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Law Update
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A new FSSAI notification has put the use of the word âPaneerâ under the scanner for certain analogue dairy products.
The Food Safety and Standards Authority of India issued a draft notification dated 22 September 2026 proposing an amendment to the Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011. The Gazette carrying the notification is dated 23 September 2026.
The important part is that this is not yet a final rule.
FSSAI proposes to restrict the manufacture and sale of an analogue product as Paneer. It has also specifically stated that products already licensed or registered under the category âAnalogue in Dairy Contextâ should discontinue the term âPaneerâ in their nomenclature, labelling and marketing. According to FSSAI, the reason is to prevent consumers from being misled about the nature and composition of the product.
For businesses, this does not mean that every analogue dairy product has suddenly become illegal. What it does mean is that manufacturers and brands using the word âPaneerâ for an analogue product now have a clear regulatory proposal to examine closely.
| Particular | Details |
| Issuing Authority | Food Safety and Standards Authority of India |
| Notification Date | 22 September 2026 |
| Gazette Date | 23 September 2026 |
| File Number | F. No. RCD-15001/1/2024-Regulatory-FSSAI |
| Document Status | Draft amendment |
| Governing Law | Food Safety and Standards Act, 2006 |
| Regulations Being Amended | Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011 |
| Relevant Provision | Regulation 2.1, sub-regulation 2.1.1 |
| Proposed New Clause | Clause (12) |
| Main Subject | Paneer made of constituents not derived from milk |
| Main Regulatory Proposal | Restrict manufacture and sale of an analogue product as Paneer |
| Main Regulatory Proposal | Products under âAnalogue in Dairy Contextâ are specifically addressed |
| Areas Mentioned | Nomenclature, labelling and marketing |
| Public Consultation | 60 days as calculated under the notification |
| Final Effective Date | Not expressly specified |
| Final Compliance Deadline | Not expressly specified |
| Submission Email | regulation@fssai.gov.in |
It is still a draft.
FSSAI has published the proposed amendment so that persons who may be affected can send objections or suggestions. The draft states that it will be taken into consideration after the expiry of 60 days from the date on which copies of the Official Gazette are made available to the public.
This distinction matters.
A draft tells businesses what the regulator is considering. A final regulation tells them what has actually become law and from when it applies.
So, at this stage:
The Gazette does not give a final commencement date.
FSSAI gives a fairly direct reason.
It wants to prevent consumers from receiving misleading information about the nature and composition of the product.
That makes this primarily a product-identity and consumer-information issue.
The concern is easy to understand. A consumer who sees the word âPaneerâ on the front of a package may understand that product in the conventional dairy sense. Where the product belongs to an analogue category, FSSAI does not want the name, label, or marketing to create a different impression about what the product actually is.
The notification does not say that every analogue dairy product is unsafe.
It does not present new health-risk data.
It does not cite an outbreak, accident, or scientific study.
The reason stated by FSSAI is much more specific: the consumer should not be misled about the product's nature and composition.
That distinction should remain clear in any business interpretation of the notification.
Food Safety and Standards Act, 2006
The proposal has been issued under the Food Safety and Standards Act, 2006.
The Gazette refers to Section 92 of the Act. FSSAI states that it proposes to amend with the previous approval of the Central Government while exercising the powers available under Section 92(2). The draft is being published as required under Section 92(1) so that affected persons have an opportunity to comment.
In practical terms, FSSAI is following the formal draft-regulation process.
Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011
The amendment would be made in the Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011.
These are the regulations under which the proposed Paneer-related restriction is being introduced.
Regulation 2.1 and Sub-Regulation 2.1.1
FSSAI proposes to amend Regulation 2.1, specifically sub-regulation 2.1.1.
After clause (11), a new clause (12) is proposed to be inserted.
The clause refers to:
âpaneer made of constituents not derived from milk.â
That short line carries most of the legal weight of the proposed amendment.
The draft has to be read in two parts.
The first part is the proposed legal amendment.
The second part is FSSAI's explanatory statement about what it wants to achieve.
