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The last 4 (four) months of 2025 witnessed significant developments, supporting the growth of the Indian food and consumer sector. In September 2025, the Government of India rationalised the Goods and Services Tax (“GST”) slabs, pursuant to which the Indian food sector emerged as a major beneficiary, with most products now falling under the 5% GST slab. The tax rationalisation, among others, has facilitated the growth of Indian food and consumer sector. Continuing with sentiment to boost food export, the Agricultural and Processed Food Products Export Development Authority (“APEDA”) launched BHARATI (Bharat’s Hub for Agritech, Resilience, Advancement and Incubation for Export Enablement), aiming to empower 100 (one hundred) agri-food and agri-tech startups, foster innovation, and create new export opportunities to help achieve APEDA’s target of USD 50,000,000,000 (US Dollars fifty billion) in agri-food exports for its ‘Scheduled Products’ by 2030. This was a pilot run for 3 (three) months to serve as a model for a long-term, scalable incubation framework to drive continuous innovation and growth in India’s agricultural and processed food exports.[1] Interestingly, at the aligning with the Finance Minister’s budget proposal, the Ministry of Agriculture & Farmers Welfare, notified the formation of National Makhana Board (“NMB”) in Bihar with the primary objective to improve production, processing, value addition, marketing and export promotion of makhana.[2]
In October 2025, FSSAI instructed all States and Union Territories (“UT”) to ensure the efficient utilisation of installed High-End Equipment (HEE) and to obtain National Accreditation Board for Testing and Calibration Laboratories (“NABL”) accreditation for their food laboratories. This step is critical for ensuring greater reliability, uniformity, and scientific robustness in food sample testing nationwide.[3]
This edition of the JSA Foods and Consumer Newsletter highlights recent (September 2025 to December 2025) regulatory developments focused on consumer protection and the food businesses in India.
Introduction of new kind of business for ‘Ayurveda Aahara’ under Food Safety Compliance System for license/registration[4]
FSSAI has introduced a new Kind of Business (“KoB”) category, ‘Ayurveda Aahara’, on the Food Safety Compliance System (“FoSCoS”) portal aligning traditional recipes with contemporary food safety and quality standards aligning traditional recipes with contemporary food safety and quality standards. This allows manufacturers to obtain a license or registration for producing and marketing traditional Ayurvedic foods. The new category enables manufacturers across India to apply for such licenses seamlessly. The KoB framework for ‘Ayurveda Aahara’ aims to formalise and streamline the sector, aligning traditional recipes with contemporary food safety and quality standards. Businesses having a central license can make a payment of payment of annual fee of INR 7,500 (Indian Rupees seven thousand five hundred) plus GST. ‘Ayurveda Aahara’ refers to food prepared according to recipes and processes from authoritative Ayurvedic texts. It excludes medicinal products and narcotics. The order outlines the requirements and procedures for businesses to apply for KoB. The FSSAI has published a list of 91 (ninety-one) approved ‘Ayurveda Aahara’ recipes to provide Food Business Operators (“FBOs”) with a clear, pre-approved reference for manufacturing products under KoB, ensuring both authenticity and regulatory compliance and help facilitate a smooth transition for the industry.
Permission to manufacturers or packers or importers of pre-packaged commodities to declare the revised retail sale price on the unsold stock[5]
Following the GST rate rationalisation, the Ministry of Consumer Affairs, Food and Public Distribution (“MoCA”) has permitted manufacturers/packers/importers of pre-packaged commodities to declare the revised retail sale price (“MRP”) on existing stock. The revision may reflect an increase or decrease in tax due to the changes in GST rates. This relaxation applies to unsold stock as on September 22, 2025, upto December 31, 2025, or till such date the stock is exhausted, whichever is earlier, under the Legal Metrology (Packed Commodities) Rules, 2011. Declaration of the changed MRP is proposed to be made by way of stamping or putting stickers or online printing, after complying with certain conditions, such as:
- the original MRP continue to be displayed, and the revised price must not overwrite on it;
- the difference between the MRP originally printed on the package and the revised MRP must not, in any case, be higher than the extent of increase in the tax, if any, or in the case of imposition of fresh tax, such fresh tax, on account of implementation of GST Act and Rules. In the case of reduction of tax, the revised MRP must not be higher than the extent of price after reduction of tax, if any;
- manufacturers/packer/importers must make atleast 2 (two) advertisements in 1 (one) or more newspapers in this regard and also by circulation of notices to the dealers and to the Director of Legal Metrology in the Central Government and Controllers of Legal Metrology in the States and Union Territories, indicating the change in the price of such packages.
