Why Food Labelling Compliance Matters
A food label is the single most visible expression of a manufacturer’s claim about a product. It is the basis on which consumers make purchase decisions, regulators decide enforcement action, and retailers accept or reject stock. Under Indian law, food labelling is not a marketing exercise — it is a legal disclosure mandated by the Food Safety and Standards Authority of India (FSSAI) under the Food Safety and Standards (Labelling and Display) Regulations, 2020, which replaced the older 2011 Packaging and Labelling Regulations in their entirety from December 2020.
FSSAI is stringent on labelling compliance. Mislabelled, misbranded, or non-compliant products are routinely seized, recalled, and prosecuted under the Food Safety and Standards Act, 2006. Penalties for misbranding range from monetary fines under Section 52 of the FSS Act to product seizure, licence suspension, and in serious cases of misleading claims, criminal prosecution.
This guide explains the structure of India’s food labelling framework, walks through every mandatory declaration that must appear on a packaged food label, covers category-specific rules for edible oils, infant nutrition, irradiated food, and organic products, and outlines the recent front-of-pack labelling (FoPL) and Health Star Rating proposals that are reshaping label design.
The Regulatory Framework
Three regulations govern what appears on an Indian food label:
| Regulation | Scope |
|---|---|
| FSS (Labelling and Display) Regulations, 2020 | Mandatory declarations, layout, font size, language, date marking, allergen, veg/non-veg mark, and display requirements for all pre-packaged foods. |
| FSS (Advertising and Claims) Regulations, 2018 | Nutrition claims (source of, high in, free of), health claims, reduction-of-disease-risk claims, comparative claims, and conditions for permitted claims. |
| FSS (Food Products Standards and Food Additives) Regulations, 2011 | Compositional and labelling rules for specific product categories — dairy, edible oils, cereals, beverages, etc. |
These are supplemented by category-specific regulations such as the FSS (Foods for Infant Nutrition) Regulations 2020, FSS (Organic Foods) Regulations 2017, FSS (Food or Health Supplements, Nutraceuticals, Foods for Special Dietary Use, Foods for Special Medical Purpose, Functional Foods and Novel Foods) Regulations 2022, and the FSS (Fortification of Foods) Regulations 2018.
General Requirements Applicable to All Packaged Foods
Every pre-packaged food sold in India must display the following declarations clearly, prominently, and indelibly on the principal display panel (PDP) and the information panel:
- Name of the food
- List of ingredients (in descending order by weight or volume at the time of manufacture)
- Nutritional information
- Declaration of vegetarian or non-vegetarian status (the green or brown dot-in-square symbol)
- Declaration of food additives (with class name and INS number or specific name)
- Name and complete address of the manufacturer, packer, importer, or brand owner
- FSSAI logo and 14-digit licence or registration number
- Net quantity
- Lot, code, or batch identification
- Date of manufacture or packing
- Best before, use by, or expiry date
- Country of origin (for imported foods)
- Instructions for use, where required
- Allergen declaration
The label language must be English or Hindi in Devanagari script. A regional language may be added but cannot replace English or Hindi. Font size is regulated against the principal display panel area — smaller packages allow smaller minimum font sizes, but legibility cannot be compromised.
Name and Trade Name of the Food Product
The name of the food must reflect its true nature — not its brand. A product called “Crunchy Wonder” must additionally identify itself as, for example, “breakfast cereal” or “extruded snack.” Where the name appears in regulations (such as “edible vegetable oil” or “infant milk substitute”), the regulatory name must be used.
A trade name or fancy brand name is allowed but cannot mislead about the nature, substance, or quality of the food. Names that imply a benefit not substantiated by the product (for example, “Slim” on a high-sugar product) attract scrutiny under both the Labelling Regulations and the Advertising & Claims Regulations.
List of Ingredients
Ingredients must be listed in descending order of weight or volume at the time of manufacture. Compound ingredients (a recipe within the recipe — for example, “biscuit pieces”) must themselves be broken down if they account for more than 5% of the finished product, or if they contain a designated allergen.
Specific rules apply to:
- Water added during manufacture — declared as an ingredient unless it forms part of a compound ingredient already listed
- Volatile ingredients that evaporate during processing — exempt from declaration
- Single-ingredient foods — list of ingredients can be omitted
- Class names — generic names such as “vegetable oil,” “starch,” or “spices” are permitted only for specified categories where exact identification is impractical
Ingredients carrying functional roles (preservatives, antioxidants, emulsifiers, colours, flavours) must be declared with the appropriate class name plus the INS (International Numbering System) number or the specific name. For example: “Acidity regulator (INS 330)” or “Acidity regulator (citric acid).”
