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FSSAI Pan Masala Packaging Amendment Regulations, 2026: Compliance Guide for BusinessesSummary: Pan masala is provided with a special packaging entry by the Food Safety and Standards Authority of India. Food Safety and Standards (Packaging) Amendment Regulations, 2026, include pan masala in Schedule IV of the Food Safety and Standards (Packaging) Regulations, 2018. The new entry says that paper, paperboard, cellulose, and other naturally derived materials used for pan masala must be free of plastic. They must also be free from aluminium foil and metalized layers. Tin and glass containers are included as other packaging choices. The notification does not state a separate grace period. Pan masala manufacturers, packers, brand owners, importers, and packaging suppliers should therefore examine every layer and component of their packaging. Although these rules are brief, their impact on businesses could be more than expected. The bag might appear to be made of paper but actually be made of plastic, aluminium, or metallised films. Businesses require facts about materials, not assumptions based on appearance. Notification at a Glance Particular Verified detail Issuing authority Food Safety and Standards Authority of India Governing law Food Safety and Standards Act, 2006 Regulations amended Food Safety and Standards (Packaging) Regulations, 2018 Schedule amended Food Safety and Standards (Packaging) Regulations, 2018 Product covered Pan masala Main stakeholders Manufacturers, packers, brand owners, importers and packaging suppliers Main development Addition of plastic-free, foil-free packaging choices for pan masala Transition period Not expressly specified Separate compliance deadline Not expressly specified; the amendment states that it starts on publication The Regulatory Framework Food Safety and Standards Act, 2006 The Food Safety and Standards Act, 2006, is India’s main central law for food safety. It created the FSSAI and gave it the authority to make food regulations. The Act covers many matters, including how food is made, stored, distributed, sold, and packaged. The 2026 notification refers to section 92 of the Act. Section 92 provides the regulation-making process. The final notification states that FSSAI used the power under section 92(2)(k), with the previous approval of the Central Government, to amend the Packaging Regulations. In simple words, FSSAI did not issue this as an informal suggestion or a news release. It issued amendment regulations in the Official Gazette under the powers conferred by the Act. Food Safety and Standards (Packaging) Regulations, 2018 The Packaging Regulations establish general standards for packaging materials used to package food products. According to these regulations, primary packaging materials are materials that come into direct contact with the food product. Secondary packaging comes around the primary pack but does not come into direct contact with the food product. The regulations require food-contact packaging to be food-grade. Packaging must suit the food, storage conditions, filling and sealing equipment, transport conditions, and normal mechanical, chemical, or heat stress. Food must also be packed in a clean, hygienic, and tamper-proof package. Another important rule concerns evidence. The official FSSAI compendium states that a food business operator must obtain a certificate of conformity from a National Accreditation Board for Testing and Calibration Laboratories (NABL)- accredited laboratory for packaging that directly touches food or is likely to touch it. Schedule IV gives a product-wise list of suggestive packaging materials. The base regulations describe this as an indicative list and generally do not preclude the use of other materials that meet the specified standards. The new pan masala entry, however, uses direct words such as “shall be free from any plastic.” This means businesses should not read the word “suggestive” as permission to ignore the express plastic-free and foil-free conditions. Where there is uncertainty, a written legal or regulatory view is safer than a broad assumption. Connection with the Plastic Waste Management Rules, 2016 The amendment does not work alone. It expressly says that clauses (f) and (i) of Rule 4(1) of the Plastic Waste Management Rules, 2016, also apply. Rule 4(1)(f) says that sachets made of plastic material must not be used for storing, packing, or selling gutkha, tobacco, and pan masala. Rule 4(1)(i) is wider. It states that plastic material in any form, including Vinyl Acetate-Maleic Acid-Vinyl Chloride Copolymer, must not be used in any package for gutkha, pan masala, or tobacco. This is a vital point. The environmental rules already contained a plastic restriction. The FSSAI amendment now includes a clear entry for pan masala material in the food-packaging schedule and expressly links it to those environmental rules. The Plastic Waste Management Rules also state that Rule 4 export exemption does not apply to units packaging gutkha, tobacco, and pan masala. Businesses should therefore avoid assuming that an export order automatically removes the packaging restriction. What Has Changed? The change in Schedule IV is directly caused by the introduction of Serial Number 11 for pan masala. This includes three interrelated aspects: approved material categories, excluded material categories, and the link to the Plastic Waste Management Rules. Addition of Pan Masala to Schedule IV Before this amendment, the 2025 version of the FSSAI Packaging Regulations listed ten product categories in Schedule IV. Pan masala did not have its own entry in that version. The amendment inserts pan masala after Serial Number 10. This makes the expected packaging direction easier to find within the FSSAI food-packaging framework. A manufacturer no longer needs to look only at a general environmental ban to understand the basic material position. Permitted Packaging Materials The new entry names the following material categories: Paper Paperboard Cellulose Other naturally derived materials Tin containers Glass containers Paper, paperboard, cellulose, and other naturally derived materials are not approved without conditions. The notification says these materials must be free of any plastic. It also says they must not contain aluminium foil or metallised layers. A paper pouch with a hidden polyethylene coating may fail the stated condition. The same concern can arise when a paper pack contains a polyester layer, a synthetic laminate, or a metallised film. The outside appearance of a package is therefore not enough to prove compliance. Tin and glass are named as container choices. These containers must still meet the general FSSAI rules on food-grade quality, cleanliness, suitability, sealing, and safe food contact. For example, choosing a glass jar does not eliminate the need to assess its closure, seal, and any component that may come into contact with the product. Prohibited Packaging Materials and Components The notification says the naturally derived material must be free from any plastic, including but not limited to: Polyethylene, often called PE Polypropylene, often called PP Polyester Polyvinyl chloride, or PVC Any synthetic polymer Copolymers Laminates containing prohibited plastic Aluminum foil Metalized layers The words “including but not limited to” matter. The list provides examples, but it is not exhaustive. A business cannot treat an unlisted plastic as allowed simply because its chemical name does not appear in the notification. The phrase “any plastic” also makes it risky to assume that bio-based, biodegradable, or compostable plastic is acceptable. Such material may still legally be a plastic. The amendment does not create a clear exception for it. Does the Restriction Cover Every Packaging Component? The entry speaks about material used for pan masala packaging and also refers to plastic material “in any form” through Rule 4(1)(i). A safe compliance review should therefore examine the whole pack, including: The main pouch, jar, or tin Inner linings and barrier layers Heat-seal coatings Plastic-based adhesives Lids, caps and closure systems Inner seals and membranes Transparent windows Labels and shrink sleeves Printing coatings and varnishes Tamper-evident parts The notification does not explain every small component separately. It also does not clearly state how its new Schedule IV wording applies to secondary transport material that never forms part of the consumer pack. Those questions should be assessed against the exact pack design, the general Packaging Regulations, and the Plastic Waste Management Rules. Earlier Position vs New Position Earlier verified position New position from 10 August 2026 Plastic was already barred for pan masala packaging under the Plastic Waste Management Rules. Schedule IV had no separate row for pan masala. Serial Number 11 now names natural material, tin, and glass options and expressly excludes plastic, aluminum foil, and metalized layers from the natural-material format. The amendment therefore makes the material direction clearer within the FSSAI framework. It does not mean that plastic was freely allowed before 10 August 2026. Scope and Applicability Products and Businesses Covered The new entry expressly covers pan masala. It does not create a new product definition. Businesses should check the product standard, ingredients, label, and FSSAI license before deciding whether a similar product is covered. Supari or mouth freshener should not be included only because it is sold in a small pouch; equally, changing a product name does not change its true legal classification. These are the parties who are directly involved: manufacturers, contract packers, brand owners, importers, and packaging suppliers. Distributors and retailers may also require stock information. Imported pan masala intended for India must comply with India's packaging regulations. The Plastic Waste Management Rules are also important for exporters. Their general Rule 4 export exemption does not extend to units packaging gutkha, tobacco, and pan masala. Implementation Timeline and Norms Notification, Publication and Effective Dates The draft notification was released on 28 April 2026. The notification date is 7 August, whereas the gazette date is 10 August 2026. Since the amendment will commence from the date of publication, 10 August 2026 will serve as the date of operation. No other implementation date is stated in the notification. Is a Transition or Grace Period Available? There is no explicit mention of any transition, grace period, or phased implementation. Redesign of the package may be difficult, but business difficulty, per se, does not constitute a legal extension. Existing Packaging and Finished Goods There is no information in the notification on how much older packaging, produced before 10 August, can be used. The notification does not provide a definite rule for the sell-through of existing packaged goods. Businesses should segregate unused packaging materials, WIP, factory and market stock, and take a document-specific approach. Why Was This Amendment Implemented? Closing the Gap Between Paper Appearance and Actual Composition The Plastic Waste Management Rules have already banned plastic packaging for pan masala. In practice, a pack described as “paper-based” can still be a mixed structure. It may contain a plastic barrier, a heat-seal coating, a synthetic adhesive, aluminium foil, or a metallised layer. A 2026 Bureau of Indian Standards innovation challenge explained that manufacturers had shifted to multilayer paper-based laminates, but these small mixed-material sachets remained hard to collect, separate, and recycle. It also identified the continued use of plastic-based adhesives and heat-seal coatings as a concern. The FSSAI amendment gives businesses a clearer material direction: natural material must actually be free from plastic, foil, and metalized layers. Waste and Litter Concerns Small sachets are light and easily scattered. Their size makes collection difficult. When several materials are bonded together, separation and recycling become harder. Such packs can escape normal waste systems and become litter in streets, drains, fields, and water bodies. The final notification does not include a detailed statement of reasons. The waste explanation should therefore be understood as part of the verified policy context, not as extra wording inserted into the legal clause. Promotion of Workable Alternatives The amendment does not merely list banned materials. It also names paper, paperboard, cellulose, other naturally derived materials, tin, and glass. This gives manufacturers a starting group of alternatives. The hard part is performance. Pan masala packaging often needs moisture protection, aroma retention, seal strength, and enough shelf life for distribution. A truly useful alternative must align with environmental goals while keeping food safe and stable. Impact on Businesses Impact on Pan Masala Manufacturers Manufacturers need the exact construction of every pack. “Paper pouch” is too broad. Quality and procurement teams need layer-wise data, while production teams must check whether the material fills and seals safely on existing equipment. Impact on MSMEs MSMEs may face a heavier short-term adjustment because they buy smaller quantities and may have fewer packaging experts. They should not accept an “eco-friendly” claim without a composition statement and suitable evidence. Impact on Packaging Suppliers Suppliers now have a reason to develop plastic-free, foil-free barriers that still control moisture and aroma. Clear layer information and reliable