Subsequently, MoCA, vide letter dated September 18, 2025, has decided that the declaration of the revised MRP on unsold pre-packaged commodities/unused packaging material/wrapper bearing a pre-printed MRP is not mandatory. However, if the manufacturers/packers/importers/their representatives who may like to voluntarily affix additional revised MRP sticker, on unsold packages can do so if they desire. Further, the Central Government, has decided to waive off the requirement to issue advertisement, about revised MRP. The manufactures/packers/importers are required to only circulate the revised price list to wholesale dealers and retailers, with copies endorsed to the Director, Legal Metrology in Central Government and Controllers of Legal Metrology in States/ Union Territories, about the revised MRP. The advisory also permits use of old packaging material or wrappers printed before the GST revision, up to 31st March 2026 or until such stock is exhausted, whichever is earlier.[6]
Clarification regarding withdrawal of permissions for use of the term ‘ORS’ along with brand names[7]
FSSAI, vide order dated October 14, 2025, has superseded and withdrawn the earlier orders dated July 14, 2022, and February 2, 2024. These earlier orders had permitted the use of the term Oral Rehydration Solution (“ORS“) on food labels as part of the trademark with prefix or suffix in the product name, subject to a declaration requirement.
Subsequently, it is clarified that the use of the term ‘ORS’ in the trademarked name or in the naming of any food product, whether fruit-based, non-carbonated, or ready-to-drink beverages, is not permitted. Even when used with a prefix or suffix, such usage constitutes a violation of the provisions of the Food Safety and Standards Act, 2006 and the regulations made thereunder. All FBOs are directed to remove the word ‘ORS’ from their food products whether used as a standalone term or in combination with any prefix/suffix or as part of the trademark with prefix/suffix in the product name and to ensure strict compliance with the labelling and advertisement requirements prescribed under the Food Safety and Standards Act, 2006 and the regulations framed thereunder. The use of the term ‘ORS’ is misleading to consumers by way of false, deceptive, ambiguous, and erroneous names/label declarations. It is also in contravention of many sections of the Food Safety and Standards Act, 2006 and Food Safety and Standards (Labelling and Display) Regulations, 2020.
Provision for granting registration certificate for seasonal food businesses[8]
A provision in the FoSCoS for granting registration certificate for seasonal food business during short events such as religious fairs and food festivals is created under the window of ‘Registering Authority’ subject to prescribed conditions. Some of these conditions are:
- Registering Authorities are required to fill Form A of Food Safety and Standard (Licensing and Registration of Food Businesses) Regulation, 2011 on behalf of FBOs;
- KoBs such as retailers, food vending agencies, petty retailer of snacks/tea shops, hawker and food vending establishment are allowed to register;
- the validity of such registration will be upto 3 (three) months and is non-renewable; and
- a fee of INR 100 (Indian Rupees one hundred) will be charged. However, hawkers are exempted from registration fee.
Further, a user manual detailing the procedure of granting registration certificate on the FoSCoS portal by registering authorities is prescribed. This provision is already implemented in FoSCoS with effect from August 1, 2025.
Legal Metrology (Packaged Commodities) Amendment Rules, 2025[9]
Amendments are made to the Legal Metrology (Packaged Commodities) Rules, 2011, that aligns packaging and labelling rules for medical devices with the Medical Devices Rules, 2017. Key changes include requiring packages containing medical devices, to comply with the provisions of the Medical Devices Rules, 2017. These include making declarations for the height of any numeral and letter, and for the width of any numeral and letter. Further, in case where the Medical Devices Rules, 2017 are applicable, the relaxation given under Rule 33 of the Legal Metrology (Packaged Commodities) Rules, 2011, will not apply.