1. Manufacture and sale
FSSAI says the amendment is intended to restrict the manufacture and sale of an analogue product as Paneer.
The wording âas Paneerâ is important.
It is different from saying that every analogue product is prohibited from being manufactured.
2. Existing analogue products
This notice pertains to the products which have been licensed or registered in the category:
âAnalogue in Dairy Products.â
Therefore, the scope of the notice is not only future but also present.
Existing product portfolios may also need attention if the final rule retains the same approach.
3. Use of âPaneerâ in the product name
Affected products are proposed to discontinue the use of âPaneerâ in their nomenclature.
In simple terms, businesses may need to reconsider the name under which such a product is identified.
4. Use of âPaneerâ on labels
The draft expressly mentions labelling.
If the proposal becomes final, existing artwork carrying âPaneerâ could therefore become one of the main practical areas for manufacturers and brand owners to review.
5. Use of âPaneerâ in marketing
FSSAI also includes marketing.
This extends the issue beyond the printed pack.
Websites, product catalogues, online listings, and promotional material may also need attention where they use the term for an affected analogue product.
The proposed clause uses a very short description:
âpaneer made of constituents not derived from milk.â
Businesses should resist the temptation to add technical detail that is not actually in the notification.
This draft does not specify:
So, this notification should not be used to invent a numerical test for deciding whether a product falls inside or outside the proposed clause.
A proper product-specific assessment may require reading the final regulation together with other applicable FSSAI food standards and product-category requirements.
This is where many short summaries can become misleading.
Based on this Gazette, FSSAI is proposing to restrict an analogue product being manufactured and sold as Paneer.
For products already licensed or registered as âAnalogue in Dairy Context,â FSSAI expressly says that use of âPaneerâ should be discontinued in:
The draft does not say that the entire analogue dairy category is being abolished.
It also does not say that every existing analogue product must cease to be manufactured regardless of what it is called.
That is why the proposal is better understood as a restriction on product identity and representation, based on the wording available in this notification.
This is one of the most important parts of the notification for existing businesses.
FSSAI has not limited the proposal to new applications. It has directly referred to products that are already licensed or registered under âAnalogue in Dairy Context.â
Product Nomenclature
If the final regulation retains the proposal, the product name may need to be reconsidered where âPaneerâ currently appears.
Businesses should therefore identify:
licensed product names,
commercial product names,
internal SKU descriptions,
customer-facing product names.
Product Labelling
Existing packs may carry âPaneerâ prominently.
That makes current artwork worth mapping now, even though the draft itself does not yet prescribe a final transition date.
Product Marketing
The word may also appear outside the package.
Businesses may need to identify its use in:
Licence or Registration Status
The Gazette does not say that existing FSSAI licences or registrations automatically become invalid.
Nor does this draft expressly prescribe:
Until further official instructions are available, businesses should not assume that such procedures have already been created.
Labelling is likely to be one of the biggest practical areas for affected food businesses.
What FSSAI expressly says
The Gazette says that products already licensed or registered under the relevant analogue category should discontinue the use of âPaneerâ in their labelling.
What a business may need to review
If the proposal is accepted, then the following must be assessed by the manufacturer or brand owner where the term is used:
There is also a commercial issue.
Many food businesses order packaging well in advance. A company may already have several months of printed material in stock.
The attached draft does not say how such packaging will be treated.
It does not provide an exhaustion period and does not say that existing packaging must immediately be destroyed.
That issue will need to be checked against the final regulations or subsequent FSSAI instructions.
Marketing is expressly mentioned in the notification, which means businesses should not limit their review to physical labels.
A product can be described in dozens of places after it leaves the factory.
The possible touch points may be:
Digital media
Trade materials
Retail material
The draft does not create a new separate advertising licence or marketing registration process.
The practical concern is consistency: if a product name ultimately has to change, old terminology should not continue circulating through other business channels.
Not expressly.
That point should be stated clearly because changing a product's name and changing its recipe are very different things.
The September 2026 draft does not expressly tell manufacturers to:
The proposal focuses on the manufacture and sale of the analogue product as Paneer, together with its naming, label and marketing presentation.