evidence will matter more than labels such as “green laminate.” Cost and Supply-Chain Impact The cost may be due to factors such as research, testing, changes in machinery or suppliers, and even stock loss. The use of tin and glass packing materials might also contribute to weight, storage, and damage costs. There will be no cost associated with the notification. The cost may depend on the type of material used, pack size, quantity, machine, and shelf life. How Businesses Will Achieve Compliance Step 1: Confirm Product Classification Check the ingredients, food standards, FSSAI license, and label to determine whether the product is classified as pan masala. Step 2: Complete Package Analysis Prepare a bill of materials identifying all substrates, coatings, adhesives, seals, caps, labels, etc. Do not limit yourself to the substrate only. Step 3: Identify Prohibited Material Check for the presence of polyethylene, polypropylene, polyester, PVC, other polymers, copolymers, plastic laminates, aluminum foils, metallizations, etc. Maintain the status of "unknown" for each material until identification. Step 4: Selection of Alternative Material Narrow down your selection to paper, paperboard, cellulose, natural material, tin, glass, etc. Check the moisture resistance, aroma, strength, sealing, storage, and transport conditions. The cheapest material would be useless if it affects the product quality. Step 5: Confirming the Supplier A signed composition declaration and technical data sheets for plastic, foil, and metallization must be requested. All papers must be confirmed against the specific grade. Inform us of any alteration in the material. Step 6: Testing and Validation Obey FSSAI guidelines for testing and get a certificate of compliance for the packaging material that comes into direct contact. Testing can be carried out for migration, smell, seal strength, leakage, moisture, aroma, transport, and shelf life. Distinguish between mandatory testing and testing associated with product development. Step 7: Run Machine Trials Conduct machine trials with the material at normal speed and note any tearing, poor feeding, low seal strength, and rejection rate. Train the operator regarding the parameters. Step 8: Control Inventory Reject unknown material, separate the old and new materials, and associate approved packaging codes with the specific product and line. Step 9: Update Internal Controls Update purchase specifications, the approved supplier list, incoming inspection, change management, and allocate responsibilities to the regulatory, purchasing, quality, engineering, and warehouse departments. Documents and Evidence Businesses Should Maintain There is no specific requirement for any documents on pan masala under the notification. In line with the Packaging Regulations, it is necessary to provide a conformity certificate for the food contact package. The required internal documents will be: Packaging bill of material Composition declaration and technical data sheet of supplier Conformity, food contact, and migration report Shelf life and machine trial report Purchase specification and vendor approval form Change control, batch record, and packaging code. Mandatory and recommended controls need to be segregated. It needs to be identified as per the actual commercial grade. The generic brochure is poor evidence because it doesn't show the actual structure purchased. Benefits for Businesses Full material maps mean the company will have greater control over changes from suppliers. Specifications prevent the company from getting an incorrectly described laminate. A package that is truly free of plastics might help the company establish a positive image, if the claims are true. The need for good alternatives can drive innovation and collaboration with suppliers. Trackable decisions will allow the company to inspect the process and conduct internal audits. Not all of these advantages will necessarily be achieved. Challenges and Cost Implications The biggest technical challenge will be replacing the plastic or foil without exposing the contents to moisture, while maintaining its smell and ensuring a good seal. Metal and glass packaging can be highly protective, yet more expensive and heavy. Glass packaging can be breakable. Metal containers will require special closure and analysis when handling corrosive products. Paper and cellulose packaging can be lightweight; however, it might be hard to design a plastic-free barrier and heat-sealing system. The lack of additional time before changes raises certain expectations, especially for MSMEs and companies with stockpiles. The right response is not to lower food safety. It is to redesign the package with legal, technical, and production teams working together. Is This the Right Decision or an Additional Burden? The amendment has a valid environmental purpose, but it also creates practical and financial challenges. The following table presents a balanced assessment. Assessment area Why the decision makes sense Additional burden on businesses Balanced view Environmental protection Plastic-free packaging can reduce difficult-to-collect and difficult-to-recycle waste. Alternative materials may still require technical development and proper disposal systems. The environmental goal is reasonable, but the alternative must work throughout its full life cycle. Clearer packaging rules The amendment makes it clear that paper packaging cannot contain hidden plastic, aluminium foil or metallised layers. Businesses must examine every coating, adhesive, barrier, seal, and closure. Clear rules reduce confusion, but FSSAI guidance on smaller packaging components would help. Packaging innovation The rule can encourage the development of paper, cellulose, tin, glass, and other suitable alternatives. New materials may not yet be widely available or affordable. Innovation may create long-term value, but businesses need scalable and cost-effective solutions. Food safety and quality Businesses are encouraged to select packaging that is both compliant and food-grade. Plastic-free materials may face problems with moisture, aroma retention, sealing, and shelf life. Environmental compliance should not weaken food safety or product quality. Proper testing remains essential. Cost of compliance Better packaging controls can improve supplier management and material traceability. Manufacturers may face costs for testing, machinery, supplier development, and packaging conversion. Larger businesses may adjust faster, while MSMEs may need technical and financial support. Implementation period Immediate application can accelerate the move toward compliant packaging. The notification does not expressly provide a grace period or phased implementation plan. A reasonable transition period could have reduced disruption without weakening the regulatory objective. Existing stock Immediate application discourages continued use of potentially non-compliant packaging. The notification does not clearly explain how unused packaging and already-packed goods should be treated. Written clarification on old stock and sell-through conditions would improve consistency. Overall business impact Early compliance may improve reputation and create a market for sustainable packaging. Short-term costs, material shortages, and production changes may affect business continuity. The decision is justified in purpose, but its success depends on clear guidance, affordable alternatives, and practical support. Balanced Conclusion This amendment is not just an advantage or disadvantage. The environmental goals of this amendment are justified because it tackles hidden plastics and packaging waste that are difficult to manage. However, manufacturers will pay more due to costs, technology issues, and uncertainty about current stock. We should get additional clarity from FSSAI on packaging components, evidence, old stock, and implementation. MSMEs might require assistance with testing and materials. Business Opportunities Created The modification can drive demand in the entire packaging industry. Paper and Cellulose Materials without Plastic Companies can manufacture paper and cellulose materials that regulate moisture and odour without using any plastic. Testable claims have to be made. Packaging Using Tin and Glass Containers Firms can produce small, light, and safer tin and glass containers. Designing closures will still be critical. Testing and Technical Assistance Laboratories can experience increased demand for food contact, material, barrier, seal, and shelf-life testing when using proper techniques. Machinery and Retrofitting Equipment manufacturers can provide sealing and filling equipment or adapt machines to handle natural materials. Compliance and Supplier Services Packaging audit, supplier assessment, legal validation, and change management services will also be needed. The biggest business opportunities are those that meet three requirements: legal compliance, food safety, and feasibility of mass production. Risks and Consequences of Non-Compliance There is no specific penalty prescribed for pan masala under the 2026 notification. Businesses should not quote any penalty amount as a general rule, since violations must be assessed under the FSSA and environmental laws, taking into account the specific circumstances of each case. These include questions that may arise during inspections and product testing, the inability to shift stock, decisions on product withdrawal, conflicts with suppliers, production halts, and damage to brand reputation. There may be other risks associated with environmental deception. Inadequate information is the biggest risk to controls. If the supplier designates a packaging structure as ‘paper’ and does not inform you of its plastic coating, the end package will not meet the new requirement. Documentation and change controls are thus fundamental controls. Practical Compliance Checklist Ensure that the product is properly classified as pan masala. Document the packaging structure completely. Check for layers made of polyethylene, polypropylene, polyester, and PVC. Check for other synthetic polymers and copolymers. Check for aluminium foil and metallised layers. Review coatings, adhesives, seals, caps, and labels. Obtain exact supplier composition information. Confirm applicable food-contact requirements. Obtain the applicable certificate of conformity. Complete suitable safety and performance tests. Validate shelf life and product quality. Run the material on the actual packing machine. Separate uncertain old packaging and finished stock. Revise purchase and supplier requirements. Train regulatory, purchasing, quality control, and manufacturing staff. Maintain batch, material, and change-control documentation. Examples of controls that can be implemented include the bill of materials, machine trial report, and internal checklists, unless another requirement or license condition necessitates their use. The requirement for a certificate of compliance arises from the general FSSAI Packaging Regulations for food contact packaging. How Corpseed Can Help Corpseed helps pan masala manufacturers, importers, brand owners, and packaging companies understand and follow the new FSSAI packaging requirements. The support is based on the actual product, the materials used in its packaging, and the compliance gaps that need to be addressed. 1. Checking Whether the New Rules Apply Check whether the product is a pan masala product according to the law. Determine which FSSAI packaging regulations pertain to the product and business. Describe what is required and what needs further clarity. 2. Reviewing the Complete Packaging Structure Check every part of the packaging, including its layers, coatings, adhesives, seals and closures. Find any plastic, aluminium foil, or metallised material hidden inside the package. Assess whether the proposed packaging material meets the amended requirements. 3. Finding Compliance Gaps Compare the existing packaging with the new FSSAI requirements. Identify materials, records and business processes that need to change. Prepare a clear action plan to correct the identified gaps. 4. Checking Supplier Documents Review material declarations, technical data sheets and other documents provided by packaging suppliers. Confirm that the documents relate to the exact packaging material being purchased. Identify missing, incomplete or unclear information about the material’s composition. 5. Supporting Packaging Testing Help the business understand which food-contact and packaging tests may be relevant. Coordinate with suitable laboratories for the required testing. Organise conformity certificates, test reports and supporting records. 6. Improving FSSAI Records and Internal Controls Review the relevant FSSAI licence and existing compliance records. Prepare simple checklists for checking and approving packaging materials. Improve records so that each packaging material can be traced to its supplier, product and batch. 7. Providing Ongoing Regulatory Support Monitor new FSSAI packaging notifications, directions and clarifications. Review proposed packaging changes before they are used in commercial production. Help the business keep its compliance documents complete, current and properly organised. Professional support cannot replace correct supplier information or guarantee a regulatory outcome. However, it can help businesses understand their obligations, identify packaging risks, and maintain reliable evidence before starting commercial production. Pan masala manufacturers, importers, and brand owners may use Corpseed’s FSSAI compliance services for a document-based review of their packaging and implementation plan.
