GUIDANCE ON LABELLING REQUIREMENTS FOR FOOD IMPORTED INTO INDIA

Date: 27/04/2016

The following guidance on general labelling requirements for food items imported into India has been prepared by the New Zealand High Commission in
New Delhi with the objective of helping New Zealand exporters understand India’s food labelling requirements. While best efforts have been made to
ensure its accuracy as at the date of drafting, it should not be considered a substitute for due diligence. Exporters are strongly advised to read Chapter
2 of the Food Safety Standards (Packaging and Labelling) Regulation 2011 and subsequent amendments (noting that rules and regulations change
frequently), and to seek independent advice before finalising any labels for products to be exported to India . Please also refer to the Food Safety
Standards (Import Foods) Regulations 2016 and to www.fssai.gov.in for full details.

This guidance covers only general labelling requirements. Some food groups require special labelling such as:
o ‘infant milk substitute and infant food’ as included in section 2.4.1 of the Packaging and Labelling Regulations; and
o condensed and desiccated (dried) milk (see section 2.4.5(2) of the Packaging and Labelling Regulations).

GENERAL MANDATORY REQUIREMENTS

For all imported food and beverage items, the following general requirements must be met. The information must form part of the original food label
and cannot be affixed separately (i.e. by an additional sticker) at the time of import if the primary packaging label does not include the information.
1. The label must be printed in the English and/or Hindi languages.

2. Product information must be printed on a label securely affixed (i.e. not easily separable) to the package (i.e. by sticker) or printed on the
package itself.

3. No false, misleading or deceptive representation shall be made which can create an erroneous impression of the pre-packaged food in any respect.

4. The content of the label shall be clear, prominent, indelible, and readily legible by the consumer.

5. Where the container is covered by a wrapper, the wrapper shall carry the necessary information and be readily legible.

6. The name of the food must be mentioned along with trade name and description of the food contained.

7. The balance of shelf life of the food as on the date of import must be at least 60 percent of the shelf life.
Disclaimer: While every effort is made to ensure the accuracy of the information contained herein, this document only contains general information and is not formal advice. The
New Zealand High Commission does not endorse or warrant the accuracy, reliability or fitness for any purpose of any information provided. It is recommended that you seek independent
advice on any matter related to the use of the information. In no event will the New Zealand High Commission or New Zealand Government agencies be liable for any loss or damage
whatsoever arising from the use of the information.
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(This means that: 60 percent of the period from the ‘date of manufacture’ to the ‘best-before date’ or the ‘use by date’/ ‘recommended last
consumption’/’expiry date’, at the time of clearance from customs.)

**Laws from the Office of Legal Metrology are superseded by FSSAI’s regulations. However, two regulations from this office apply:
1. The retail sale price of the package: when reducing the Maximum Retail Price (MRP), a sticker with the revised lower MRP (inclusive of all
taxes) may be affixed but it shall not cover the original MRP declaration on the label of the package.
2. If a product is genetically modified, it must include on the label the initials “GM”**

In addition to the general mandatory requirements for food imports, there are additional labelling requirements depending on
whether your product is classified as “pre-packaged food” or “wholesale food”. We set out these additional requirements below and
indicate whether this information is required on primary packaging, or whether it can be supplied by the use of a sticker.

FOR PRE-PACKAGED FOOD FOR WHOLESALE FOODS Primary Use of

(including multi-piece packages) In addition to the general mandatory requirements, all Packaging Sticker (i.e.
“wholesale foods” are required to comply with the (i.e. at the time of
In addition to the general mandatory requirements, all labelling regulations set out in this column. Wholesale information import, a
“pre-packaged” or “pre-packed” food is required to foods include: must form sticker can be
comply with the labelling regulations set out in this - foods intended for sale, distribution/delivery to an part of the used to add
column. As per the rules, pre-packaged food means: intermediary and are not intended for sale direct to a original food this
food, which is placed in a package of any nature, in single consumer; label and information
such a manner that the contents cannot be changed - Commodities sold to an intermediary in bulk to enable cannot be to the label)
without tampering with it and which is ready for sale to such intermediary to sell, distribute or deliver such affixed (i.e. by
the consumer. commodity of food to the consumer in smaller quantities; an additional
and sticker)
- semi-finished/intermediary food products which will be separately at
further processed to make a final product and will be the time of
packed as pre-packaged or pre-packed food import if the
label does not
include the
information)

