What Are FSSAI's Labelling Requirements for Imported Food Products?

Every food product imported into India must carry a label that complies with FSSAI's labelling regulations before arriving at an Indian port, not after clearance. The label must be in English, must display the importer's FSSAI Central Licence number and must meet specific requirements for content, placement and legibility. A consignment with a non-compliant label is a non-compliant consignment and no amount of paperwork filed after the goods arrive will change that.

What are fssai's labelling requirements?

The Food Safety and Standards Authority of India (FSSAI) labelling requirements for food products are primarily set out in the Food Safety and Standards (Labelling and Display) Regulations, 2020, which came into force replacing the earlier Food Safety and Standards (Packaging and Labelling) Regulations, 2011. The 2020 Regulations apply to all food products sold or distributed in India including imported food products. For imported food specifically, the requirements are reinforced by the Food Safety and Standards (Import) Regulations, 2017 which make label compliance a condition of import clearance.

The mandatory information must appear on the label of every imported food product sold in India in English as prescribed in Regulation 4 of the Labelling and Display Regulations, 2020. These mandatory declarations include the name of the food, list of ingredients in descending order of composition by weight or volume, nutritional information per 100 grams or 100 millilitres, net quantity of the food, country of origin, name and complete address of the importer in India, the FSSAI Central Licence number of the Indian importer, the best before or use by date, the batch number or lot number and where applicable, the instructions for use or storage.

Nutritional information is a separate and detailed requirement. FSSAI prescribes a mandatory nutritional information table that must declare energy in kilocalories, total fat in grams, saturated fat, trans fat, total carbohydrate, total sugars, protein and sodium. Additional declarations are required where specific health or nutritional claims are made on the label. The format and positioning of the nutritional information panel are also prescribed by the regulation.

FSSAI's requirements on label placement and permanence are specific. The preferred and legally defensible approach is to have labels that comply with Indian requirements printed on the product before it leaves the manufacturing facility. The practice of importing products with foreign-language labels and applying English stickers at the port or warehouse is now closely scrutinised.

Implications for businesses

For foreign food manufacturers and exporters, FSSAI's labelling requirements impose a direct production cost that must be built into the India supply chain. Bespoke label artwork compliant with Indian regulations must be prepared for all India-bound products. Foreign manufacturers must also ensure that the label for India does not carry health claims, nutrient content claims, or disease risk reduction claims not substantiated under FSSAI's claims regulations. Labelling non-compliance leads to a rejection or re-labelling at the port or a re-export.

For Indian importers and distributors, label compliance is both an import as well as a market obligation. The importer is required to ensure the label is compliant before filing the Bill of Entry on ICEGATE or risk clearance by the Food Safety Officer at the port for non-compliance.

The importer's FSSAI Central Licence number must appear on the label which means the label must be finalised after the importer is known. A foreign manufacturer who prints India-specific labels before a confirmed importer has been appointed cannot include the correct licence number creating a compliance gap. Also, a mismatch between the label submitted in the application and the label on the actual product will result in a rejection at the inspection stage.

How FSSAI labelling compliance works

Under the Green Channel, where clearance is document-based, the Food Safety Officer reviews the label documentation submitted with the Bill of Entry. Under the Yellow and Red Channels, physical inspection of the label on the actual product is conducted as part of the clearance process.

The process for achieving label compliance begins at the product development or supplier onboarding stage. The importer must obtain the product's complete formulation data, including all ingredients and their proportions, from the foreign manufacturer. This data is used to prepare the FSSAI-compliant ingredient list, nutritional information table and all other mandatory declarations. If stickering is used, it must cover the entire non-compliant portion of the original label and must be applied in a manner that is not easily removable.

FSSAI requires best before and use by dates to be stated in day-month-year format. Products from markets that use month-day-year format, principally the United States, arriving with dates that are present in the wrong format are at the risk of non-compliance. The omission of a batch number on the Indian label when the original label carries only a production date or a lot code in a format unfamiliar to the Food Safety Officer is another preventable error with a thorough pre-shipment label review.

Legality and risks

The legal consequences of labelling non-compliance arise under the Food Safety and Standards Act, 2006 and the Food Safety and Standards (Labelling and Display) Regulations, 2020. Section 52 of the FSS Act deals with labelling offences and provides for penalties for any person who manufactures, imports or sells food products in packaging that does not comply with FSSAI's labelling requirements with penalties extending to Rs 3 lakh for a first offence. Where the labelling violation involves a false or misleading claim Section 53 provides for penalties extending to Rs 10 lakh.

At the port, a labelling violation results in the Food Safety Officer declining to issue the No Objection for clearance. The importer then either re-exports the goods or applies for permission to re-label at a bonded warehouse where such permission is available and the violation is correctable. The cost risks include re-exporting a rejected consignment, including return freight, insurance, port handling and demurrage during detention.

Word of counsel

Importers should treat the FSSAI licence number requirement on the label as a structural supply chain issue and not merely a compliance checkbox.

If the importer changes because the original importer and exporter part ways or because a distribution agreement is restructured, every unit of stock bearing the old importer's licence number becomes non-compliant for resale purposes.

Importers entering into exclusive distribution arrangements for Indian-labelled products should ensure their supply agreements address what happens to label artwork and pre-printed packaging if the commercial relationship ends.

CHAs should confirm that the label documentation submitted to FSSAI includes all mandatory declarations and that the physical product label matches the documentation.

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