Subject
FSSAI Draft Amendment 2026 for School Food: Proposed Fat, Sugar and Salt Limits ExplainedSummary: The Food Safety and Standards Authority of India ( FSSAI ) has published a draft amendment to its rules on safe food and balanced diets for children in school. The FSSAI Draft Amendment 2026 proposes exact limits for deciding when a solid or liquid food is high in added fat, added sugar or salt. The draft was notified on 7 August 2026 and published in the Gazette of India on 10 August 2026. It is not a final amendment yet. FSSAI has invited objections and suggestions before it decides on the final wording. This means businesses should study the proposal and prepare, but they should not describe the proposed limits as a new law already in force. The proposal is short, but it may affect manufacturers, schools, canteens, caterers, distributors and sellers. Clear limits could make it easier to decide which products fall under the existing school food controls. Notification at a Glance Particular Verified details Issuing authority Food Safety and Standards Authority of India Document type Draft amendment regulations Proposed title Food Safety and Standards (Safe Food and Balanced Diets for Children in School) Amendment Regulations, 2026 File number SS-T0SP08(NOTI)/1/2026-Standard-FSSAI Notification date 7 August 2026 Gazette publication date 10 August 2026 Gazette details Extraordinary, Part III, Section 4, No. 490 Governing law Food Safety and Standards Act, 2006 Existing regulations Food Safety and Standards (Safe Food and Balanced Diets for Children in School) Regulations, 2020 Proposed change Insertion of Regulation 7 after Regulation 6 Main subject Limits for food high in added fat, added sugar or salt Present legal status Draft; not final Consultation period 60 days from the date Gazette copies are made available to the public Effective date Not applicable at the draft stage; not expressly specified for a final amendment The most important point is the document’s draft status. It creates a proposal and a public comment process. A final legal duty will depend on the text that FSSAI later notifies, if the proposal is finalised. The Regulatory Framework Role of FSSAI FSSAI is India’s main food regulator. It makes food standards and supervises food safety under the Food Safety and Standards Act, 2006. The draft states that FSSAI is acting with the previous approval of the Central Government. The legal power mentioned in the notification comes from Section 92 of the Act. Section 92(1) deals with the publication of draft regulations before final rules are made. Clause (v) of Section 92(2) supports regulations concerning conditions and guidelines relating to food business activities covered by the Act. FSSAI must first show the proposal to the public. Affected people and businesses can comment before FSSAI decides the final text. The 2020 School Food Regulations The proposal would amend the Food Safety and Standards (Safe Food and Balanced Diets for Children in School) Regulations, 2020. Those regulations create duties for school authorities and food business operators connected with school meals. The framework covers many types of schools and meals supplied through canteens, messes, hostel kitchens, vending machines and mid-day meal kitchens. It deals with licensing or registration, hygiene, menus, marketing, sale and monitoring. Why does New Regulation 7 Matter? The 2020 regulations refer to foods high in saturated fat, trans fat, added sugar or sodium. They restrict the sale or offer of such food on school premises or campuses. They also address advertising, marketing and sale to school children within 50 metres of the school gate in any direction. The 2020 text does not give these numerical tests. Proposed Regulation 7 would act as a measuring rule. It would not replace the wider framework. Scope and Applicability Businesses and Institutions That May Be Affected The draft does not create a separate list of covered businesses. Its reach comes from the 2020 regulations that it proposes to amend. The following groups may be affected if the amendment is finalised: School authorities that sell or provide meals themselves. Canteen, mess and hostel kitchen operators working inside school campuses. Caterers and food business operators supplying prepared school meals. Manufacturers whose packaged foods or drinks are sold, supplied, promoted or advertised in school settings. Distributors and vendors supplying products to schools. Sellers operating in places covered by the 2020 school food rules. Nutrition, quality, legal and compliance teams that review products for school channels. State food authorities and other notified public authorities involved in monitoring. Products That May Be Affected The proposal uses the broad term “food products.” It provides separate tests for solid and liquid products. It does not list brands or product categories. A product would need to be checked through its recipe, reliable nutrition data and, where needed, suitable testing. The 2020 schedule gives examples of foods for school menus, but it says the lists are illustrative. Products should not be classified only by their everyday name. Two biscuits, drinks or snacks can have different recipes. One may cross a limit while another may not. Questions the Draft Does Not Fully Answer The draft does not explain how to handle semi-solid foods, powders, concentrates or multi-part packs. It also gives no testing method, rounding rule, tolerance or method for separating added nutrients from naturally present nutrients. Businesses may raise these questions during consultation. What Has Changed Under the FSSAI Draft Amendment 2026? The proposal contains one main legal change. It would insert Regulation 7 after Regulation 6 of the 2020 regulations. Regulation 7 would define when certain foods are considered high in added fat, added sugar, or salt. Proposed High Added Fat Limit A solid food would be considered high in added fat when it contains more than 4.2 grams of added fat per 100 grams. A liquid food would be considered high in added fat when it contains more than 1.5 grams of added fat per 100 millilitres. “More than” matters. A solid product at exactly 4.2 g would not cross the limit under the plain wording; a value above it would. The same logic applies to every proposed limit. Proposed High Added Sugar Limit A solid food would be considered high in added sugar when it contains more than 3 grams of added sugar per 100 grams. A liquid food would be considered high in added sugar when it contains more than 2 grams of added sugar per 100 millilitres. Added sugar is not always the same as total sugar. Sugar may occur naturally in fruit or milk, while another amount is added during production. The notification does not say how to separate the two. Proposed High Salt Limit A solid food would be considered high in salt when it contains more than 0.625 grams of salt per 100 grams. A liquid food would be considered high in salt when it contains more than 0.175 grams of salt per 100 millilitres. Salt and sodium are related, but they are not the same measurement. The draft gives no conversion formula. Complete Proposed Threshold Table Nutrient Solid food is “high” when it contains Liquid food is “high” when it contains Added fat More than 4.2 g per 100 g More than 1.5 g per 100 ml Added sugar More than 3 g per 100 g More than 2 g per 100 ml Salt More than 0.625 g per 100 g More than 0.175 g per 100 ml These are product concentration limits, not daily intake or per-pack limits. Values must be expressed per 100 g or 100 ml. Important Difference Between “Added Fat” and “Total Fat” Total fat can include natural fat and fat added during production. A manufacturer may know the added amount from its recipe, but a buyer may see only total fat on the label. The final rule should state which records or tests can prove added fat. Important Difference Between “Salt” and “Sodium” The opening sentence of the proposed Regulation 7 refers to food products high in “added fat or added sugar or sodium.” The detailed tests below it uses the headings high fat, high sugar and high salt. The existing 2020 regulations also refer to saturated fat, trans fat, added sugar and sodium. This poses a question of interpretation. Salt and sodium are different, while fat refers to more than saturated or trans-fat. The FSSAI needs to be explicit about the relation between the proposed limits and the wording used. Implementation Schedule and Standards Current Status of the Procedure The amendment is in draft form. The FSSAI issued it to allow stakeholders to examine and comment on it. Neither 7 August 2026 nor 10 August 2026 is the effective date of the proposed limits. The 60-Day Consultation Period The notification allows 60 days from the date Gazette copies are made available to the public, but it does not state that date. Businesses should confirm the deadline. Comments may be sent to the Chief Executive Officer, FSSAI, FDA Bhawan, Kotla Road, New Delhi–110002, or regulation@fssai.gov.in. What Happens After Consultation? FSSAI will consider timely comments and may keep or revise the text. The draft gives no final-notification date, effective date, or transition period. Event Verified date or position Business action Draft notification 7 August 2026 Begin legal and product review Gazette publication 10 August 2026 Obtain and preserve the official text Public consultation 60 days from public availability of Gazette copies Confirm the deadline and submit evidence-based comments if needed Final notification Not expressly specified Monitor official FSSAI and Gazette sources Effective date Not expressly specified Do not assume; check the final text Why Was This Proposed? Giving the Existing Rules a Measurable Test The clearest practical reason is the need for a number-based test. A rule that says “high in sugar” can be difficult to apply if different people use different ideas of “high.” A fixed value gives manufacturers, schools, sellers and inspectors a common starting point. This does not remove every doubt, but it can reduce basic disagreement. A product above a clearly written limit can be identified more easily than a product judged only through a broad description. Alignment with the Dietary Guidelines for Indians 2024 The draft expressly links its proposed limits to the Dietary Guidelines for Indians 2024 issued by the Indian Council of Medical Research. The ICMR-National Institute of Nutrition guidelines encourage people to minimise foods high in fat, sugar and salt, and ultra-processed foods. The food system for school considers children, who acquire food behaviours when young. The proposal seems aimed at transforming food guidelines into measurable standards in this environment. It is a logical deduction from the documents but not an additional reason stated explicitly in the brief document. Supporting Safer and More Balanced School Food The 2020 regulations aim to improve the food environment in and around schools. They promote safe meals, balanced diets, clean food handling, suitable menus and regular monitoring. They also restrict certain marketing and sales practices for foods covered by the nutrient description. The proposed limits may help school authorities select products and review vendors. They may also help food businesses design products for school supply. Clearer classification can support more consistent decisions, provided FSSAI resolves the technical wording issues. Impact on Businesses 1. Food Manufacturers Manufacturers may need to map products sold through school channels and review recipes, added ingredients and nutrition data. Products above a final limit may lose access to some school channels. The draft does not order a recall, packaging change or nationwide ban. 2. School Canteens, Caterers and Meal Providers School food operators may need product specifications or recipe declarations because total values may not prove added nutrients. Canteens may also review menus and update approved product lists when recipes or suppliers change. 3. Distributors and Sellers Distributors may need to separate products and share current specifications with schools. A distributor making a product claim should keep reliable support for it. 4. MSMEs and Startups Small businesses may face higher relative costs for recipe review, nutrition analysis and reformulation. Yet a startup that creates suitable products may find buyers if it can meet quality, price and supply needs. 5. Schools and School Authorities Schools may gain clearer vendor criteria but face more checking and record-keeping work. The proposal does not remove the wider duties on safe handling, suitable licensing, balanced menus and monitoring. What Businesses Should Do Before Finalisation? Because the amendment is a draft, the right approach is preparation, not a claim of completed legal compliance. Step 1: Check Applicability Identify whether products are sold, supplied, promoted, or advertised through school-related channels covered by the 2020 framework. Record the schools, caterers, distributors, and vendors involved. Step 2: Create a Product List List the solid and liquid products, recipe version, supplier, nutrition values, and last testing date. Step 3: Review Added Nutrients Check added fat, added sugar, and salt in every recipe. Record any differences between recipe and label measures. Step 4: Compare Values with the Draft Limits Express values per 100 g or 100 ml. Mark products above, equal to, and below each limit. Review borderline products carefully. Step 5: Check the Evidence Record whether each value comes from a recipe, supplier declaration, calculation or test. Match the evidence to the correct product version. Step 6: Assess Reformulation Study whether a product can be reformulated without harming safety, quality or shelf life. Involve food technology and quality teams. Step 7: Review Contracts and Product Claims Check school-channel contracts. Do not claim compliance with a draft standard without a sound basis. Step 8: Submit Comments Where Needed Comments to FSSAI should identify the clause, explain the problem, provide evidence, and suggest workable wording. Issues may include nutrient terms, tests, tolerance, and semi-solid foods. Step 9: Monitor the Final Notification Assign a team member to watch official updates and compare the final amendment with the draft. Benefits for Businesses Clearer Product Decisions: Numerical limits can reduce uncertainty. Businesses can use one reference point when screening products for school supply. This may improve communication between manufacturers, distributors, schools and regulators. Better Product Development: The proposal can guide food businesses that want to create products for children. Research and development teams can consider the limits at the recipe stage instead of discovering a problem after launch. Stronger Procurement Records: Schools and caterers can ask vendors for data linked to fixed criteria. This can make product selection more consistent and easier to review during an inspection. Consumer Trust: Parents often want clear information about food offered to children. Businesses that maintain sound evidence and communicate honestly may build stronger trust. This is a possible commercial benefit, not a guaranteed result. Early Preparation: Businesses that study the draft now will have more time to identify data gaps and technical problems. Early review can reduce rushed decisions after a final notification. Challenges and Cost Implications Testing and Data Costs Businesses may need better recipe calculations, supplier information or laboratory support. The exact cost is not stated in the draft and will differ by product and business. Reformulation Work Reducing fat, sugar or salt can change taste, texture, preservation and customer acceptance. A new recipe may require trials, stability