Decoding FSSAI Labelling Requirements for Safe and Transparent Food Packaging

Introduction

Food labels serve as a vital bridge between the manufacturer and the consumer, ensuring transparency, safety, and trust. Under the Food Safety and Standards (Labelling and Display) Regulations, 2020, the Food Safety and Standards Authority of India (FSSAI) mandates specific labelling provisions to inform consumers, assist in food traceability, and facilitate regulatory compliance.

This article elaborates on the detailed requirements laid down under clauses (5) to (15), covering everything from food additives to declarations for non-edible food products.

1. Declaration Regarding Food Additives [Clause 5]

Food additives are integral to processed foods. Under FSSAI guidelines:

  • The functional class (e.g., emulsifier, preservative) must be declared.
  • Each additive should be named specifically or assigned its International Numbering System (INS) code.

Flavouring Agents

Per Regulation 3.3.1(1) of the Food Product Standards and Food Additives Regulations, 2011:

  • Artificial flavours must disclose the common name of the flavour (e.g., Artificial Vanilla Flavour).
  • Natural or nature-identical flavours require only the class name (e.g., Natural Flavouring Substances).

This helps consumers identify the additives and flavouring substances present in packaged foods and make informed dietary choices.

2. Declaration of Name and Complete Address [Clause 6]

Every label must mention the full name and address of the brand owner, irrespective of whether they manufacture, market, or only distribute the product.

Prefixes:

  • “Manufactured by” (Mfg. by / Mfd. by)
  • “Marketed by” (Mkt. by)
  • “Packed and Marketed by”

Alcoholic Beverages:

Additional prefixes like “Bottled by,” “Blended and Bottled by,” or “Distilled and Bottled by” are permitted.

Imported Foods:

  • Name and address of the importer in India must be present.
  • If packaged or bottled in India, labels must also show:
    • Country of origin
    • Importer’s address
    • Packing/Bottling location in India

This ensures traceability and accountability, especially in cross-border trade.

3. FSSAI Logo and License Number [Clause 7]

The FSSAI logo and license number are mandatory on all packaged food products.

Format:

  • Must appear in contrast colour to the background.
  • Example: Lic. No. 12345678901234

Requirements:

  • Display the license number of the brand owner.
  • If the manufacturer or marketer is different, include their license number as well.

Imported Products:

  • Must display FSSAI logo and importer’s license number.

Business Premises:

  • All FBOs must display their registration/license number or Food Safety Display Board prominently.

Fortified & Organic Foods:

  • Must carry the respective logos as defined in Schedule II.
  • FSSAI may issue additional logos for other categories in the future.

4. Net Quantity, Retail Sale Price and Consumer Care Details [Clause 8]

Declared in accordance with the Legal Metrology Act, 2009:

Labels must include:

  • Net weight/volume/number of units
  • MRP (inclusive of taxes)
  • Consumer care contact:
    • Phone number
    • Email
    • Address

This empowers consumers to raise complaints and receive after-sale support.

5. Lot / Code / Batch Identification [Clause 9]

Every food package must display a unique batch number, code number, or lot number. This is critical for:

  • Quality control
  • Traceability
  • Product recalls

Example: Batch No. BGH2106A

6. Date Marking [Clause 10]

Date-related information helps consumers assess the freshness and usability of food.

Required Dates:

  • Date of Manufacture or Packaging
  • Expiry Date / Use By Date
  • Optional: “Best Before” date

Format:

  • Shelf life ≤ 3 months: DD/MM/YY
  • Shelf life > 3 months: MM/YY (Month in caps and at least three letters)

Grouping:

These declarations must be grouped together on the label.

Storage Conditions:

Mention if shelf life depends on specific storage (e.g., “Keep refrigerated after opening”).

Exemptions:

Expiry need not be declared for:

  • Fresh fruits & vegetables
  • Wine
  • Alcohol (≥10% by volume)
  • Vinegar
  • Sugar-boiled confectionery
  • Salt for industrial use
  • Solid sugars
  • Chewing/Bubble gum

Special Cases:

  • Airlines, Railways, Mobile Catering: Must declare date and time of manufacture on packed meals.

7. Labelling of Imported Foods [Clause 11]

Imported foods must comply with both:

  • FSSAI Labelling Regulations
  • FSS (Import) Regulations, 2017

Requirements:

  • Country of origin
  • Importer’s name and address
  • FSSAI license number
  • FSSAI logo

Labelling must be completed before customs clearance and must not mislead consumers.

8. Country of Origin for Imported Foods [Clause 12]

A transparent declaration of origin is mandatory:

  • The country of origin must be mentioned clearly.
  • If the food undergoes processing in a second country that changes its HS Code (6-digit level), then that country becomes the country of origin.

This helps trace supply chains and enables informed purchasing decisions.

  1. Instructions for Use [Clause 13]

Clear usage instructions must be provided where:

  • Reconstitution is required (e.g., powdered milk)
  • Safety is a concern (e.g., “Refrigerate after opening”)

Examples:

  • “Add 500 ml hot water and stir well.”
  • “Consume within 3 days after opening.”

These instructions ensure the product is consumed safely and as intended.

10. Declaration Regarding Food Allergens [Clause 14]

Allergens must be clearly declared to protect consumers with sensitivities.

Declare as:

Contains: [Name of Allergen]

List of Known Allergens:

  1. Cereals containing gluten (e.g., wheat, rye, barley, oats, spelt)
  2. Crustaceans
  3. Milk and milk products
  4. Eggs
  5. Fish
  6. Peanuts and Tree Nuts (e.g., almonds, walnuts, cashews)
  7. Soybeans
  8. Sulphites (≥10 mg/kg)

Cross Contamination:

Declare as:

May Contain: [Allergen]

Exemptions:

  • Oils derived from these allergens
  • Raw agricultural commodities (e.g., whole grains)

Allergen declarations must be made separately and prominently.

11. Declaration for Non-Edible Food Materials [Clause 15]

Certain products sold in retail but not meant for human consumption (e.g., pooja oil, diya ghee) must bear a clear warning.

Symbol:

  • A black cross inside a square
  • With a black outline
  • Must meet minimum size requirements as per Regulation 5(4)(c)

This helps prevent accidental ingestion and ensures the product is used only as intended.

Conclusion

FSSAI’s labelling regulations go beyond statutory compliance—they are essential for consumer awareness, safety, and product transparency. Accurate labelling helps:

  • Build consumer trust
  • Enable traceability
  • Support public health
  • Avoid misleading practices

Food Business Operators (FBOs) must implement robust labelling protocols, train teams on evolving norms, and regularly audit their packaging to avoid penalties and ensure regulatory alignment.

By adhering to these well-defined requirements, the food industry can offer both compliance and credibility, paving the way for a safer and more transparent food ecosystem.

Penalty for non-compliance:

Any person who whether by himself or by any other person on his behalf manufactures for sale or stores or sells or distributes or imports any article of food for human consumption shall be liable to a penalty which may extend upto ₹10 lakh + imprisonment up to 7 yearsAny person who whether by himself or by any other person on his behalf manufactures for sale or stores or sells or distributes or imports any article of food for human consumption which is misbranded, shall be liable to a penalty which may extend to three lakh rupees.

Disclaimer: The information contained in this Article is intended solely for personal non-commercial use of the user who accepts full responsibility of its use. The information in the article is general in nature and should not be considered to be legal, tax, accounting, consulting or any other professional advice. We make no representation or warranty of any kind, express or implied regarding the accuracy, adequacy, reliability or completeness of any information on our page/article. 

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