Labelling Requirements on Packaging of Products
1. Key Definitions
a. Labelling: has been defined as any written, printed or graphic matter that is displayed on or near the label of the food. As per the provisions of Food Safety and Standards Act, 2006 and Food Safety and Standards (Labelling and Display) Regulations, 2020, the food business operators are required to label and display the information of their food articles on the packaging of the products.
b. Bakery Products: Regulation 2.4.15 of Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011 and First Amendment Regulations, 2021 defines bakery products –
i. Biscuit is a baked product
- Leavened or non-leavened
- Coated or uncoated
- Center-filled partially or wholly
but not limited to wafer biscuits, coated wafers, cookies, crackers, centre-filled biscuits, enrobed biscuits, sandwich biscuits, crème biscuit including fat free/ low fat or sugar free/ low sugar variants.
ii. Bread and bread type products such as rusks means the baked product prepared from a mixture of atta (whole wheat flour) and/or maida, water, salt, yeast or other fermentive medium or leavening medium.
2. General Requirements for Labelling of Products – As per regulation 5 of Food Safety and Standards (Labelling and Display) Regulations, 2020 every package shall carry the following information on the label:
a. Name of the food – Indicating the true nature of the food
b. List of Ingredients in the manner prescribed
c. Nutritional Information
d. Declaration regarding veg/non-veg along with the respective symbol
e. Declaration regarding food additives
f. Declaration of name and complete address of – brand owner, manufacturer, marketer, packer
g. FSSAI logo and license number
h. Declaration and manner of declaration of -Net quantity, Retail Sale Price, Consumer Care details: contact number and email id shall be as provided in Legal Metrology Act, 2009 and Legal Metrology Rules, 2011.
i. Lot/Code/Batch identification
j. Date of Manufacture or Packaging and Date of Expiry
k. Labelling of Imported foods
l. Country of Origin for Imported foods
m. Instructions for use
n. Declaration regarding food allergy
o. Declaration along with symbol of black colour cross which are not meant for human consumption
p. Further, any product meant for non- retail sale shall bear a statement “NOT FOR RETAIL SALE”.
q. Information relating to food allergens
r. Logo for veg or non-veg
s. Nutritional information
t. Information relating to organic food or ingredients
u. In case of multi-unit package containing several retail units the label of at least one retail unit containing the declarations required under these regulations shall be visible.
v. Particulars of declaration required under these Regulations on the label shall be in English or Hindi
3. Additional Declarations
A. Bakery Products –
i. Schedule II of Food Safety and Standards (Labelling and Display) Regulations, 2020
- Bakery product containing caffeine shall bear the following label: “CONTAINS CAFFEINE along with the quantity (ppm).”
- Bakery products where the trehalose is added shall bear the following label – “Contains Trehalose”
- “Polyols may have laxative effect” and “Polydextrose may have laxative effect” shall be displayed on the label.
- Food containing Isomaltulose to bear the declaration “Contains Isomaltulose—–(kcal) per 100gm or 100ml”
- Food containing 10% or more Sorbitol and Sorbitol syrup to bear declaration about laxative effect, bloating, diarrhea etc.
- Bakery products where dextrin is allowed, containing added Dietary Fibre (Dextrinsoluble fibre), shall bear the following declarations – “Contains Dietary Fibre (Dextrin) —– (Source of soluble Dietary Fibre)”
- Bakery products containing Artificial/non-nutritive sweeteners shall bear:
(i) This contains – (Name of the artificial/non-nutritive sweeteners)
(ii) NOT RECOMMENDED FOR CHILDREN
(iii) NOT FOR PHENYLKETONURICS (if Aspartame is added)
- Bakery products containing added plant sterol shall contain the following declarations –
“Contains Plant Sterol (as Phytosterols) —g/100g or 100ml.
Patients on cholesterol lowering medication should use the product under medical supervision
May not be nutritionally appropriate for pregnant and lactating women and children under the age of five years.
“CONSUMPTION OF MORE THAN 3g/DAY, TOTAL OF STEROL, STANOLS, OR COMBINATION THEREOF, SHOULD BE AVOIDED”.
- Maida treated with improver or bleaching agents shall bear the label: REFINED WHEAT FLOUR (MAIDA)TREATED WITH IMPROVER/BLEACHING AGENTS, TO BE USED BY BAKERIES ONLY
- Package of fortified food as per FSS (Fortification of Foods) Regulations, 2018 to carry the words fortified with (name of the fortificant) with logo.