checks and updated production controls. Unclear Technical Terms The salt-sodium and added-fat issues can lead to different results. Semi-solid foods and products prepared with water may also be treated differently by different parties unless FSSAI gives clear rules. Burden on Small Businesses MSMEs may not have in-house nutrition or regulatory teams. They may depend on outside experts and laboratories. A clear transition period in the final amendment could help such businesses prepare. Is This a Right Decision or an Additional Burden? Arguments Supporting the Proposal The proposal supports a valid public-interest goal: making the school food environment easier to manage. Clear numbers can help identify products consistently. They can also encourage food businesses to improve recipes and give schools a better tool for procurement. Children are the main group protected by the 2020 regulations. A simple classification system can make the rules easier for school staff and parents to understand. The link with the Dietary Guidelines for Indians 2024 also gives the proposal a current nutrition-policy basis. Additional Burden on Businesses The weight is genuine. Businesses can require product mapping, formula checking, nutritional assessment, record-keeping, and reformulation of their products. Small businesses can suffer relatively higher costs due to their smaller size. There are still some outstanding issues that the draft fails to address. The business must not be subjected to any enforcement dilemma where one document calls for sodium and the other for salt. There must be no confusion between added fat and saturated fat without legal clarification. Is the Timeline Practical? The draft gives a 60-day consultation period but no implementation timeline for a final amendment. It is therefore too early to decide whether the compliance timeline is practical. A final rule should clearly state its commencement date and allow reasonable preparation where product changes are required. Balanced Assessment The policy approach makes sense insofar as there could be tangible boundaries that will help ensure school foods are safer and more uniform decisions are made. But the policy cannot be finalised until it has better definitions and a framework for measuring that aligns with the terminology of the nutrients from 2020. Ideally, what is needed is a well-defined final regulation with a reasonable transition period. This will help safeguard the interests of children and at the same time offer legitimate businesses a reasonable chance to prove themselves. Business Opportunities Created Healthier Food and Beverage Development Manufacturers can develop products with lower added fat, added sugar and salt for school and family markets. Success will still depend on safety, taste, price and reliable supply. Product Reformulation Services Food technologists and ingredient specialists may support recipe changes. Businesses may need help reducing nutrients while protecting texture, shelf life and product quality. Nutrition Testing and Data Services Demand may grow for reliable nutrition analysis, recipe calculations and product specification review. Laboratories and technical consultants must avoid claiming that a test proves legal compliance when the final method has not been specified. School Procurement and Menu Support Schools may need help screening suppliers, planning menus and keeping product records. Nutritionists, dietitians and food safety professionals may support this work within the legal framework. Compliance Technology Digital tools can help manufacturers and institutional buyers track recipes, test reports, supplier declarations and product approvals. Such systems are useful only when the underlying data is correct. Regulatory Advisory Services Businesses may seek support to understand applicability, prepare consultation comments and build a readiness plan. Advice should be based on the exact business model and product, not a generic checklist. Risks to Avoid Do not call the draft a final or implemented regulation. Do not assume that 10 August 2026 is the effective date. Do not treat added sugar as total sugar without a legal and technical basis. Do not treat salt and sodium as the same number. Do not assume every packaged food is automatically banned in schools. Do not use a product name as proof of its nutrient content. Do not rely on an old test report after a recipe or supplier change. Do not promise that a product complies before checking the final notification. Do not ignore the wider duties contained in the 2020 school food regulations. How can Corpseed help? Corpseed can support food businesses, schools and institutional suppliers that need to understand the draft and prepare for possible changes. Its FSSAI compliance services should be matched to the client’s actual product, role and regulatory need. Regulatory Applicability Assessment- Corpseed can review the business model, product category and school-related sales channel to identify which parts of the framework may apply. Product Compliance Gap Review- The team can help organise product data, compare available values with the proposed thresholds and record points that need technical confirmation. Testing and Technical Coordination- Where suitable, Corpseed can assist with coordination between the business and qualified food-testing or technical service providers. Testing scope must be selected carefully because the draft does not specify every method. FSSAI Registration and Licence Support- Food business operators that require registration or licensing under the wider FSSAI framework can receive application and documentation support. The correct requirement depends on the business activity and eligibility conditions. Labelling and Documentation Review- Corpseed can support a structured review of product labels, specifications, supplier records and compliance documents. It cannot replace missing scientific evidence with a declaration. Consultation Response Support- Businesses with technical or legal concerns can receive help preparing clear objections or suggestions for FSSAI. The submission should be evidence-based and filed within the verified consultation period. Ongoing Regulatory Monitoring- Corpseed can help businesses track the final notification and update the compliance plan when the legal position changes. Corpseed’s Core Message Understand Before Acting The FSSAI Draft Amendment 2026 is a proposal, but it deserves early attention. Businesses should first understand whether their products and school channels are connected with the 2020 regulations. Prepare Reliable Product Data Good decisions need good records. Manufacturers and suppliers should know what is added to each product, how the nutrition value was calculated, and which product version the data supports. Use the Consultation Period Well If the draft wording creates a genuine problem, businesses should explain it to FSSAI with facts. Waiting until the final regulation may remove the chance to improve unclear wording. Seek Product-Specific Support Generic advice cannot answer every question about a recipe, label or supply chain. A product-specific assessment can help businesses focus on the issues that matter. Food manufacturers, school suppliers, caterers and institutional vendors can contact Corpseed for an applicability review and practical FSSAI regulatory compliance plan. Professional support should improve decision-making, but it cannot guarantee government approval or a particular regulatory outcome. Key Takeaways FSSAI has proposed a new Regulation 7 under the 2020 school food regulations. The proposal is a draft and is not yet a final enforceable amendment. It introduces separate limits for solid and liquid foods. The limits cover added fat, added sugar and salt in the detailed text. The draft invites objections and suggestions during a 60-day consultation period. Businesses should confirm the actual submission deadline instead of assuming it. Manufacturers and school suppliers should review product recipes and nutrition evidence. FSSAI should clarify the differences between salt and sodium and between added fat and the fat terms used in the existing regulations. Early review can help businesses prepare comments, identify data gaps and plan possible reformulation. FSSAI Draft Amendment 2026 for School Food: Proposed Fat, Sugar and Salt Limits Explained
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FSSAI LC-HRMS Specifications 2026: Complete Compliance UpdateSummary: The Food Safety and Standards Authority of India (FSSAI) issued the FSSAI LC-HRMS specifications 2026. The specifications cover Liquid Chromatography-High Resolution Mass Spectrometry systems that are used for advanced food, feed, and water testing. The notice provides details on the LC-QToF and LC-Q-Orbitrap systems. It covers the instrument, chromatography system, software, databases, workstations, gas supply, power backup, accessories, testing evidence, training, warranty, and after-sales support. The most important point is its legal nature. FSSAI has clearly stated that these specifications are purely indicative. They are not standard tender specifications or mandatory procurement conditions. Procuring agencies may change any parameter after assessing their operational needs. This update pertains to procurement of laboratories, equipment manufacturers, authorized suppliers, technical evaluation committee, and bid teams. This update is not meant for every food business or every food testing laboratory to buy an LC-HRMS system. The FSSAI notice clearly states that the specification mentioned is only indicative. Background of the LC-HRMS Procurement Framework The FSSAI is a scientific authority established under the Food Safety and Standards Act, 2006. Its functions are related to food safety standards, testing systems, laboratory capacity, and scientific assessment. Liquid Chromatography-High Resolution Mass Spectrometry is used to separate, detect, and identify chemicals in complex samples. It can detect very small quantities of contaminants and generate accurate information about their molecular mass. An LC-HRMS laboratory may use the technology for: Pesticide residue analysis. Antibiotic and veterinary drug testing. Pharmaceuticals and personal care product screening. Water contaminant analysis. Food and feed contaminant testing. Metabolomics and lipidomics. Honey adulteration and floral-origin assessment. Targeted measurement of known compounds. Untargeted screening of unknown compounds. The instrument cannot operate effectively as a standalone machine. It needs chromatography, software, spectral libraries, data-processing systems, gases, uninterrupted power supply, qualified staff, and ongoing maintenance. FSSAI's annexure addresses these related requirements as a single package. Earlier regulatory position The notice does not identify an earlier LC-HRMS specification that has been amended, withdrawn, or replaced. It also does not provide an old-versus-new comparison. The correct interpretation is that FSSAI has finalised a suggestive technical reference. The source does not support a claim that an earlier statutory requirement has changed. Why Has FSSAI Issued These Specifications? The express purpose is to provide finalised suggestive specifications for LC-HRMS equipment. FSSAI does not give a detailed policy explanation beyond this point. In the case of procurement-related problems, this is very useful because it requires evaluating laboratory devices across many criteria. It means that comparing their mass resolution or sensitivity alone will not be enough. The specifications place attention on: The analytical work that the system must perform. Measurable instrument performance. Software and database capabilities. Laboratory infrastructure and utilities. Performance evidence from the vendor. Staff training and method-development support. Warranty and maintenance coverage. Post-warranty service and spare-part availability. This procurement context is a reasonable business interpretation. It should not be presented as a separate legal objective unless FSSAI states it in another official document. What Has Been Introduced? FSSAI has introduced an end-to-end reference containing 26 grouped requirement areas. New requirement area Who it concerns Main requirement Business meaning Analytical applications Laboratories and vendors Support targeted, untargeted and authentication workflows The complete solution must meet the laboratory’s intended work UHPLC system Equipment suppliers Meet proposed flow, pressure, accuracy and autosampler conditions Chromatography performance becomes part of bid evaluation Mass spectrometer Manufacturers and technical committees Meet proposed flow, pressure, accuracy and autosampler conditions Vendors need measurable proof of instrument performance Software and databases Vendors and laboratory analysts Supply licensed software, libraries and processing workflows Software scope cannot be treated as an optional extra Laboratory utilities Suppliers and facility teams Supply vacuum, gas and power backup systems Site infrastructure becomes part of procurement planning Performance evidence Bid teams Submit application notes, curves, data sheets and user evidence Claims must be supported by records Training and validation Vendors and laboratory personnel Provide basic and advanced training Knowledge transfer becomes a supply obligation Warranty and service Vendors and procurement teams Provide multi-year support and maintenance Lifecycle cost and service capacity affect evaluation Accessories and consumables Suppliers Supply listed supporting items and initial consumables The package is expected to be ready for installation and use Requirement-Wise Analysis of the LC-HRMS Specifications Application requirements The proposed system must be a high-resolution accurate-mass LC-QToF or LC-Q-Orbitrap system. All software and accessories needed for its successful operation should form part of the solution. The system is expected to support four broad workflows. Contaminant screening and measurement The equipment should perform simultaneous untargeted screening and quantification of chemical contaminants in food, feed and water. The notice specifically refers to: Antibiotics. Veterinary drugs. Pharmaceuticals and Personal Care Products. Water contaminants. Pesticide residues. Other small molecules. The solution should collect full-scan and tandem mass spectrometry data. It must also include databases for accurate-mass and MS/MS spectral matching. Targeted analysis The platform should support targeted measurement via high-resolution Multiple Reaction Monitoring or an equivalent data acquisition mode. Targeted analysis looks for selected compounds. It differs from untargeted screening, which searches more broadly for known and unknown chemicals. Metabolomics and lipidomics Metabolomics studies small molecules produced during biological processes. Lipidomics focuses on fats and related molecules. The software should support: Peak alignment and peak picking. Grouping of adducts. Metabolite annotation. Lipid annotation. Expandable databases. Pathway mapping. Multivariate statistics. Biomarker selection. Honey Authentication The proposed system is expected to authenticate honey, oligosaccharides, adulteration, and floral characteristics. Vendors must submit data connected with honey authentication as part of the technical evidence. UHPLC System Requirements Ultra-High Performance Liquid Chromatography separates chemicals before they enter the mass spectrometer. The UHPLC and mass spectrometer should work together through the supplied operating software. Parameter Indicative requirement Practical significance Pump Binary high-pressure pump with built-in degasser Supports controlled solvent delivery Operating flow 0.1 to 2.000 mL/min or better Covers the proposed