Mandatory information required on the label: Mandatory information required on the label:

1. The name of the food 1. The name of the food

2. List of ingredients (but not required for single 2. List of ingredients in descending order of their

ingredient foods) in descending order of their composition by weight or volume (but not required in
composition by weight or volume. (refer to regulations cases of single ingredient: raw agricultural commodities,
for specific details) spice mixes, condiments, non-nutritive products, alcoholic
Disclaimer: While every effort is made to ensure the accuracy of the information contained herein, this document only contains general information and is not formal advice. The
New Zealand High Commission does not endorse or warrant the accuracy, reliability or fitness for any purpose of any information provided. It is recommended that you seek independent
advice on any matter related to the use of the information. In no event will the New Zealand High Commission or New Zealand Government agencies be liable for any loss or damage
whatsoever arising from the use of the information.
 Page 3 of 6
beverages, fruits and vegetables, processed pre-
packaged vegetables and fruits are exempted from
nutritional labelling requirements.)

3. Nutritional information, per serving of the product 3. Nutritional information For any exemptions that

or per 100 gram or 100 ml with energy value in Kcal, may apply with regards to wholesale packaging, please
amount of protein, carbohydrates (specify quantity of refer to section 2.6.1 of the FSSAI Packaging and
sugar) and fat in grams or millilitres, amount of any Labelling regulations for detailed clarification.
other nutrient for which a nutritional or health claim is
made. (Note that Nutritional information for alcoholic
beverages is not required)

4. Declaration regarding vegetarian or non- 4. Declaration regarding vegetarian or non-

vegetarian vegetarian * these
symbols can
Vegetarian food must have a symbol consisting of a Not required be affixed
green colour-filled circle inside a square with a green using a single
non-
outline prominently displayed on the package,
detachable
contrasting against the background on the principal
sticker or by
display panel, in close proximity to name or brand name
any other
of the food; and non-vegetarian, i.e. any food which
non-
contains whole or part of any animal including birds,
detachable
marine animals, eggs, or products of any animal origin
method next
as an ingredient, excluding milk or milk products), must
to the
have a symbol of a brown colour-filled circle inside a
principle
square with a brown outline prominently displayed display panel.
on the package, contrasting against the background on
the principal display panel, in close proximity to the
name or brand name of the food.
(Declaration of vegetarian /non-vegetarian logo shall
not apply for alcoholic beverages)

5. Declaration of food additives. Food additives 5. A declaration of food additives

contained in the food product must be mentioned along
with class titles and specific names or recognised Not required.
international numerical identifications.
- Addition of colour must be mentioned with “CONTAINS
PERMITTED NATURAL COLOURS” just beneath the
Disclaimer: While every effort is made to ensure the accuracy of the information contained herein, this document only contains general information and is not formal advice. The
New Zealand High Commission does not endorse or warrant the accuracy, reliability or fitness for any purpose of any information provided. It is recommended that you seek independent
advice on any matter related to the use of the information. In no event will the New Zealand High Commission or New Zealand Government agencies be liable for any loss or damage
whatsoever arising from the use of the information.
 Page 4 of 6
ingredients on the label.
- Where an extraneous flavouring agent has been used
labelling should include a statement like “CONTAINS
ADDED FLAVOUR” just beneath the list of ingredients on
the label.

6. Name and complete address of the
manufacturer, of the manufacturing or packing or
bottling unit and also the name and complete
address of the manufacturer or the company for
and whose behalf it is manufactured or packed or
bottled. This information should be indicated with a
prefix of “Mfd. By/ prd By:/ Pkd by:”
6. Name and complete address of manufacturer

indicated with a prefix of “Mfd. By/ prd By:/ Pkd by:”
Note: When bulk food is packaged or bottled in India, the
name and address of the premises of packing or bottling
in India must be included.

7. Date of manufacture or packing: The month and 7. Date of manufacture or packing

year in which the commodity is manufactured, packed
or pre-packed shall be indicated on the label. (Note: Not required.
FSSAI has advised verbally that this information may be
ink jetted or stamped on the product label or carton.)