Some businesses may later consider reformulation for commercial reasons, but the attached draft itself does not establish a mandatory reformulation process.
The legal amendment is short.
Under Regulation 2.1 of the 2011 Regulations, FSSAI proposes that sub-regulation 2.1.1 be amended by adding a new clause after clause (11).
The proposed clause is numbered (12) and covers:
Paneer made of constituents not derived from milk.
For a business reader, the significance becomes clearer when this clause is read together with FSSAI's explanatory paragraph.
That paragraph states that the amendment is intended to restrict the manufacturing and sale of an analogue product as Paneer and that products already licensed or registered under âAnalogue in Dairy Contextâ should discontinue âPaneerâ in nomenclature, labelling and marketing.
| Area | What Can Be Established From the Gazette | Proposed Position | Business Meaning |
| Analogue products | Existing products are already licensed/registered under âAnalogue in Dairy Contextâ | FSSAI proposes a restriction concerning their representation as Paneer | Existing product portfolios may require review |
| Product name | Gazette does not reproduce the full earlier naming framework | âPaneerâ proposed to be discontinued for affected analogue products | Product nomenclature may need revision |
| Labelling | Full historical labelling position is not reproduced | Use of âPaneerâ is proposed to be discontinued | Artwork may require change |
| Marketing | Complete earlier marketing rules are not reproduced | Use of âPaneerâ is proposed to be discontinued | Promotional and digital content may need revision |
| Licence/registration | Existing licences/registrations are acknowledged | No automatic cancellation stated | Records should be reviewed, not assumed invalid |
| Reformulation | No such requirement stated | No express formulation change prescribed | Do not assume recipe change is mandatory |
It is deliberately a very narrow comparison. The Gazette does not reprint all of the existing legal regime concerning analogue dairy products, so no generalizations can be incorporated into this article without separate legal review.
| Stakeholder | Level of Relevance | Why It Matters | Main Review Area |
| Analogue dairy manufacturers | Direct | Manufacture and sale are central to the proposal | Product name, label and marketing |
| Existing FSSAI licence holders | Direct where covered | Existing licensed products are expressly mentioned | Product records |
| Existing registration holders | Direct where covered | Registered products are also mentioned | Product description |
| Brand owners | High operational relevance | Product branding may use âPaneerâ | Artwork and marketing |
| Private-label businesses | Possible indirect impact | Product identity may be shared across parties | Brand/manufacturer coordination |
| Contract manufacturers | Possible indirect impact | Manufacturing and product naming may involve different entities | Contract and artwork coordination |
| Distributors | Possible indirect impact | Existing stock and product masters may carry old names | Inventory/catalogue records |
| Retailers | Possible indirect impact | Shelf or online names may repeat supplier description | Product listing |
| E-commerce sellers | Possible indirect impact | Old titles may remain online | Listing review |
| Food-service operators | Possible indirect impact | Procurement descriptions may use product names | Sourcing and menu terminology |
Not every stakeholder in this table is directly regulated by the proposed clause in the same way. Some are listed because they could face a practical downstream effect if the product name changes.
Analogue Dairy Product Manufacturers
Manufacturers sit closest to the proposed restriction.
They may have to examine:
Brand Owners
For brand owners, the issue can move quickly from regulatory interpretation to packaging execution.
Artwork, marketplace listings, sales catalogues and retail records may all use the same product name.
Private-Label Businesses
Where a retailer or food brand sells a product made by another manufacturer, responsibility may be split across several teams.
That makes early coordination useful.
Distributors and Retailers
While these might not be the actual targets of the proposed manufacturing limit, they would most likely need to be changed in the long run.
E-Commerce Sellers
Online product information often lives independently of the physical pack.
If a product is renamed in the future, old listings should not be forgotten.
Restaurants and QSRs
Food-service operators that purchase such products may want to check how suppliers describe the item and how it is represented to customers.
The draft itself does not establish a new restaurant licence requirement.
FSSAI does not prescribe a detailed comment template in this notification.