analytical flow range Operating pressure 15,000 psi or better at 1 mL/min or better Supports high-pressure separation Flow accuracy ±1% Helps maintain repeatable retention conditions Degasser Four-channel vacuum degasser Removes dissolved gases from solvents Flow precision ≤0.07% Relative Standard Deviation or better Supports repeatable chromatography Autosampler Refrigerated Helps protect prepared samples Sample capacity At least 96 vials of 1.5-2 mL and support for 96/384-well plates Supports batch testing Injection range 0.1-100 µL Allows different sample volumes Injection accuracy ±1.0% Supports repeatable injection Carryover Below 0.004% for caffeine/chlorhexidine or better Reduces contamination between samples Column oven At least two columns with software-controlled switching Supports multiple analytical methods Oven range Ambient temperature to 85°C or better Allows temperature-controlled separation C18 columns Five columns, 2.1 × 100 mm, sub-2 µm or equivalent Supports specified residue and research workflows Mass Spectrometer Requirements Ion sources The system should include dedicated Electrospray Ionisation and Atmospheric Pressure Chemical Ionisation sources. The sources should: Cover the proposed application areas. Be easy for the operator to interchange. Allow automatic probe detection by the instrument and software. Permit source cleaning without disturbing the vacuum. Handle flow rates from 1-1,000 µL/min or better without splitting. Provide a desolvation temperature of at least 400 °C. Mass analyser and performance parameters Parameter Indicative requirement Practical significance Mass analyser QToF or Q-Orbitrap Allows high-resolution accurate-mass analysis Quadrupole mass range At least 50-2,200 atomic mass units or better Covers the stated mass range Resolution 70,000 or higher, or 60,000 or higher with ion mobility Supports separation of closely related ions QToF acquisition speed At least 40 MS/MS spectra per second or better Supports fast data collection Orbitrap scan speed At least 22 Hz or better Sets the proposed Orbitrap speed Mass accuracy Stated as “minimum 1 PPM” in MS and MS/MS modes Supports accurate mass assignment Dynamic range Five orders or better Supports signals across different concentration levels Screening sensitivity Sub-ppb or femtomole levels, with SDL below 5 ppb or better Supports trace contaminant screening Application-note method LOQ Below 5 ppb for pesticide or antibiotic residues Requires application-level evidence Parts per billion measures very small concentrations. A Limit of Quantification is the lowest level that a method can measure with acceptable performance. A Screening Detection Limit indicates whether screening can reliably detect an analyte at a specified level. Mass-accuracy evidence A brochure statement is not enough. The vendor must provide documents showing mass accuracy over 24 hours or more of consecutive on-column injections. The purpose is to demonstrate stability over longer metabolomics cohort analyses. The final tender should define the test conditions so that all vendors are assessed on the same basis. Sensitivity evidence Vendors must state the sensitivity achieved in Data Independent Acquisition and MS/MS modes. They must also provide and demonstrate: Application notes showing pesticide or antibiotic residue analysis below a 5 ppb method LOQ. Calibration curves for relevant contaminants. Data from DIA and high-resolution MRM modes. The source does not name the analytes, matrices, number of injections, or statistical acceptance rules for this demonstration. The procuring agency should define these points in its final tender. Data-Acquisition Requirements The system should support several data-acquisition modes. Variable-window acquisition in the first quadrupole for Data Independent Acquisition. Full-scan mass spectra. Selected Ion Monitoring for target compounds. MRM, PRM, SRM or similar reaction-monitoring datasets. Timed SIM for scheduled target-compound acquisition. Timed MS/MS for scheduled fragment-spectrum acquisition. Dynamic exclusion of selected ions while collecting MS/MS spectra for less-abundant precursor ions. These modes allow the same platform to support broad screening, confirmatory identification, and targeted measurement. Software, Databases and Workstation Requirements Licensing and instrument control The notice calls for original and licensed universal perpetual software. Free upgrades should be provided for up to five years. All hardware and software needed for instrument control, data acquisition and processing should be included. The operating software should control the complete UHPLC-HRMS system. It should also provide: System-suitability calculations. User-designed report formats. Background subtraction. Elemental-composition analysis. Component differential analysis. Targeted and untargeted screening. Compound and library searches. Fragment prediction. Quantitative and qualitative analysis. Acquisition and processing computers System Proposed configuration Acquisition computer One high-performance computer with factory-recommended processor and operating system Acquisition memory At least 32 GB RAM Acquisition storage At least 2 TB Acquisition display 24-inch high-resolution monitor Processing computer One computer with Intel i7 processor and Windows 10 Professional Processing memory 64 GB RAM Processing storage 10 TB Processing display 28-inch high-resolution monitor Additional hardware Wireless keyboards, mice and laser printer with printing, copying and scanning Office software Microsoft Office Professional Application software and spectral databases The proposed software should include current high-resolution mass spectral libraries and fragment information for pesticides, antibiotics, and small molecules. Required functions include: Automatic searching of free and commercial libraries. Automatic searching of user-created libraries. User-editable target databases. Empirical-formula generation from mass spectra. Fragment prediction for metabolite identification. Targeted and untargeted metabolomics. Lipidomics analysis. Pathway-based target-list generation. Selection of MS or MS/MS ions for quantification. Qualitative, quantitative and characterisation workflows. The solution should contain ready-to-use acquisition and processing methods for at least 300 contaminants. It should include predefined columns, quality-control samples and settings so the methods can work after installation. Advanced analysis and reporting The software should support: Grouping isotopes, charge states, adducts and fragments into one feature. Rapid recognition of known compounds. Annotation-quality scoring. Principal Component Analysis. Analysis of Variance. T-tests. Hierarchical Cluster Analysis. Structure searches using elemental composition. In silico fragmentation. Client-server processing. Remote access to data. Export to third-party statistical and pathway tools. Combination of data from different mass analysers. False-discovery discrimination. Grouping of environmental pollutants. Biological interpretation of identified metabolites. Vacuum, Gas and Power Requirements The package includes the utilities needed to operate the instrument. Vacuum system The proposed vacuum system should be oil-less, efficient and low-noise. It should include an automatic vacuum lock and safety features that protect the instrument. All accessories required for proper vacuum operation must be included in the supply. Nitrogen and other gases A nitrogen generator should be included with: Minimum nitrogen purity of 99.9%. Adequate flow for the proposed HRMS instrument. Compressor, gas regulators and filters. Required connectors and tubing. If another gas is needed, such as collision gas, the supplier should disclose it. At least two cylinders, regulators and connectors should then be supplied. The gas arrangement should use as little laboratory space as possible. It should also maintain laboratory safety and access to work. The vendor must provide an affirmation for this condition. Gas-cylinder documents The following documents must be supplied with the cylinders: Manufacturer certificate. Hydrostatic test certificate. Chief Controller of Explosives, Nagpur gas-filling approval certificate. Purity certificate. Uninterrupted power supply The package should contain an online 20 kVA or better Uninterrupted Power Supply. It must provide at least two hours of backup for: The LC-HRMS system. The vacuum pump. The nitrogen generator. The battery should be placed in a suitable rack. Required power connections and accessories must also be supplied. Warranty, Service and Post-Warranty Requirements Five-year system warranty The system and supporting accessories should carry a minimum five-year warranty. The period starts after completion of Installation Qualification, Operational Qualification and Performance Qualification. These three qualification stages confirm that the equipment has been installed correctly, operates properly, and performs the required applications. The warranty should cover: LC-HRMS hardware. Nitrogen generator and compressor. Vacuum system. UPS and batteries. Computers and printer. Gas cylinders and accessories. Software. Wear-and-tear consumables, except columns and sample-preparation items. Training and application support. Applicable software upgrades. Ten-year component warranty The heated ESI/APCI ion source and detector should have a ten-year warranty. The final tender should clearly define which source and detector components are covered. This can prevent later disputes about excluded components. Breakdown response and preventive maintenance A vendor should attend to service calls within 48 hours during the five-year warranty period. Other parts of the annexure use a 24-48-hour service period. The specifications also require: Immediate servicing after a breakdown. Maximum stated downtime of 24-48 hours. Warranty extension if a breakdown is not attended within the stated period. At least two preventive-maintenance visits each year. Preventive-maintenance kits when required. The final contract should define when the response period begins, what constitutes attendance, and how a warranty extension will be calculated. After-sales and post-warranty support The supplier should have an application laboratory in India or abroad. It should also have trained service engineers in nearby metropolitan areas. Post-warranty requirements include: Unlimited breakdown visits by service or application engineers. Free troubleshooting training when required. Application and method-development support. Supply of spares, accessories, consumables and service for at least ten years. Separate AMC and CMC quotations for three years after warranty. Separate terms and price breakup for AMC and CMC. Use of the three-year AMC price while finalising the lowest evaluated bidder. FSSAI does not state any AMC or CMC amount. Each supplier must quote the applicable price under the final tender. Demonstration, Training and Validation Requirements The supplier is responsible for training laboratory personnel at the supplier's site or installation site. The package should provide: Basic training for at least ten working days after installation. Method development support during the warranty and AMC periods. One general entry-level workshop at the user site. One advanced workshop at the user site. Training on experiments and data analysis. Instrument and application troubleshooting. Support for developing and validating at least one priority parameter selected by the laboratory. On-site performance validation against laboratory or regulatory protocols. The final tender should specify the number of trainees, course content, training records and expected competency level. Accessories and Initial Consumables Item Indicative quantity or requirement HPLC and MS preventive-maintenance kits Enough for the warranty period Single-channel micropipettes, 50-1,000 µL 4 Single-channel micropipettes, 10-100 µL 4 Single-channel micropipettes, 1,000-5,000 µL 2 Capillary tubes, cones, desolvation lines or similar accessories 10 Calibration and tuning standards All standards needed for MS and HPLC calibration Clear vials, 1.5/2.0 mL 1,000 Amber vials, 1.5/2.0 mL 2,000 13 mm syringe PTFE filters 1,000; pore size appears as “022µ” in the source Standard maintenance toolkit Required Solvent filtration unit with pump Required Mobile-phase bottles, 500 mL 12 Mobile-phase bottles, 1,000 mL 12, followed by another reference to 12 one-litre bottles Low-volume 500 µL recovery vials 1,000 QuEChERS pesticide-extraction kits 1,000 Heavy-duty multi-tube vortex mixer 1 Rack for 50 × 1.5/2 mL tubes 2 or more Rack for 50 × 15 mL tubes 2 or more Rack for 15 × 50 mL tubes 6 or more Horizontal QuEChERS rack for 9 × 50 mL tubes 2 or more The proposed vortex mixer should have: A speed range of 500-2,500 rpm or better. A timer from one minute to 99 hours and 59 minutes or better. An orbit of 3.0 mm or better. A 100-240 V and 50-60 Hz electrical range. An operating range from +5°C to +50°C or better. Support for horizontal and vertical mixing. Scope and Applicability The notice applies as a technical reference for the procurement of LC-HRMS equipment. Its practical effect differs across stakeholders. Stakeholder Covered? Relevant condition Main responsibility Procuring agencies Directly relevant Specifications are indicative Assess operational needs and prepare the final tender Food testing laboratories Directly relevant when procuring equipment System must suit the laboratory’s work Define applications, methods and site requirements Equipment manufacturers Commercially relevant Performance claims need evidence Supply verified technical information Authorised suppliers and distributors Commercially relevant Complete package and service support may be required Coordinate hardware, software, warranty and local support Technical evaluation committees Directly relevant when formed Agencies may form their own committee Review technology and finalise fair tender conditions Food manufacturers and exporters Indirectly affected No purchase duty is created May use laboratories operating this technology General food business operators Not directly covered No licensing or registration change No new action is created by this notice alone Exclusions and limitations The notice does not favour or restrict any manufacturer, technology, supplier or country of origin. It also does not create: A mandatory LC-HRMS purchase requirement. A food business registration process. A laboratory approval procedure. A certification program for the equipment. A mandatory testing schedule. A new food product specification. A compliance date. A transition period. A non-compliance penalty. FSSAI also states that it will not be liable for procurement or contractual issues arising from purchases made by other agencies. Indicative Procurement Requirements The responsibilities in the annexure apply only when a procuring agency adopts them in a tender. Procuring agencies Procuring bodies should independently assess their operational needs. They may modify any specification before issuing the tender. They may also: Form a Technical Evaluation Committee. Consult subject-matter experts. Accept equivalent or better performance. Modify accessory quantities. Change software and workstation requirements. Define site-specific service conditions. Set their own technical evaluation method. Vendors and suppliers Where the final tender adopts the FSSAI benchmark, vendors may need to: Offer a complete LC-HRMS solution. Submit a clause-wise compliance sheet. Support every claim with technical records. Demonstrate residue-testing performance. Provide training and on-site validation. Supply the listed utilities and accessories. Meet warranty and service commitments. Quote post-warranty AMC and CMC prices separately. These