Food labelling plays a critical role in ensuring transparency, consumer protection, and informed decision-making. The Food Safety and Standards (Labelling and Display) Regulations, 2020, framed by the Food Safety and Standards Authority of India (FSSAI), mandate various declarations and exemptions to streamline how information is shared with consumers. This article delves into the provisions under Regulation 8 which focuses on mandatory declarations and exemptions from labelling requirements, especially for specific food types and packaging conditions.
Mandatory Declarations
1.1 Schedule-II Compliance
All packaged food products that contain ingredients and/or additives listed in Schedule-II of the regulations must prominently display this information on the label. These include:
To ensure visibility and consumer comprehension, the minimum height of numerals and letters used for these declarations should not be less than 3 mm based on the letter “l”. This is aimed at eliminating ambiguity and ensuring clarity in compliance language.
1.2 FSSAI’s Power to Amend
The Food Authority holds the power to add, delete, or modify the list of ingredients and additives requiring mandatory declarations. This ensures that the regulations remain dynamic and responsive to new scientific evidence, technological innovations, and public health concerns.
2. Special Cases Where Declarations Are Modified or Exempted
2.1 Refillable Bottles
In the case of liquid products marketed in reusable bottles, the regulation grants an exemption from the requirement to declare the list of ingredients, provided these bottles are meant to be refilled. However, such products must still include nutritional information as mandated under Regulation 5(3). This balances environmental sustainability (encouraging reusable packaging) with consumer rights to nutritional data.
2.2 Foods with Short Shelf-Life
Foods that have a shelf-life of not more than seven days are not required to mention the “Date of Manufacture” on their labels. However, the “Expiry Date” or “Use By” date is mandatory, as it is
critical to consumer safety. This provision is particularly relevant to fresh bakery items, dairy products, and chilled foods.
2.3 Prepared Foods for Immediate Consumption
Prepared food served for immediate consumption—such as meals provided by hotels, caterers, hospitals, halwais, or food services on airlines, railways, or mobile vending units—need not bear full product labels but must display or accompany the following minimum information at the point of sale or service:
These requirements aim to safeguard consumer interests even when food is consumed on the go or in non-retail settings.
2.4 Food from Vending Machines
For food served via vending machines, FSSAI mandates an additional display of labelling information such as nutritional data and mandatory declarations. These may be presented through:
This ensures that even in self-service situations, consumers receive complete and accurate food-related information.
3. Exemptions When Information is Embedded in GTIN/Barcode
In cases where food products use a Global Trade Identification Number (GTIN) or Barcode system, certain label elements can be exempted from being physically printed on the package if they are available through the code. These include:
This digital-first approach allows better inventory tracking and is particularly useful in high-volume retail environments, reducing label clutter while maintaining regulatory traceability.
4. Shelf-Life Labelling for Assorted Packs
In the case of assorted packs (which contain a variety of food products within a single package), the shelf-life declaration must correspond to the item with the shortest shelf life among all the contents. This ensures that consumers are not misled into consuming expired components of the pack while assuming all contents are safe.
5. Exemptions for Small Packaging (Less than 100 sq. cm.)
For packages with a surface area less than 100 square centimeters, several labelling requirements are exempted. These include:
However, these details must be provided on the outer packaging or multi-unit pack, if applicable. This provision ensures practical labelling for small products like spice sachets, mini-candy packs, or bite-sized confectioneries, without compromising access to necessary information.
6. Implications for Stakeholders
6.1 For Food Business Operators (FBOs)
6.2 For Regulators
6.3 For Consumers
These regulations ensure that:
7. Conclusion
The FSSAI’s Mandatory Declarations and Exemptions from Labelling Requirements reflect a careful balance between consumer rights, industry feasibility, and technological advancements. Whether it’s declaring allergens on a hospital meal or omitting certain details from a barcode-enabled label, the emphasis is on accountability, clarity, and accessibility.
These provisions uphold India’s commitment to global best practices in food safety, labelling transparency, and regulatory compliance. Food businesses must stay agile and routinely audit their labelling practices to remain aligned with the ever-evolving regulatory ecosystem under the Food Safety and Standards Act, 2006.
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 which is misbranded, shall be liable to a penalty which may extend to three lakh rupees.
Read more about the regulation from: https://fssai.gov.in/cms/food-safety-and-standards-regulations.php
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