Nutritional Information
The Nutritional Information panel is mandatory for almost all packaged foods, with limited exemptions for raw agricultural produce, single-ingredient products with minimal labelling, and certain small packs. The panel must declare, per 100 g or 100 mL and per serving:
- Energy value in kcal
- Amounts of protein, carbohydrates (including sugars), and fat in grams
- Quantity of added sugar, separately disclosed
- Amount of trans fat and saturated fat in grams
- Quantity of sodium in milligrams
- Any other nutrient for which a claim is made
Vitamins and minerals are declared in metric units, alongside their percentage contribution to Recommended Dietary Allowance (RDA) values for an average Indian adult, per the ICMR-NIN reference. Fortified foods carry the +F logo prescribed under the FSS (Fortification) Regulations 2018.
For products marketing dietary fibre claims (“source of fibre” or “high in fibre”), the fibre content must be substantiated by an accredited laboratory analysis — see our dietary fibre testing service for the AOAC methods accepted by FSSAI.
Declaration of Vegetarian or Non-Vegetarian Status
Every packaged food must carry the veg/non-veg symbol — a filled green circle inside a green square (vegetarian) or a filled brown triangle inside a brown square (non-vegetarian) — on the package, on each individual package within a multi-pack, and on all advertising and promotional materials. The symbol must appear close to the brand name or, where this is not feasible, on the principal display panel.
Eggs and egg products are classified as non-vegetarian under FSSAI. Products containing additives derived from animal sources (e.g. some emulsifiers, lard-derived fatty acids, animal rennet) are also non-vegetarian. Plant-based meat analogues that do not contain animal ingredients carry the vegetarian mark with an optional supplementary descriptor such as “plant-based.”
Declaration of Food Additives
All food additives — preservatives, antioxidants, emulsifiers, stabilisers, sweeteners, flavour enhancers, anti-caking agents, and colours — must be declared in the ingredients list using their class name and either INS number or specific name. Examples:
- “Preservative (INS 211)” or “Preservative (sodium benzoate)”
- “Sweetener (INS 951)” or “Sweetener (aspartame)” — sweeteners require additional warning statements for products containing aspartame, sucralose, or saccharin
- “Colour (INS 110)” or “Colour (sunset yellow FCF)”
- “Acidity regulator (INS 330)”
- “Flavour enhancer (INS 621)”
Permitted food colours, when used, must be declared. Where a “natural identical” or “synthetic” colour is used, the appropriate qualifier must accompany the declaration. Use of non-permitted colours is a misbranding offence and grounds for licence suspension.
Date Marking: Manufacture, Best Before, and Use-By Date
Three date markings are recognised:
| Date | Meaning | Required for |
|---|---|---|
| Date of manufacture or packing | The day the food was produced or packed | All pre-packaged foods |
| Best before | Date until which the food retains its specific qualities (flavour, texture, aroma) under stated storage conditions | Most pre-packaged foods |
| Use by / Expiry | Date after which the food should not be consumed for safety reasons | High-perishable foods, infant formula, foods for special medical purpose |
Dates must be in DD/MM/YY, DD/MM/YYYY, or month and year format. The expression “Best before … from the date of manufacture” is permitted only where the shelf life is greater than three months and the date of manufacture appears clearly. Hidden, illegible, or stamped-over dates are a common cause of regulatory seizure.
Declaration of Net Quantity
Net quantity must be declared in grams or kilograms for solid foods, millilitres or litres for liquids, and additionally by number for products sold by count (e.g. eggs, biscuit packs). The declaration appears on the principal display panel in a font size that is also regulated against PDP area.
For products in a liquid medium (e.g. canned vegetables in brine, fruit in syrup), the drained weight must also be declared. Multi-piece packs declare both the number of units and the total net weight.
The Legal Metrology (Packaged Commodities) Rules 2011 govern complementary aspects — Maximum Retail Price (MRP) inclusive of all taxes, the name and address of the importer for imported foods, and the customer-care contact. While these are administered by the Department of Consumer Affairs rather than FSSAI, retail authorities check both regimes in inspection.
Lot, Code, or Batch Identification
Every package must carry a lot, code, or batch number that enables traceability of the production unit. The marking must be indelible, must not obscure other mandatory declarations, and must be linked to internal production records that allow rapid recall identification. Batch markings are essential for FSSAI’s recall procedures under the Food Recall Procedure Regulations 2017.