are indicative tender responsibilities. They are not general statutory duties imposed on every equipment vendor. Effective Date and Compliance Timeline It does not state a separate effective date, procurement deadline or transition period. The annexure contains several contract-related periods, but these are not statutory compliance deadlines: Software upgrades for up to five years. Minimum five-year system warranty. Ten-year warranty for the heated ion source and detector. Service attendance within 48 hours, with other references to 24-48 hours. At least two preventive-maintenance visits each year. Availability of spares and service for at least ten years. Three years of AMC and CMC quotations after warranty. Basic training for at least ten working days. These periods begin or become binding only when incorporated into an actual tender and contract. How the Notice Differs From the Earlier Position? The attached notice is not described as an amendment or corrigendum. It does not identify an earlier LC-HRMS technical specification or show any parameter that has been substituted. The verified change is the availability of a finalised FSSAI reference for LC-HRMS procurement. No verified old-versus-new technical comparison can be prepared from this notice alone. A procuring agency should therefore treat the document as a new reference point. It should not assume that the notice automatically changes an existing tender or contract. Technical Documentation Required From Vendors Document or record Status in annexure Purpose Responsible party Stage Mass-accuracy records for 24 hours or more Required Show long-run stability Vendor Technical evaluation Application notes below 5 ppb method LOQ Required and demonstrated Support pesticide and antibiotic performance Vendor Evaluation or demonstration Calibration curves Required Support DIA and high-resolution MRM claims Vendor Technical evaluation Service-response affirmation on stamp paper Required Confirm service attendance Vendor Bid submission User reference letter Minimum one Confirm performance and service experience Vendor Bid submission Gas-layout affirmation Required Confirm suitable gas arrangement Vendor Bid submission Cylinder manufacturer certificate Required Verify cylinder source Supplier Delivery Hydrostatic test certificate Required Verify cylinder testing Supplier Delivery CCOE gas-filling approval certificate Required Support gas-filling approval Supplier Delivery Purity certificate Required Verify gas purity Supplier Delivery Proof-of-performance records Required with compliance sheet Support technical claims Vendor Bid submission Original and authenticated data sheets Required Verify offered specifications Vendor Bid submission Honey-authentication data Required Support the proposed application Vendor Technical evaluation Indian user list Required Show installations in India Vendor Bid submission Performance testimonials Minimum two from reputed users Support instrument performance Vendor Bid submission AMC and CMC price breakup Required separately Assess post-warranty cost Vendor Commercial submission One user reference letter and two performance references are needed from the source. It does not make clear if the same user can support both requirements. This needs to be made clear in the final tender. Testing and Performance Validation Performance verification testing must focus on actual performance, not only on brochure specifications. It requires validation of: Mass accuracy in successive injections for 24 hours or more. Pesticide or antibiotic residue analysis below a 5 ppb method LOQ. Sensitivity in DIA and MS/MS modes. Calibration curves in DIA and high-resolution MRM modes. Honey-authentication capability. Ready-to-use workflows for at least 300 contaminants. Onsite validation against laboratory or regulatory protocols. Proof-of-performance documents supporting the compliance sheet. The notice does not provide a complete testing protocol. Procuring agencies should define the sample matrix, analytes, concentration levels, number of replicates and acceptance rules. Impact on Businesses and Stakeholders Procuring laboratories Laboratories receive a detailed starting point for tender preparation. The benchmark may reduce the chance of overlooking software, gas systems, accessories or long-term service. The laboratory must still decide: Which contaminants it plans to test. Required reporting limits and sample throughput. Whether metabolomics and lipidomics are needed. Which software modules are essential. Whether the proposed accessories match existing facilities. How competing technologies will be compared. Equipment manufacturers Manufacturers may need to show both technical performance and application readiness. A system that meets headline hardware values may still fall short on software, databases, training or service. Long warranty periods may also require approval from the original equipment manufacturer rather than only a local distributor. Authorised suppliers and distributors Suppliers may need to coordinate many parts of the package. These include hardware, software licences, gas systems, UPS equipment, accessories, training and post-warranty support. The bid file must clearly identify which organisation is responsible for each commitment. Technical evaluation committees A technical committee must protect both performance and fair competition. The FSSAI notice allows equivalent or better specifications and rejects preference for a particular manufacturer or country. Evaluation criteria should thus be based on measurable outcomes rather than on the product's branding. Food Manufacturers and Exporters The notice places no direct obligation on food manufacturers to provide equipment or testing services. It is an indirect obligation. Improved LC-HRMS capacity may support access to advanced residue analysis, contaminant screening, product investigation and authenticity testing. Any actual testing duty must arise from a separate law, standard, buyer requirement or contract. MSME suppliers Smaller suppliers may face difficulty meeting long warranty periods, India-based service expectations, application support and large accessory requirements. The burden may be reduced through clear rules on consortium, authorisation, and subcontracting in the final tender. The FSSAI notice does not prescribe such arrangements. Cost and Operational Implications The notice fails to provide any figure for the equipment cost, procurement cost, or budget approval. Cost factors include: LC-QToF or LC-Q-Orbitrap unit. UHPLC system and columns. Nitrogen generator and gas accessories. Online 20 kVA UPS and batteries. Acquisition and processing computers. Licensed software and spectral libraries. Initial standards, reagents and consumables. Installation and qualification. Training and method development. Laboratory modifications. Ongoing costs may be affected by: Annual and comprehensive maintenance. Software subscriptions not covered by the perpetual licence. Database renewals. Replacement parts and consumables. Gas and electricity use. Data storage and backups. Preventive maintenance. Staff training. Method validation. A low equipment price may not represent the lowest lifecycle cost. The final tender should state how AMC, CMC, software, and utility costs will be evaluated. Business Benefits of the FSSAI Benchmark A properly adapted procurement benchmark can offer several practical benefits. Complete package planning: It covers the instrument, software, utilities, and accessories. Improved performance evaluation: Accuracy, speed, and sensitivity can be evaluated through their stated numbers. Improved control of evidence: Claims need to be supported by application data and technical documentation. Application preparedness: Since the emphasis is on workflow, there is a lower likelihood of purchasing equipment without a method in place. Staff training and troubleshooting: These are included in the suggested package. Longer service visibility: Warranty, preventive maintenance, and post-warranty support are considered early. Technology neutrality: Procuring agencies may accept equivalent solutions that meet their actual needs. Improved procurement planning: Lifecycle requirements can be reviewed before contract award. The benefit depends on careful adaptation. Using every clause without review may create unnecessary expense or limit competition. Technical and Operational Challenges Comparing different instrument technologies QToF and Q-Orbitrap systems may use different designs and performance-reporting methods. Resolution and scan speed cannot be directly compared using a single number. The tender should state the measurement conditions, the reference mass, and the required performance for the intended acquisition mode. Proving sensitivity The document uses sub-ppb, femtomole, screening detection limit and method LOQ concepts. These measures are not identical. Without a common demonstration plan, suppliers may submit results from different samples, compounds or test conditions. Software scope and licensing A perpetual software licence may not include every database, cloud service or future module. The tender should identify: Included licences. Number of users. Database subscriptions. Remote-access rights. Upgrade costs. Data-export rights. Cybersecurity and backup requirements. Service coverage The source uses both 48 hours and 24-48 hours. It also refers to trained engineers in nearby metropolitan areas without defining "nearby." Remote and difficult locations may need a separate service plan. Long-term commitments A five-year warranty, a ten-year component warranty, and a ten-year spare-parts support promise can pose commercial risk. The procuring agency should verify that the bidder has written support from the original manufacturer. Procurement and Bid Risks The notice does not create statutory penalties. The main risks are technical, operational and contractual. An unsuitable specification may lead to the purchase of an instrument that cannot perform the required applications. Ambiguous performance tests may lead to disagreements during technical evaluation. A lack of documentation may pose a problem if the final tender includes documentation requirements. Ambiguous licensing provisions may lead to future software costs. Insufficient gas or power supply might delay the installation process. Insufficient local service availability might increase downtime. Ambiguous warranty exclusions may lead to disputes over repairs. The brand-specific provisions may limit competition despite the notice's technology-neutral wording. Incorrect treatment of indicative provisions as statutory duties may lead to unnecessary spending. Whether a bid deviation causes rejection will depend on the final tender. The FSSAI notice itself does not create a bid-rejection rule. LC-HRMS Tender Readiness Checklist The following checklist converts source-based requirements into a tender review tool. The intended food, feed or water testing applications have been identified. The selected LC-QToF or LC-Q-Orbitrap configuration meets the stated performance needs. UHPLC flow, pressure, injection, and carryover parameters have been checked. Mass range, resolution, acquisition speed, accuracy, and sensitivity have been mapped. The 24-hour mass-accuracy evidence is available. Application notes and calibration curves below 5 ppb are available. Honey-authentication data has been included where required. Software licences, libraries and databases have been listed. Workstation and storage configurations have been verified. Gas, vacuum, and UPS systems constitute part of the supply. There are cylinder certificates and gas purity documents. Amounts of accessories have been verified. Training and on-site validation arrangements are confirmed. Warranty, response time, and maintenance arrangements are outlined. Costs of AMC and CMC are listed separately. There are customer testimonials and verified data sheets. All variations from the final tender are noted. Recommended Procurement Practices These are the recommendations, not added legal duties. Define the laboratory's applications before choosing technical specifications. Utilize a clause-wise compliance matrix in each bidding. Demand performance testing of competing systems as a common practice. Allow the use of equivalent technology with verifiable output. Evaluate manufacturer's authorisation and servicing capabilities. Differentiate perpetual software from subscription services. Check laboratory power, gas, cooling and space before tender issue. Calculate lifecycle cost rather than comparing only the purchase price. Record every technical clarification through the formal tender process. Link payment milestones with installation, qualification, training and acceptance. Risks to Avoid While Using the FSSAI Specifications The following drafting and evaluation risks need attention: Treating the indicative notice as a mandatory legal standard. Copying every parameter without a laboratory-needs assessment. Using brand-based wording where performance-based wording is possible. Comparing resolution without stating measurement conditions. Treating Screening Detection Limit and Limit of Quantification as the same measure. Leaving the demonstration protocol open to different interpretations. Ignoring software subscriptions and database renewal charges. Accepting a long warranty promise without manufacturer backing. Failing to define service-response and downtime calculations. Ignoring duplication or unclear quantities in the accessory list. Business Opportunities Created The specifications may support demand for several document-related products and services. LC-QToF and LC-Q-Orbitrap equipment supply. UHPLC systems and compatible columns. Pesticide and antibiotic residue-testing solutions. Honey-authentication methods. Metabolomics and lipidomics software. Spectral databases and laboratory data systems. Nitrogen generation and laboratory gas equipment. UPS installation and power-quality services. Instrument qualification and performance verification. Analyst training and method-development support. AMC, CMC and spare-part supply. Laboratory setup consultancy. Technical tender support and bid-document review. The notice does not announce a procurement quantity or market size. Commercial opportunities will depend on future tenders and individual laboratory decisions. How Can Corpseed Help? Corpseed can support laboratories, procuring organisations, equipment manufacturers and suppliers with document-specific technical tender support. Relevant assistance may include: Reviewing the applicability of the FSSAI benchmark. Preparing a clause-wise compliance matrix. Providing technical bid consulting. Conducting a tender specification review. Identifying unclear or restrictive tender conditions. Bid compliance evaluation. Review of technical data sheets and performance proofs. Warranty, training, and service obligations mapping. Procurement advisory and laboratory establishment planning support. Corpseed focuses on accurate document review and practical bid preparation. Final technical acceptance, procurement and contract decisions remain with the concerned authority. For an LC-HRMS tender or technical bid, Corpseed's technical tender support can help organise requirements, supporting records, deviations and lifecycle commitments before submission. This is an indicative reference to get a fully-fledged LC-HRMS system. The standard includes analytical workflow, instrument capabilities, software, databases, utilities, accessories, training, test data, and support. No statutory purchase duty, registration requirement, compliance deadline, or penalty has been introduced. The final tender issued by the concerned procuring agency will determine the binding technical and commercial conditions. For free consultation, connect with Corpseed!