Legal Metrology (Government Approved Test Centre) Amendment Rules, 2025[10]
The Legal Metrology (Government Approved Test Centre (“GATC”)) Rules, 2013 is amended pursuant to the Legal Metrology (GATC) Amendment Rules, 2025. Some of the amendments made are as follows:
- the weights and measures specified in the First Schedule will either be verified by a GATC or by the legal metrology officers;
- any person desirous of obtaining recognition for carrying out verification of weights or measures must submit an application to the Joint Secretary, Department of Consumer Affairs in the specified format;
- the legal metrology officers of the concerned State Government, can inspect the premises of the test centre prior to making any recommendation for its approval, including the specification of its area of operation;
- the test centre can issue separate certificate of verification for each weight or measure, such that the certificate conforms to individual instrument;
- the test centre will undertake verification of weight or measure either in its authorised premises or within the territorial limits of the district, and may extend such verification to any part of the State in which the GATC operates; and
- The fee payable to test centre for verification or re-verification of weights or measures shall be as specified in the Fifth Schedule.
Food Safety and Standards (Import) First Amendment Regulations, 2025[11]
The Food Safety and Standards (Import) Regulations, 2017, is amended to include the manuals of the method of analysis, adopted by FSSAI, to be used for analysing the samples of food articles. However, in case the method for analysing any parameter is not available in these manuals, the food laboratory may adopt a validated method of analysis prescribed by AOAC / ISO / Pearson’s/ Jacob/ IUPAC/ Food Chemicals CODEX / BIS / Codex Alimentarius / Woodmen/ Winton-Winton/ Joslyn or any other internationally recognised regulatory agencies (earlier the agencies were not prescribed). Further, for the purposes of analysis of samples of imported articles of food, the notified laboratory or referral laboratory must provide the laboratory analysis report duly signed by its food analyst or director, within 5 (five) days from the date of receipt of the sample (earlier the report had to be signed by food analysts only). These amendments will come into force on May 1, 2026.
Advisory on environmentally compliant disposal of seized, rejected and expired food[12]
FSSAI has reiterated on the directives dated December 21, 2020, outlining the procedure for proper disposal of perishable, seized and rejected food items. All the designated officers, food safety officers, and enforcement teams are directed to follow the prescribed procedure to prevent improper disposal and maintain full compliance with the prescribed norms
Frequently asked questions on legal metrology
Frequently asked questions on legal metrology are accessible here. The same has been published by the Department of Consumer Affairs, Legal Metrology Division, on November 11, 2025.
Hydroxymethylfurfural to be considered as a quality parameter in Honey[13]
FSSAI has clarified that any honey sample found to be non-compliant with the prescribed limit of 80 mg/kg for Hydroxymethylfurfural will be categorised as ‘Substandard’ according to the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011. For context, it must be noted that jurisdictions such as European Union, United Kingdom and United States of America have a safety limit range that typically falls between 40 mg/kg to 80 mg/kg. To that end, setting an upper limit as prescribed by FSSAI should not only be a positive for the domestic consumer but also spur the Indian honey export segment.
SWIFT 2.0 streamlines food import processing, championing ‘Ease of Doing’[14]
FSSAI has integrated its Food Import Clearance System (“FICS”) with the Central Board of Indirect Taxes and Customs (“CBIC”) through the ICEGATE platform under the advanced SWIFT 2.0 initiative. This major digital integration is a significant milestone in promoting the Government’s vision of ‘Ease of Doing Business’ and trade facilitation. It is designed to (i) further streamline the import clearance process by enhancing transparency; and (ii) promoting efficiency across the system; (iii) significantly reduce human interface; (iv) minimises delays; and (v) ensures greater objectivity and accountability.
