---|---|---|
| Buyer-added ATC | Clause 3(B)(x): competent-authority approval and buyer responsibility for the effect on competition | Check the actual ATC and bid disclaimer; GeM may require a corrigendum or cancel a bid containing prohibited clauses. |
| External eligibility conditions | Clause 3(B)(xiii)(g): use GeM filters/ATC, rather than incorporating conditions through references to external websites/documents | A bidder should be able to identify operative eligibility conditions within the GeM bidding process. |
| Catalogue/OEM verification | Clause 28: no separate OEM-authorisation demand for an OEM-verified catalogue offered by an OEM-verified reseller; the clause also addresses Q1/Q2 | Check portal verification and the precise category instead of routinely demanding a redundant letter. |
| Q4 warranty | Clause 28: reseller responsibility for replacement warranty | The buyer need not pursue the OEM for Q4 warranty claims. |
| Unapproved Q3/Q4 reseller | Clause 28: sourcing and genuine-replacement undertaking applies on upload, order acceptance and bid participation | Maintain chain documents for delivery; an undertaking is a substantive responsibility. |
Do not claim that every physical-document requirement is forbidden. The GTC itself includes specific requirements for originals in some procedures. Challenge a restriction by identifying its conflict with the applicable GTC, STC or published bid disclaimer, rather than by relying on a general slogan.
Source: GTC v1.29, pages 12, 20 and 49–51.
Make in India and land-border controls are separate checks#
Manufacturer-linked catalogues improve identification, but do not prove domestic value addition. Under the DPIIT public-procurement preference order revised 19 July 2024, ordinary Class-I status requires at least 50% local content; Class-II requires at least 20% but below 50%, subject to applicable higher category requirements. Imported goods bought from a domestic distributor do not become local content merely because the invoice is Indian. Repackaging or rebranding imported finished goods is also excluded from local-content calculation.
Country of origin, local-content classification and restrictions relating to bidders from countries sharing a land border are distinct questions. Check the applicable product rules and tender declarations individually. A notarised ownership form is not an automatic finding that a bidder satisfies every registration or exemption condition.
Sources: DPIIT revised PPP–Make in India order, definitions and local-content provisions, GFR Rule 144(xi).
Worked examples: applying the rules without mixing approvals#
The following are illustrative editorial scenarios, not GeM adjudications or promises of acceptance.
An unbranded manufacturer with an inactive catalogue#
A small fabricator receives a notice concerning its brand field. Its next steps are to identify the notice and category, confirm VA/VAE and OEM status, select the manufacturer-linked unbranded request, and resolve product evidence. Filing a trademark is not automatically the only remedy. A supported route must still pass the applicable account and category checks.
A reseller whose OEM has not answered#
A Q3 reseller creates a missing catalogue and awaits dashboard review. Seventy-two hours elapse. The reseller should retain the request and raise the unanswered review; it should not represent the catalogue as approved merely because the response period expired. Verify the actual status and prepare sourcing records before relying on it for delivery or a bid.
Three quotations from one manufacturer#
For an ordinary ₹3 lakh Rule 149 purchase, three distributors quote for the same manufacturer’s product. There are three sellers but only one manufacturer. This does not satisfy the ordinary comparison requirement for three different manufacturers. The buyer must use a compliant comparison or another applicable procurement procedure; three GST numbers do not resolve the distinction.
Imported goods supplied by an Indian distributor#
A distributor imports finished equipment, adds its label and offers it through an approved GeM catalogue. Indian seller registration and catalogue approval do not establish Class-I local content. Assess the imported component/value under the relevant order and retain the calculation and supporting records instead of treating rebranding as manufacturing.
A product with no retail packaging#
An OEM supplies made-to-order industrial equipment and proposes a letterhead MRP declaration. First establish that packaging is inapplicable under GeM’s decision, then use the prescribed declaration or eligible recent rate list. Align the stated price with the category unit and the offered configuration. A valid signature cannot fix a price for the wrong product or unit.
A buyer asks for another OEM letter#
An OEM-verified reseller offers an OEM-verified catalogue, but a bid demands a separate authorisation letter. Review clause 28, the exact verification status and any applicable STC before raising the discrepancy through the bid’s clarification process. This is a targeted policy question, not permission to ignore every bid document.
A practical catalogue review for manufacturers and resellers#
The following workflow is an editorial recommendation for organising a review.
1. Inventory affected listings#
Create a register with catalogue ID, product, manufacturer, category, brand status, seller role, dashboard status and any outstanding notice. Add a named owner and target date for each unresolved item.
2. Diagnose the actual problem#
Separate a brand request from a catalogue request or reseller-pairing request. Record the precise rejection reason instead of assuming that every inactive catalogue has been affected by a marketplace-wide ban.
3. Check consistency#
Compare the entity and manufacturer names across your account, uploaded documents, product photographs and commercial records. Explain legitimate differences and correct actual errors before resubmitting.
4. Prepare a complete response#
Answer each deficiency in the notice with the relevant evidence. Maintain dated versions so the business can establish what was submitted and when. Do not substitute a new generic label for an unresolved identity or documentation problem.
5. Verify the result#
Check approval status, catalogue visibility, seller pairing, stock and delivery settings. Retain the approval reference and check the actual bid conditions before relying on the listing for a tender.
An approval should be recorded as a completed catalogue step, not described internally as a guarantee of bid eligibility or contract award.
What to do when a catalogue is rejected or removed#
Use the reason displayed in your account as the starting point. A useful support request contains:
- The catalogue and request IDs.
- The category and whether you are acting as OEM or reseller.
- The dated rejection or notice.
- A concise explanation of the discrepancy.
- Supporting documents and the clarification you need.
Ask for the applicable policy version and clause when a requirement is unclear. Keep a record of the response. Avoid promising reinstatement within a fixed number of days unless GeM has confirmed the relevant process.
For a rejected bid, distinguish a catalogue problem from a technical-specification, document, delivery or buyer-eligibility issue. They may require different remedies.
Frequently asked questions#
Can an unbranded product be listed on GeM?#
The verified documents recognise an unbranded manufacturer-linked route. The applicable category, account permissions and current notices determine the steps for your listing.
Does a pending trademark mean the brand is registered?#
No. Keep the application status distinct from a granted registration and use the applicable approval route.
Does the OEM’s silence automatically approve a reseller catalogue?#
Do not assume approval from silence. Check the recorded status and any outstanding dashboard request before relying on the catalogue.
Was there a universal NA-catalogue purge on 12 January 2026?#
This review did not obtain an official notice establishing that claim. An account-specific notice should be assessed on its own terms.
Does catalogue approval prove Make-in-India compliance?#
Do not treat catalogue approval as proof of every separate procurement requirement. Review applicable origin, local-content, certification and bid declarations independently.
Get help with your next step#
Explore our business services or discuss your GeM catalogue question. Share your category, seller role and the specific notice so the team can establish what support is available.
Editorial scope#
Prepared from the official documents linked above. This guide distinguishes verified provisions, dated training material and practical editorial recommendations. It does not promise approval, reinstatement or a tender award, and it does not reproduce unverified social-media notices as government policy.