Nevertheless, an effective submission by an industry should follow a logical format.
1. Clause being suggested
Name the specific clause that is being referred to.
2. Impact on the industry
In case of any effects of the clause on existing products, packaging, and production processes, elaborate on them.
3. Provide technical reasoning
Where a technical point is being raised, support it with relevant information instead of using only commercial arguments.
4. Address the consumer-information objective
FSSAI's stated concern is consumer understanding.
Any representation is likely to be clearer if it also explains how the suggested approach would deal with that concern.
5. Raise practical transition issues
Businesses holding large quantities of printed packaging may want to draw attention to implementation time and inventory management.
These points are practical suggestions. The Gazette does not prescribe them as mandatory contents of a representation.
The Gazette says that FSSAI will consider objections and suggestions received within the specified period.
Beyond that, businesses should avoid assumptions.
The draft does not tell us:
The next decisive document will therefore be the final FSSAI notification, if and when issued.
This section is especially useful for businesses because it separates what the Gazette actually says from what people may assume it says.
| Issue | Position in Draft |
| Final commencement date | Not expressly specified |
| Final compliance deadline | Not expressly specified |
| Transition period | Not expressly specified |
| Grace period | Not expressly specified |
| Existing packaging exhaustion | Not expressly specified |
| Mandatory reformulation | Not expressly specified |
| Replacement product name | Not expressly specified |
| New testing requirement | Not expressly specified |
| Laboratory testing method | Not expressly specified |
| Fresh licensing procedure | Not expressly specified |
| Licence amendment process | Not expressly specified |
| Additional fee | Not expressly specified |
| New specific penalty under this draft | Not expressly specified |
| Mandatory recall | Not expressly specified |
| Treatment of existing stock | Not expressly specified |
Businesses should not fill these gaps with assumptions.
Waiting for final wording does not mean doing nothing. It simply means separating preparation from mandatory implementation.
The draft should not automatically be interpreted as saying that:
The attached draft expressly creates none of these outcomes.
For many manufacturers, changing a product name is not as simple as editing a PDF.
Packaging may already exist at several points in the supply chain.
A business could have:
If the final rule keeps the same direction, companies may eventually have to coordinate all these touchpoints.
The difficulty is that the present draft does not tell businesses how existing inventory will be treated.
That is one reason why manufacturers may want to map their stock now without destroying or replacing it merely because a draft has been issued.
A sensible internal review can start before the final notification.
Product category
Confirm the exact FSSAI category under which the product is licensed or registered.
Product name
Check whether âPaneerâ appears in:
Labelling
List every active label and packaging format.
Marketing
Review websites, catalogues, distributor materials and advertisements.
E-commerce
Identify marketplace listings that may continue carrying an old product name independently of packaging.
Contract manufacturing
Where the brand owner and manufacturer are different entities, check who controls regulatory naming, artwork, and marketplace data.
This is regulatory preparedness, not a statement that all of these changes are mandatory today.
| Priority | Area | What to Review | Current Position |
| High | Product portfolio | Identify analogue products using âPaneerâ | Review now |
| High | FSSAI records | Check exact licensed/registered product description | Review now |
| High | Labels | Locate use of âPaneerâ across active packs | Practical preparation |
| High | Marketing | Find the term across brochures and advertisements | Practical preparation |
| Medium | E-commerce | Map live product titles and descriptions | Practical preparation |
| Medium | Packaging stock | Estimate unused printed material | Practical preparation |
| Medium | Supply chain | Identify distributor and retailer records | Practical preparation |
| Medium | Consultation | Decide whether an industry comment is necessary | Optional consultation action |
| High | Final regulation | Monitor FSSAI for final wording | Essential monitoring |
Product branding
A business that uses âPaneerâ as the commercial identity of an analogue product may have to reconsider the way that product is positioned.
For some brands, this may be a bigger issue than the technical amendment itself.
Packaging
Label artwork may need revision if the proposal becomes final.
Where a company sells several pack sizes, each artwork version may need separate attention.
Marketing
Packaging and marketing should not move in different directions.