Advisory for milk vending kiosk[15]
To ensure food safety, consumer confidence and interests, transparency and to encourage participatory food safety culture, all dairy manufacturers who are involved in sale of milk/milk products through vending/kiosk machine have been directed to keep or make available FSSAI-approved/validated rapid test kits at the vending/kiosk location for basic detection of common adulterants in milk/milk products. The dairy units are required to ensure the following:
- display simple instructions on how to use the rapid test kit;
- facilitate consumer self-checking, by either allowing consumers to use kits at the kiosk area or keeping the kits for demonstration by trained staff;
- ensure that kits used are within validity period and stored as per manufacturer’s guidelines; and
- monitor and record the results and utilisation of testing kits.
Food Safety and Standards (Alcoholic Beverages) Second Amendment Regulations, 2025[16]
Amendments are made to the amend the Food Safety and Standards (Alcoholic Beverages) Regulations, 2018, which will come into effect from June 1, 2026. Accordingly, the maximum permissible limit of esters (as ethyl acetate) in alcoholic beverages is revised from 0.2 per gram per liter (“g/l”) to 3.0 g/l of absolute alcohol. These limits are typically higher than limits set in other major jurisdictions such as EU, the substantial increase is ester levels is also likely to increase marketability of alcoholic beverages through newer brands, flavours and varieties.
Extension of date of enforcement for labelling provisions[17]
The enforcement date of some provisions related to labelling for mead (honey wine), craft beer, Indian liquors, wine-based beverages, alcoholic ready-to-drink (RTD) products and Indian liquors, under the Food Safety and Standards (Alcoholic Beverages), First Amendment Regulations, 2025 (“Amendment Regulations”) was specified as January 1, 2026. Pursuant to the release of the Amendment Regulations, representations were received from various stakeholders expressing the operational operational difficulties that mid-year change in labelling requirements would create. Therefore, in order to omit such difficulties, extension has been provided in the date of enforcement up to July 1, 2026, for provision related to labelling under the Amendment Regulations.
Enforcement action against use of industrial dye auramine in food products such as roasted chana and other products[18]
The commissioners of food safety of all States/Union Territories and Central Licensing Authorities (“Licensing Authorities”) are directed to conduct targeted enforcement actions including inspections, sampling, testing and subsequent actions of roasted chana, and other similar food products which are vulnerable to adulteration through Auramine (an Industrial dye used for textiles and leather). Further, the Licensing Authorities are directed to initiate appropriate actions against the defaulting FBOs, under their respective jurisdictions and submit a consolidated action-taken report within 15 (fifteen) days.
Auramine, being a yellow dye, is used in chana, turmeric, yellow sweets and similar food items. Food business operators (not just makers/manufacturers) will now be obligated to comply with the exclusion obligation in this regard.
Legal Metrology (Packaged Commodities) Second (Amendment) Rules, 2025[19]
With effect from February 1, 2026, the rule of exemption in respect of packages where the net weight or measure of the commodity is 10 (ten) gram or 10 (ten) milli litre or less, if sold by weight or measure, will not apply to pan masala. Rule 26(a) of the Legal Metrology (Packaged Commodities) Rules, 2011 (“Rules”), describes the exemption in respect of certain packages, whereby the Rules will not be applicable to any package containing a commodity with the net weight of 10 (ten) gram or 10 (ten) milli litre or less, or any package containing fast food items packed by restaurant, or agricultural form produces in packages of above 50 (fifty) kilo gram etc.