- Food Business Operators (FBOs) to incorporate Quick Response (QR) codes on food product labels for easy accessibility to nutritional information for visually impaired individuals
- Bakery products containing an admixture of edible oils shall carry the following label -“Multi-Sourced Edible Vegetable Oils
(Name and nature* of edible vegetable oil) % by weight
(Name and nature* of edible vegetable oil) % by weight”
- The term “Gluten Free” shall be printed in the immediate proximity of the name of the product.
- Labelling of Milk and Milk products- “NOT TO BE USEDFOR INFANTS BELOW SIX MONTHS”
- Package of food undergone through process of irradiation shall bear the Radura logo and prescribed declaration on the label
- Gelatin meant for human consumption to bear the declaration “Gelatin Food Grade” on the label.
- Food containing Frozen Desert/Frozen Confection shall bear the declaration “Frozen Desserts/Frozen Confection is made with _____Edible Vegetable Oil/and Vegetable Fat” on the label.
- Food containing coated/packed with grade waxes shall bear the declaration “COATED WAX TO BE REMOVED BEFORE CONSUMPTION” on the label.
- Food with flavor emulsion and flavor paste shall bear the declaration “FLAVOUR EMULSION AND FLAVOUR PASTE FOR USE IN CARBONATED OR NON- CARBONATED BEVERAGES ONLY” on the label.
- Food with Fruit squash shall bear the declaration “CONTAINS ADDITIONAL SODIUM/POTASSIUM SALT” on the label.
- Food with dried glucose syrup shall bear the declarations “DRIED GLUCOSE SYRUP FOR USE IN SUGAR CONFECTIONERY ONLY” on the label.
- Package of certified organic food to carry the logo of Jaivik Bharat
ii. Food Safety and Standards (Vegan Foods) Regulations, 2022
i. Every package of vegan foods, shall carry the logo distinguishing the food article from non-vegan food.
iii. Food Safety and Standards (Health Supplements, Nutraceuticals, Food for Special Dietary Use, Food for Special Medical Purpose, and Prebiotic and Probiotic Food) Regulations, 2022
i. The words “HEALTH SUPPLEMENT/ NUTRACEUTICAL/ FOOD FOR SPECIAL DIETARY USE/ FOOD FOR SPECIAL MEDICAL PURPOSE/ PREBIOTIC FOOD /PROBIOTIC FOOD” as applicable to the concerned category, in capital and bold letters and A prominent statement indicating the target consumer group and/or age group if the product has been formulated for a specific age group
iv. Food Safety and Standards (Organic Food) Regulations, 2017
i. Organic status of the product (if produced organically) shall be displayed in a manner other than non-organic food items.
v. Food Safety and Standards (Advertising and Claims) Regulations, 2018
i. Claims regarding the non-addition of sugars to a food, where sugars are naturally present in the food, and in such case the following indication shall also appear on the label. ‘CONTAINS NATURALLY OCCURRING SUGARS’
B. Meat and Meat Products
ii. The companies who have obtained the Halal certificate have the option to display the Halal Logo on the labelling and packaging material of the product (food is free from any type of pork, alcohol, blood, gelatin, or any other non-halal ingredients).
4. Declarations on Menu, Boards and Booklets
- Establishments having Central license or outlets at 10 or more locations shall mention the calorific value (in kcal per serving and serving size) against the food items displayed on the menu cards or boards or booklets.
5. Bakery Products Over the Shelf
- calorific value, serving size, logo for veg or non-veg, any food allergens, nutritional information and certain warnings as specified in Schedule 2 to the Regulations, such as, “Polyols may have laxative effect” and “Polydextrose may have laxative effect”, added caffeine, artificial sweetener, dietary fibre and Last consumption date.
Exemptions from Labelling
- If they are provided in a Barcode/Global Trade Identification Number (GTIN), then there is no need for: (a) Address of the brand owner whether or not, he himself is the manufacturer, marketer, packer or bottler, as the case may be, (b) the license number of the manufacturer or marketer or packer or bottler, as the case may be, if different from the brand owner.
- Surface area of the package is not more than 100 square centimeters, shall be exempted from the list of ingredients, Lot Number or Batch Number or Code Number, nutritional information, labelling of irradiated food, declaration of food additives, License no and logo the name and complete address of the importer and instructions for use.
- In case of food with shelf-life of not more than seven days, the ‘date of manufacture’ may not be required to be mentioned, but the ‘Expiry/use by’ shall be mentioned.