Changing one while leaving the old name active everywhere else could create confusion.
Inventory
Existing stock may become a major implementation question.
The draft provides no specific answer on how such stock would be treated.
FSSAI records
Existing licence or registration information should be checked once final requirements are known.
Internal coordination
Regulatory, legal, quality, packaging, marketing, procurement and sales teams may all hold part of the information needed for implementation.
Identifying affected SKUs
Larger businesses may sell several similar products under different pack sizes or brand names.
Old printed packaging
Packaging procurement cycles can be long, particularly where minimum print quantities are high.
Multiple sales channels
A corrected factory label does not automatically update a marketplace, distributor catalogue or retailer database.
Third-party manufacturing
The brand owner may control marketing while the contract manufacturer controls regulatory records.
Uncertainty during the draft stage
Businesses must prepare without making unnecessary changes before the final rule is known.
FSSAI's stated objective is understandable: consumers should know the nature and composition of what they are purchasing. For the regulator, the question is one of clear product identity.
For businesses, however, the change could have operational consequences. Manufacturers may need to deal with:
A workable final framework will therefore matter not just because of what it prohibits, but also because of how businesses are expected to move from the old position to the new one.
Calling every regulatory restriction a âbanâ can make the position sound broader than the document actually is.
Here, FSSAI is proposing a restriction involving an analogue product being manufactured and sold as Paneer.
The supporting text then specifically addresses use of âPaneerâ in:
That is why businesses should focus first on how the product is identified and represented.
The draft does not expressly say that the whole analogue dairy category will cease to exist.
Treating the draft as final law
This may cause unnecessary expenditure before the final position is known.
Ignoring the draft completely
Businesses directly involved with analogue dairy products have a reason to review it now.
Assuming the licence is cancelled
The Gazette does not say this.
Reformulating without first understanding the rule
Changing a recipe can create its own production and compliance issues.
Forgetting digital product information
Websites and online listings can remain unchanged long after packaging is updated.
Relying only on headlines
A headline saying âanalogue Paneer bannedâ may leave out the fact that this notification is still a draft consultation proposal.
A useful way to approach this is to divide the work into two parts.
What applies today
Continue complying with the currently applicable FSSAI framework.
Do not invent a final commencement date from this draft.
What can be prepared now?
Businesses can:
This gives management a clear view of the potential workload without forcing premature implementation.
The final FSSAI notification will matter far more than assumptions made during the draft stage.
Businesses should watch for clarification on:
Since all these aspects are not yet officially known, we should leave all these questions open.
In cases where the analogue dairy product is involved, the first thing to consider is whether the new regulation applies to the product. Corpseed's FSSAI compliance services can support manufacturers, brand owners, and other food businesses in making that assessment.
1. Applicability Assessment
Corpseed can review the product category, current product description, and regulatory position to help identify whether the proposed change may be relevant.
2. FSSAI Licence and Registration Review
Existing licence or registration records can be checked against the business's actual product portfolio.
This helps identify gaps between internal product descriptions and regulatory records.
3. Product Nomenclature Review
Where âPaneerâ is being used, the product name can be mapped across licences, artwork, catalogues and internal records.
4. Food Labelling Compliance Services
Corpseed can assist with reviewing current label artwork and identifying points that may require attention once the final regulation is issued.
This may include checking how the product name appears across different pack sizes and label versions.
5. Marketing and E-Commerce Review
Websites, product catalogues and marketplace listings can be reviewed alongside physical labels so that product identity remains consistent.
6. FSSAI Regulatory Gap Assessment
A compliance gap review can distinguish:
7. Consultation Support
Businesses wishing to submit objections or suggestions can receive support in organising the regulatory and operational points they want to place before FSSAI.
The final regulatory decision remains with FSSAI.
8. Ongoing Food Regulatory Compliance Support
Once the final regulation is issued, businesses may need help interpreting its commencement date, transition conditions, and effect on existing products.
Corpseed can support such businesses through FSSAI regulatory compliance services, food labelling compliance services, licence review, and product compliance assessment.
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