Note: labelling for milks and other foods must include

the date, month and year in which the item is
manufactured.

8. Net quantity: weight or volume or number shall be 8. Net quantity: weight or volume or number shall be

declared on every package of food. declared on every package of food.

9. Lot/code/batch identification: mark of 9. Lot/code/batch identification:

identification by which the food can be traced to the
manufacture and distribution shall be indicated on the
label. This should be identified with a prefix of “Lot No.
/ Batch No.” FSSAI has advised verbally that this
information may be ink jetted or stamped on the
product label or carton.
mark of identification by which the food can be traced to
the manufacture and distribution shall be indicated on the
label. This should be identified with a prefix of “Lot No. /
Batch No.” FSSAI has advised verbally that this
information may be ink jetted or stamped on the product
label or carton.

(Note: Milk and Bread are exempted) (Note: When bulk food is packaged or bottled in India,
the name and address of the premises of packing or
bottling in India must be included.)

Disclaimer: While every effort is made to ensure the accuracy of the information contained herein, this document only contains general information and is not formal advice. The
New Zealand High Commission does not endorse or warrant the accuracy, reliability or fitness for any purpose of any information provided. It is recommended that you seek independent
advice on any matter related to the use of the information. In no event will the New Zealand High Commission or New Zealand Government agencies be liable for any loss or damage
whatsoever arising from the use of the information.
 Page 5 of 6
10. Best before and use by date: The date, month 10. Best before and use by date

and year in capital letters up to which the product is
best for consumption. FSSAI has advised verbally that Not required.
this information may be ink jetted or stamped on the
product label or carton.

Milks and other foods must include the date as well as

the month and year.

Exception: the declaration of best before date for

consumption shall not be applicable to: i. Wines and
liquors, ii. Alcoholic beverages containing 10 percent or
more by volume of alcohol.

11. Country of origin for imported food: 11. Country of origin

i. The country of origin of the food shall be declared on
the label of the food imported into India.
ii. When a food undergoes processing in a second Not required.
country which changes its nature, the country in which
the processing is performed, shall be considered to be
the country of origin for the purposes of labelling.
12. Instructions for use: If necessary, shall be 12. Instructions for use: If necessary, shall be

included on the label to ensure correct utilization of the included on the label to ensure correct utilization of the
food. food.

13. The FSSAI logo and license number of the brand 13. Name and complete address of the importer with
A
owner shall be displayed on the label of the food the prefix “Imported by”. requirement
package in a colour that is in contrast to the as of
background in case of multiple units (manufacturer/ 31/12/2015.
packer/re-labeller/marketer) as below:

FSSAI
Lic. No. XXXXXXXXXXXXXXX

The addresses of the multiple units on the label should

carry the license number as “Lic. No.
XXXXXXXXXXXXXXX”. In addition, the license number
of manufacturing unit where the product is prepared
shall also be displayed along with the lot number.
Disclaimer: While every effort is made to ensure the accuracy of the information contained herein, this document only contains general information and is not formal advice. The
New Zealand High Commission does not endorse or warrant the accuracy, reliability or fitness for any purpose of any information provided. It is recommended that you seek independent
advice on any matter related to the use of the information. In no event will the New Zealand High Commission or New Zealand Government agencies be liable for any loss or damage
whatsoever arising from the use of the information.
 Page 6 of 6

14. Name and complete address of the importer in 14. Name and complete address of the importer in
A
India with the prefix “Imported by”. India requirement
as of
Not required. 31/12/2015.

15. Size of the label: The label shall be legible and 15. Size of the label:

prominent, definite, plain and unambiguous; and
conspicuous as to size and colour. Refer to the Food Not required.
Safety Standards Packaging and Labelling Regulation
2011 for further detail.

Disclaimer: While every effort is made to ensure the accuracy of the information contained herein, this document only contains general information and is not formal advice. The
New Zealand High Commission does not endorse or warrant the accuracy, reliability or fitness for any purpose of any information provided. It is recommended that you seek independent
advice on any matter related to the use of the information. In no event will the New Zealand High Commission or New Zealand Government agencies be liable for any loss or damage
whatsoever arising from the use of the information.