Instructions for Use
Where the product requires preparation, dilution, reconstitution, heating, or specific handling, instructions must be provided. Examples:
- Infant formula and weaning foods — full reconstitution and feeding instructions
- Cake mixes, ready-to-cook foods, and concentrated drinks — preparation directions
- Frozen and chilled foods — storage and reheating instructions
- Foods for special medical purpose — administration and use under medical supervision
Instructions must be clear, in English or Hindi, and where the safe use of the product depends on it, supported by pictograms.
Allergen Declaration
The FSS (Labelling and Display) Regulations 2020 introduced mandatory allergen declarations in line with Codex CXS 1-1985. Foods containing or derived from any of the following must declare them prominently:
- Cereals containing gluten (wheat, rye, barley, oats, spelt, kamut)
- Crustaceans and crustacean products
- Eggs and egg products
- Fish and fish products
- Peanuts, soybeans, and their products
- Milk and milk products (including lactose)
- Tree nuts and nut products
- Added sulphites at concentrations of 10 mg/kg or more
Allergen statements typically appear under a “Contains:” heading after the ingredients list, with the allergens emphasised in bold. “May contain” precautionary allergen labelling is permitted where cross-contact in production cannot be eliminated — but must be based on a documented hazard analysis.
Infant Milk Substitute and Infant Foods
Labelling of infant milk substitutes, infant foods, and foods for young children is governed by the FSS (Foods for Infant Nutrition) Regulations 2020 and the Infant Milk Substitutes, Feeding Bottles and Infant Foods (Regulation of Production, Supply and Distribution) Act, 1992 (IMS Act). Mandatory features include:
- The statement “IMPORTANT NOTICE — Mother’s milk is best for your baby” in English and the regional language
- Detailed reconstitution and feeding instructions
- Warning against unhygienic preparation and over-dilution / under-dilution
- Prohibition on pictures of infants, mothers, or feeding bottles on packaging
- Prohibition on terms such as “humanised,” “maternalised,” or implying equivalence to mother’s milk
- Compositional disclosures aligned with Codex CXS 72 (infant formula) and CXS 156 (follow-up formula)
Misleading labels on infant nutrition are among the most heavily prosecuted misbranding offences. Penalties under the IMS Act can include imprisonment of company officers.
Edible Oils, Permitted Food Colours, and Irradiated Foods
Edible oils and fats must declare the type of oil clearly (groundnut, mustard, sunflower, blended vegetable oil, etc.). Blended edible oils must declare each component oil in descending order with percentages, the brand name of the blend, and the statement “Blended Edible Vegetable Oil.” Mustard oil sold in single-source form cannot be blended; trans fat content in vanaspati and similar fats is regulated and must be declared.
Permitted food colours must be declared as discussed above, with INS number or name. Colours must be drawn only from the approved list under the FSS (Food Products Standards) Regulations 2011, and maximum limits apply by food category. Use of non-permitted colours (e.g. Sudan dyes, malachite green, rhodamine B) is a serious adulteration offence.
Irradiated foods must carry the Radura symbol along with the statement “PROCESSED BY IRRADIATION” near the name of the food. The licence number of the irradiation facility and the date and purpose of irradiation must be available in supporting documents for the regulator’s inspection.
Specific Requirements for Other Food Categories
| Category | Notable label requirement |
|---|---|
| Honey | Geographical or botanical origin if claimed; “blend of honey” if mixed |
| Beverages — non-alcoholic | Caffeine declaration if added, with “Not recommended for children, pregnant or lactating women, and persons sensitive to caffeine” warning |
| Energy drinks | ”Not recommended for children” warning; maximum caffeine 320 mg/L |
| Foods with non-nutritive sweeteners | Warning statements per the additive used (e.g. “Contains aspartame — phenylketonurics: contains phenylalanine”) |
| Health supplements and nutraceuticals | ”Not for medicinal use” disclaimer; recommended daily intake; FSSAI category mark |
| Organic foods | India Organic logo and Jaivik Bharat logo with NPOP or PGS certification number |
| Fortified foods | +F logo with statement of the fortificant and quantity |
| GMO-derived foods | Declaration of genetically modified ingredient where required by category-specific rules |
| Plant-based and vegan products | Permitted descriptors with veg mark; restrictions on terms like “milk,” “butter,” “cheese” derived from animal source nomenclature |
Restrictions on Claims and Advertising
The FSS (Advertising and Claims) Regulations 2018 restrict how nutrition, health, and disease-related claims can be made. Key thresholds:
- “Source of” — must contain at least 15% of NRV (nutrient reference value) per 100 g, or 7.5% per 100 mL, or 5% per 100 kcal for vitamins, minerals, and protein; 3 g of dietary fibre per 100 g for fibre claims
- “High in” — must contain at least 30% of NRV per 100 g, or 15% per 100 mL for vitamins, minerals, and protein; 6 g of dietary fibre per 100 g for fibre claims
- “Free of sugar” — less than 0.5 g of total sugars per 100 g or 100 mL
- “Low sodium” — not more than 120 mg per 100 g
- “No added sugar” — no sugars or sugar-containing ingredients added during processing, with appropriate statement on naturally occurring sugars
Disease-risk-reduction claims and health claims require pre-approval. Comparative claims must reference a defined comparator and disclose the basis. Endorsements, celebrity claims, and testimonials must not mislead.