Compliance of scheme of testing for packaged drinking water and mineral water[20]
The mandatory Bureau of Indian Standards (“BIS”) certification mark is no longer required for packaged drinking water and mineral water. Pursuant to the omission of the provision for mandatory BIS certification under the Food Safety and Standards (Prohibition and Restriction of Sales) Regulation, 2011, the scheme of testing of ‘Packaged Drinking Water’ and ‘Mineral Water’ is made to ensure safety and compliance of packaged drinking water and mineral water in the Indian market. Therefore, all FBOs have been directed to strictly comply with the prescribed scheme of testing. Further, the mandatory BIS certification mark is no longer required for packaged drinking water and mineral water. The prescribed scheme of testing for packaged drinking water outlines inter alia the following:
- packing provisions;
- the levels of control;
- microbiological requirements;
- parameters of the source water;
- types of containers; and
- hygienic conditions
Implementation of standardised format for submission of representation seeking risk assessment[21]
To ensure smooth management, tracking, and transparency by FSSAI, a standardised format for submission of representation is implemented for compliance. This aims to enable the scientific panels and scientific committee to conduct risk assessments in alignment with the Food Safety and Standards Authority of India (Transaction of Business and Procedure for the Scientific Committee and Scientific Panel) Regulations, 2016. Therefore, all stakeholders including FBOs, industry associations, research institutions, professionals, and citizens are invited to voluntarily share data generated through monitoring, internal assessments, or research & development relevant to food safety and nutrition, in the prescribed format.
Bureau of Energy Efficiency (Appliance Labeling and Compliance) Regulations, 2026[22]
The Bureau of Energy Efficiency has issued a comprehensive framework governing the display of essential information on labels, including their particulars, manner and time-limits, to establish the process for applying for and granting permission to affix such labels. These regulations outline the process of the following:
- appliance labelling and registration, including the process, particulars, time-limit, fee of label display along with process of refund of label security deposit and acceptable modes of payment;
- the process of label and compliance verification by the bureau, testing to ensure that the appliances or equipment conforms to the energy performance standards and norms as prescribed, conduct the failure check test for appliance or equipment; and
- publishing the operational manual consistent with the Energy Conservation Act, 2001, for the implementation of the Standards and Labelling Programme, including the procedure for undertaking the market surveillance activity or any other similar activity by the bureau or State designated agency and check testing.
This Newsletter has been prepared by:
|
Vivek K Chandy |
Saurya Bhattacharya |
Shika Suresh |
For more details, please contact [email protected].
[1] PIB, Release ID: 2163196, dated September 2, 2025
[2] Notification no. – CG-DL-E-14092025-266146, dated September 14, 2025
[3] FSSAI Press Release dated October 14, 2025
[4] Order no. – F. No. RCD-05007/1/2020, dated September 1, 2025
[5] Circular no. – I-10/14/2020-W&M, dated September 9, 2025
[6] PIB, Release ID: 2168208, dated September 18, 2025
[7] Circular no. – F. No. RCD-15001/6/2021-Regulatory-FSSAI [E-1475] dated October 15, 2025
[8] Order no. – F. No. 15(31)2020/FoSCoS/RCD/FSSAIpt1 (Comp. No. 1837), dated October 15, 2025
[9] Notification no. – CG-DL-E-24102025-267107, dated October 24, 2025
[10] Notification no. – CG-DL-E-24102025-267111, dated October 24, 2025
[11] Notification no. – CG-DL-E-04112025-267381, dated October 28, 2025
[12] Advisory number RCD-02005/10/2024-Regulatory-FSSAI-Part(1), dated November 03, 2025
[13] File No.:QA-11023/57/2024-QA-FSSAI-Part(1) QA, dated November 07, 2025
[14] Press release dated November 12, 2025
[15] RCD-15001/14/2025-Regulatory-FSSAI Advisory dated November 19, 2025
[16] FSSAI notification number F. No. Std/SP-21/A-1.2024/N-01, dated November 19, 2025
[17] File number Std/SP-21/T(Alcohol-6), dated November 27, 2025
[18] Circular number RCD-15001/16/2025-Regulatory-FSSAI, dated November 28, 2025
[19] Notification number CG-DL-E-02122025-268164, dated December 02, 2025
[20] File No.: RCD-15001/19/2025-Regulatory-FSSAI, dated December 17, 2025
[21] Office Order, File No. SS-G004/1/2024-Standard-FSSAI (Part-I), dated December 24, 2025
[22] Notification dated December 29, 2025