Claims marked on labels without analytical substantiation are a routine cause of FSSAI enforcement action. An accredited test report from a NABL- and FSSAI-notified laboratory is the recognised evidence of substantiation.
Front-of-Pack Labelling (FoPL) and Indian Nutrition Rating
In 2022, FSSAI notified a draft amendment introducing the Indian Nutrition Rating (INR) — a 5-star front-of-pack labelling system inspired by the Australian Health Star Rating. Under INR, packaged foods are rated from ½ star (least healthy) to 5 stars (most healthy) based on positive nutrients (protein, fibre, fruit and vegetable content) and negative nutrients (energy, saturated fat, total sugar, sodium).
The INR system is being phased in for various food categories. Until full notification, brands should monitor draft amendments and prepare nutrition data and INR calculations for affected categories.
Exemptions from Labelling Requirements
Certain categories are partly or fully exempt:
- Foods packed in front of the consumer at point of sale (e.g. fresh tea, sliced cheese) — exempt from the full label, but the seller must be able to disclose ingredient and allergen information on request
- Small packages with surface area less than 30 cm² — abbreviated labelling allowed, but ingredient and allergen information must be available
- Bulk packages for industrial use — labelling for buyer / processor only
- Raw, unpackaged agricultural produce — exempt
- Restaurant-prepared foods served on premises — exempt from packaged-food labelling, but display of allergen, calorie, and other consumer information is mandated under separate FSSAI regulations for restaurants and aggregators
How Auriga Research Supports FSSAI Labelling Compliance
Auriga Research is a NABL-accredited and FSSAI-notified food testing laboratory that issues reports recognised by FSSAI for label substantiation. Our scope covers:
- Complete nutritional labelling panels — proximate, vitamins, minerals, fatty acid profile
- Dietary fibre testing by AOAC 985.29, 991.43, 2009.01, and 2011.25 for “source of” and “high in” fibre claims
- Amino acid analysis for protein quality scoring (PDCAAS / DIAAS) and amino-acid declarations on supplement labels
- Food additive testing for compliance with permitted limits
- Allergen testing for gluten, peanut, soy, milk, egg, fish, crustacean, and tree-nut allergens
- Heavy metals, pesticide residues, and microbiological testing for safety verification underlying the label
Reports cite the exact regulation and analytical method, are accepted by FSSAI licensing authorities, EIC for export, and third-party retail auditors.
Key Takeaways
- Food labelling in India is governed primarily by the FSS (Labelling and Display) Regulations 2020, which replaced the older 2011 regulations.
- Fourteen mandatory declarations apply to every pre-packaged food — from name and ingredients to allergens, date marking, and FSSAI licence number.
- Nutrition information must be declared per 100 g/mL and per serving, with separate disclosures for added sugar, trans fat, and sodium.
- The FSS (Advertising and Claims) Regulations 2018 set quantitative thresholds for “source of,” “high in,” “free of,” and other nutrient claims. Claims must be analytically substantiated.
- Category-specific rules apply to infant nutrition, edible oils, irradiated foods, organic foods, fortified foods, health supplements, and nutraceuticals.
- Front-of-pack labelling (Indian Nutrition Rating) is being phased in and will reshape pack design over the coming years.
Get in touch for an FSSAI-aligned labelling test panel — our scientists work with R&D and regulatory teams to map every claim on a draft label to the right analytical method, so the on-pack statement holds up in audit.
Auriga Research Team
Auriga Research is India's largest NABL-accredited testing network with laboratories in Delhi, Manesar, Bangalore, Baddi, and Bahadurgarh. Our team of scientists delivers accurate, regulatory-accepted results across pharmaceutical, food, water, environmental, and specialised testing.
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