Subject
FSSAI HEE Specifications Corrigendum 2026: LC-MS/MS and ICP-MS ChangesSummary: The Food Safety and Standards Authority of India ( FSSAI ) issued a corrigendum on 17 July 2026 to its technical specifications for high-end laboratory equipment. The FSSAI HEE specifications corrigendum 2026 changes one LC-MS/MS specification and one ICP-MS specification. For Liquid Chromatography-Tandem Mass Spectrometry (LC-MS/MS), the stated desorption temperature has changed from 500°C or better to 400°C or better. For Inductively Coupled Plasma Mass Spectrometry (ICP-MS), the high-mass-side figure has changed from ≤ 1 × 10⁻⁷ to ≤ 5 × 10⁻⁷. Other terms in the notice dated 10 December, 2025 remain unchanged. According to the FSSAI, these specifications are indicative. These specifications are neither standard specifications for tendering nor procurement norms. Notification at a Glance Particular Verified details Issuing authority Food Safety and Standards Authority of India, Quality Assurance Division Document type Corrigendum File number QA-11013/1/2025-QA-FSSAI eOffice reference I/39900/2026 Date of issue 17 July 2026 Original notice date 10 December 2025 Effective date Not expressly specified Governing framework FSSAI is established under the Food Safety and Standards Act, 2006. The document itself contains indicative procurement specifications Equipment covered by the original notice GC-MS/MS, LC-MS/MS, ICP-MS and ICP-OES Specifications amended LC-MS/MS and ICP-MS Main stakeholders Procuring agencies, food testing laboratories, Technical Committees, manufacturers, suppliers and bidders Compliance deadline Not expressly specified Nature of requirement Indicative and non-mandatory Fees or penalties Not specified The corrigendum is mainly relevant to laboratory procurement and tender evaluation. It does not introduce any business licence, registration, certification, or regulatory filing requirements. Background of the FSSAI Equipment Specifications FSSAI issued the original notice on 10 December 2025. It contained approved technical specifications for four categories of High-End Equipment (HEE): Gas Chromatography-Tandem Mass Spectrometry (GC-MS/MS) Liquid Chromatography-Tandem Mass Spectrometry (LC-MS/MS) Inductively Coupled Plasma Mass Spectrometry (ICP-MS) and Inductively Coupled Plasma-Optical Emission Spectrometry (ICP-OES). These instruments support laboratory testing of food, agricultural products, water and other samples. They can help detect pesticide residues, veterinary drug residues, antibiotics, mycotoxins, contaminants and metals. The original annexures cover instrument performance, software, sample systems, accessories, power backup, gases, qualification, warranties, training, maintenance and technical bid evidence. The corrigendum does not replace those annexures. It corrects only two entries. The use of the word “approved” does not make every specification a compulsory legal standard. The corrigendum expressly states that the specifications are purely indicative. Why Was This Corrigendum Issued? The document was issued to correct two values in the original technical specifications. It does not give a separate scientific explanation for either correction. The corrected figures may help avoid the use of inaccurate conditions in future tenders, technical evaluations and compliance sheets. Any wider purpose, such as increasing supplier participation, would be a possible business effect rather than an objective expressly stated by FSSAI. What Has Changed? The corrigendum makes the following changes: Annexure II, Clause 6(vi), concerning the LC-MS/MS ionisation source, now uses a desolvation temperature of 400°C or better. Annexure III, Clause 6(ii)(b), concerning the ICP-MS mass analyser and detector, now uses a high-mass-side figure of ≤ 5 × 10⁻⁷. The ICP-MS low-mass-side figure remains ≤ 5 × 10⁻⁷. All remaining parts of the original notice continue without change. Old vs. Revised Technical Specifications Equipment and clause Earlier position Revised position Business meaning LC-MS/MS, Annexure II, Clause 6(vi) Desolvation temperature for ESI and APCI sources: 500°C or better Desolvation temperature for ESI and APCI sources: 400°C or better The stated temperature has been reduced by 100°C ICP-MS, Annexure III, Clause 6(ii)(b) High Mass Side: ≤ 1 × 10⁻⁷ High Mass Side: ≤ 5 × 10⁻⁷ The permitted numerical ceiling is higher Other provisions Original notice and four annexures No change Existing specifications continue unless a procuring agency modifies them The changes may affect whether certain equipment models fit a tender’s technical conditions. Final eligibility will still depend on the full tender and the operational needs of the procuring laboratory. Clause-Wise Explanation of the Technical Changes 1. LC-MS/MS ionisation source requirement LC-MS/MS is commonly used to measure pesticides, antibiotics, veterinary drug residues and mycotoxins. Its ionisation source converts sample molecules into charged particles before measurement. The original specification covers two ionisation methods: Electrospray Ionisation (ESI) and Atmospheric Pressure Chemical Ionisation (APCI). Desolvation uses heat to remove the solvent from charged droplets the earlier specification required a desolvation temperature of 500°C or higher for both sources. The corrected value is 400°C or better. This change may allow more LC-MS/MS models to fit the indicative condition. However, the corrigendum does not define what “or better” means. A procuring agency should assess the temperature range, source design, method performance, and sample needs together. A higher temperature should not automatically be treated as better for every instrument. Performance-based tender wording can reduce confusion. 2. ICP-MS mass analyser and detector requirement ICP-MS is used to detect metals at very low levels. The original specifications refer to testing food, seafood, water and other samples at parts-per-million, parts-per-billion and parts-per-trillion levels. Clause 6 covers the mass analyser and detector. The corrected part now reads: Mass range: 5–260 atomic mass units (amu) or better Low Mass Side: ≤ 5 × 10⁻⁷ and High Mass Side: ≤ 5 × 10⁻⁷. An atomic mass unit is used to express the mass of atoms and molecules. The source does not separately explain the unit or technical name for the low- and high-mass-side figures. The move from ≤ 1 × 10⁻⁷ to ≤ 5 × 10⁻⁷ raises the permitted maximum for the high-mass side. Numerically, this makes the single condition less strict. This is a technical inference from the revised figures, not an express conclusion stated by the FSSAI. 3. Specifications that remain unchanged No change has been made to the GC-MS/MS or ICP-OES annexures. For LC-MS/MS and ICP-MS, all conditions other than the two corrected values remain unchanged. Unchanged areas include instrument sensitivity, detection limits, software, workstations, autosamplers, gas systems, power backup, qualification, warranties, training, maintenance, accessories and performance documents. Scope and Applicability The corrigendum mainly affects stakeholders involved in selecting, supplying or evaluating high-end food testing equipment. Stakeholder Covered? Relevant effect Main responsibility Procuring agencies Yes May need to correct tender specifications Assess operational needs and finalise suitable conditions Food testing laboratories Yes May need to reassess equipment suitability Match the equipment with testing needs Technical Committees Yes May review or modify indicative values Prepare fair and technically clear specifications Equipment manufacturers and suppliers Yes May need to revise compliance statements Submit accurate, model-specific information Tender and bid teams Yes May need to update technical submissions Use corrected clauses and supporting evidence General food businesses Usually not directly No new operating duty is created Review only where involved in laboratory procurement The corrigendum does not create a general compliance duty for all food manufacturers, importers, distributors or sellers. Its direct use is connected with equipment procurement and technical evaluation. Nature of the Requirement: Indicative, Not Mandatory FSSAI clearly states that the specifications are purely indicative. They must not be treated as the standard tender specifications or mandatory procurement conditions. The source sets out the following procurement principles: Procuring agencies must independently assess their operational requirements. Agencies may modify any specification where needed. The specifications must not be read as favouring or restricting a manufacturer, technology, supplier or country of origin. Agencies may form their own Technical Committee (TEC). Subject-matter experts may be consulted before finalising tender specifications. FSSAI will not be liable for procurement or contractual issues arising from purchases made by other agencies. This distinction matters. A bidder should not be accepted or rejected only because a product matches or differs from an indicative value. The complete technical and operational position must be reviewed. Key Dates and Implementation Position Event Date Required response Original HEE specification notice 10 December 2025 Use as the base document Corrigendum 17 July 2026 Replace the two earlier values Separate effective date Not expressly specified Do not assume a retrospective date Compliance deadline Not expressly specified No statutory filing or transition deadline applies For an active tender that still contains the earlier figures, the procuring agency may need to decide whether a clarification or tender corrigendum is required. FSSAI does not prescribe a formal process for doing so. How Businesses Will Achieve Compliance? A practical roadmap for laboratories, agencies, and suppliers navigating this update: Whether the present or future purchase order of yours is based on LC-MS/MS or ICP-MS, the corrigendum will directly impact you. Revise the technical specifications documents to incorporate the updated desorption temperatures (≥400°C) and high mass-side sensitivity (≤5 × 10^-7) for LC-MS/MS and ICP-MS, respectively. Verify the compliance statement: If you have provided a compliance/non-compliance sheet based on the FSSAI specification table, ensure the values are from the corrigendum, not the 10 December 2025 version. Other specifications remain unchanged; this particular corrigendum affects only two data points. All other requirements in Annexure-II (LC-MS/MS) and Annexure-III (ICP-MS), including sensitivity, warranty, IQ/OQ/PQ, software, and accessories, remain the same as per the initial specifications. Documentation, manufacturer's certificate, hydrostatic test certificate, CCOE-Nagpur approval certificate, and purity certificate for gas cylinders will continue to be required. Consult the FSSAI website under "Advisories/Orders" and "Tenders/EOI" for the authoritative, current version of both the original notice and this corrigendum before finalising any bid. Common pitfall to be avoided: Depending on the cached or downloaded versions of the December 2025 notice, ignoring the fact that this corrigendum was issued. Given the change involved just two figures, this can be easily missed if one is not tracking the FSSAI advice. Impact on Businesses and Other Stakeholders Procuring agencies and laboratories Tender documents based on the December 2025 notice may contain outdated values. Procurement teams may need to recheck technical conditions and model evaluations. The correction may increase the number of systems that can be considered. However, laboratories must still review sensitivity, stability, sample type, workload, maintenance needs and service support. Manufacturers, suppliers and bidders Some LC-MS/MS or ICP-MS models that did not fit the earlier figures may fit the corrected position. This does not provide automatic tender eligibility. Suppliers may need to update: Clause-wise compliance statements Technical product comparisons Bid deviation notes Manufacturer literature Performance evidence and Tender clarification requests. Technical and procurement teams A review based only on the original notice may produce an incorrect result. The tender specification review should use both the original annexures and the corrigendum. No government fee is introduced. The likely cost relates to revising documents, reassessing models and repeating part of a technical evaluation. What Affected Businesses Should Do Next? The source does not create a formal compliance process. The following steps are practical tender controls based on the corrected provisions: Confirm the document version. Check whether internal files include the 17 July 2026 corrigendum. Replace both outdated values. Use 400°C or better for LC-MS/MS Clause 6(vi) and ≤ 5 × 10⁻⁷ for the ICP-MS high-mass side. Keep all other requirements unchanged. Do not treat the corrigendum as a new set of complete specifications. Review active tender documents. Identify tenders, technical sheets or evaluation reports that still use the earlier figures. Reassess equipment eligibility. Compare each model against the corrected values and the remaining adopted tender conditions. Update technical bid documents: correct compliance matrices, brochures, performance documents and deviation statements where required. Record technical decisions. Keep the reason for retaining, modifying or replacing an indicative specification. Benefits of the Corrected Specifications The corrigendum can provide several practical benefits: More accurate tender documents: Procurement teams can remove the two superseded values. Fairer technical evaluation: Suitable models are less likely to be excluded because of an incorrect figure. Wider equipment choice: The revised values may allow additional models to be considered. Improved documentation control: Laboratories may coordinate tender sheets, evaluation forms and compliance matrix. Improved clarity in supplier submissions: Bidders can submit evidence in response to the revised terms. Reduced disputes: Clear specifications will minimize unnecessary technical disputes. These benefits depend on careful tender drafting. The corrigendum does not guarantee a procurement result or commercial advantage. Practical and Technical Challenges The update is short, but implementation may still create difficulties: Old tender templates may still retain the earlier values. Active bids may require clarification or a revised technical sheet. The words “or better” may be interpreted differently by suppliers. Some evaluations may need to be repeated. Product literature may describe performance differently from the FSSAI table. Procurement teams must separate indicative guidance from mandatory tender conditions. The absence of a separate effective date may also create questions for tenders started before 17 July 2026. Procurement and Business Risks The corrigendum does not specify fines, suspension, prosecution or other statutory penalties. It is therefore incorrect to create a legal penalty section for this update. Reasonable business risks may still arise: An outdated value may wrongly exclude a suitable model. An inaccurate compliance statement may weaken a technical bid. Conflicting tender documents may lead to clarification requests or disputes. Manufacturer-specific wording may reduce fair competition. Failure to assess actual laboratory needs may result in the selection of unsuitable equipment. These are procurement and operational risks, not statutory consequences announced by FSSAI. Business Opportunities Created The corrected specifications may create opportunities in areas linked to laboratory procurement: Technical tender support for laboratories and suppliers Tender specification review and manufacturer-neutral drafting Bid compliance assessment Laboratory equipment selection support Technical document and performance-data review Technical Committee and procurement advisory services Installation qualification and performance planning Training, maintenance and application support. Equipment suppliers may also revisit opportunities where a model fits the corrected values but did not fit the earlier wording. Eligibility will still depend on the tender as a whole. Recommended Practices for Tender Compliance The following practices can help procurement and bid teams use the corrigendum correctly: Maintain one controlled copy of the original notice and corrigendum. Cite the corrected clause in tender and bid documents. Use performance-based language where possible. Define how “or better” will be assessed. Check claims against model-specific technical literature. Record the operational reason for each tender condition. Obtain expert input where specifications may restrict competition. Review all amendments before completing the technical evaluation. These are recommended controls. They are not additional legal duties created by FSSAI. Mistakes and Interpretation Risks to Avoid Stakeholders should avoid the following errors: Treating the corrigendum as a complete replacement for the original annexures Continuing to use 500°C for LC-MS/MS Clause 6(vi) Continuing to use ≤ 1 × 10⁻⁷ for the ICP-MS high-mass side Treating the indicative specifications as compulsory legal standards Assuming the issue date is also a stated effective date Applying the changes to GC-MS/MS or ICP-OES Claiming that a model automatically qualifies because it meets one corrected value and Ignoring the procuring agency’s independent technical assessment. These risks arise from the wording of the source and normal document-control concerns. FSSAI has not measured their frequency. Is the Corrigendum Necessary or an Additional Burden? The correction appears necessary because technical tenders depend on exact values. Even a small numerical error can change equipment eligibility and supplier participation. The LC-MS/MS revision may allow systems with a 400°C desolvation specification to be considered. The ICP-MS revision also relaxes the stated high-mass-side figure. Both changes may support a broader technical assessment. The short-term burden is mainly administrative. Procurement teams may have to revise tender sheets, recheck bids or issue clarifications. Suppliers may need to update technical submissions. The document takes a balanced approach by keeping the specifications indicative. Procuring agencies retain control over their final requirements. On balance, the correction is useful, provided it is applied with the original notice and not treated as a new mandatory standard. Future Outlook There are no other amendments announced by FSSAI, implementation process, or deadlines mentioned in the corrigendum. Speculation on other amendments would, thus, be baseless. Testing laboratories and equipment suppliers must monitor the advisories and tender pages for any further corrigenda or equipment specifications issued by FSSAI. The document control process within organizations must ensure that each amendment is linked back to its original notice. Key Takeaways The FSSAI HEE specifications corrigendum 2026 corrects two technical values. The LC-MS/MS desolation temperature is now 400°C or better. The ICP-MS high-mass-side figure is now ≤ 5 × 10⁻⁷. The update mainly affects laboratories, procuring agencies, Technical Committees, equipment suppliers and bidders. There is no stated compliance deadline or statutory penalty. The immediate priority is to update tender documents and technical evaluations while keeping the rest of the 10 December 2025 specifications unchanged. How Can Corpseed Help? Corpseed can assist laboratories, equipment suppliers, bidders and procurement teams with document-specific technical tender support. Relevant services include: Applicability and corrigendum assessment Tender specification review Clause-wise bid compliance assessment Technical bid consulting Compliance matrix preparation and review Product literature and performance-document review Manufacturer-neutral specification support and Procurement advisory services. Corpseed helps identify inconsistencies, missing evidence and outdated technical conditions. Final tender requirements, equipment selection and procurement decisions remain with the responsible authority. Laboratories and suppliers requiring tender compliance services or technical bid support can contact Corpseed for a focused review of the original FSSAI specifications, the corrigendum and the relevant procurement documents.
Subject
How is India Strengthening Global Food Standards Through Codex CAC49?Summary: India strengthened its role in Codex Alimentarius Commission compliance at the 49th Session of the Codex Alimentarius Commission (CAC49), held in Geneva, Switzerland, from 6th to 10th July 2026. The Commission adopted seven Codex standards and guidelines developed under India's chairmanship or co-chairmanship, including confirmed standards for Dried Coriander Seeds and Fresh Curry Leaves. India's proposal to begin developing a Codex Standard for Cashew Kernels was approved as new work this marks the start of a drafting process, not a finished standard. The Indian delegation was led by Rajit Punhani, Chief Executive Officer, FSSAI, supported by technical experts from FSSAI and the Spices Board. This update matters for Codex Alimentarius Commission compliance planning across India's spice, herb, and nut export sectors, even though none of these developments are yet legally binding in India. The Regulatory Framework Behind Codex Alimentarius Commission Compliance Compliance with the Codex Alimentarius Commission is based on internationally recognized standards and guidelines on food that have been created through collaboration between the Food and Agriculture Organization (FAO) and the World Health Organization (WHO), which countries can refer to but are not automatically obliged to follow when regulating food safety and international trade. This is the first step to understanding the commercial significance of the results reached within the framework of CAC49. What the Codex Alimentarius Commission Does? The Commission was established with four core objectives that directly shape global food trade: Protecting consumer health by developing internationally agreed food safety standards based on scientific evidence. Ensuring fair trade practices by giving countries a common, science-based reference point instead of relying on inconsistent national rules. Reducing technical trade barriers so that food products don't face arbitrary rejection or repeated re-testing when crossing borders. Coordinating standard-setting between FAO and WHO member states, giving Codex texts broad international scientific credibility. India's Evolving Role Within Codex India participates in the Codex Alimentarius Commission through its food safety regulator, the Food Safety and Standards Authority of India (FSSAI), which represents Indian interests across various Codex technical committees. Over the past several sessions, India has increasingly taken on chairmanship and co-chairmanship roles in drafting new Codex texts for product categories where India holds major global production or export significance, a shift from being a standard-follower toward being a standard-shaper. Particular Detail Session 49th Session of the Codex Alimentarius Commission (CAC49) Session Geneva, Switzerland Session 6th to 10th July 2026 Indian Delegation Head Rajit Punhani, Chief Executive Officer, FSSAI Supporting Team Technical experts from FSSAI and the Spices Board Issuing Authority (India) Ministry of Health and Family Welfare Press Release Date 14th July 2026 Governing Bodies Food and Agriculture Organization (FAO) and World Health Organization (WHO) What Has Changed: The Standards Confirmed at CAC49? At CAC49, the Commission formally adopted seven Codex standards and guidelines developed under India's leadership. It separately approved new work to begin drafting a Codex Standard for Cashew Kernels, two distinct outcomes that carry different compliance implications. It's important to treat these as separate developments rather than one bundled announcement. Standards Confirmed as Adopted Adopted Standard Relevance to Exporters Codex Standard for Dried Coriander Seeds Sets an internationally recognized quality benchmark for a major Indian spice export Codex Standard for Fresh Curry Leaves Establishes the first global Codex quality benchmark for this widely traded Indian herb Five additional Codex texts Not individually named in the official press release It's worth being precise here: the official government press release confirms seven total texts were adopted under India's leadership, but explicitly names only two: Dried Coriander Seeds and Fresh Curry Leaves. Businesses in other spice, herb, or agricultural export categories should track the official Codex Alimentarius Commission CAC49 session report once published in full, rather than assuming their product is or isn't among the remaining five. New Work Approved: Codex Standard for Cashew Kernels Separately, the Commission approved India's proposal to begin new work on a Codex Standard for Cashew Kernels. This is a distinct and earlier-stage outcome: "New work approved" means the Commission has agreed a standard should be developed; it authorizes the technical committee process to begin. It does not mean a finished standard, quality parameters, or grading criteria currently exist. India, having proposed this work, is expected to play a leading role in shaping the draft, giving Indian cashew industry stakeholders a genuine opportunity to influence the eventual specification from an early stage. For India's cashew processing and export industry, where India ranks among the world's largest processors, this represents a multi-year opportunity rather than an immediate compliance requirement. Implementation Timeline/Norms Codex standard adoption follows a defined multi-stage international process, and understanding where each of CAC49's outcomes sits on that timeline helps businesses distinguish between what requires immediate attention and what is still years away. Stage Domestic (FSSAI) regulatory review Cashew Kernels Draft standard developed by technical committee Domestic (FSSAI) regulatory review Not yet started Committee-level approval Completed (pre-CAC49) N/A Full Commission adoption Completed at CAC49 (10th July 2026) Not applicable yet New work formally approved N/A (already adopted) Completed at CAC49 (10th July 2026) Draft standard published for review Full text expected via official Codex publication Drafting process yet to begin Domestic (FSSAI) regulatory review Not yet confirmed in this release Not applicable standard doesn't exist yet Key distinction for compliance planning: The Dried Coriander Seeds and Fresh Curry Leaves standards are now finalized at the international level and awaiting full publication of the adopted text. The Cashew Kernels standard is only beginning its multi-year drafting journey, which typically involves several rounds of technical committee review before reaching adoption at a future Commission session. Why was This Implemented? India's growing leadership role in Codex standard-setting reflects a deliberate strategic shift from adapting to international food standards set by others to actively shaping the standards that govern products where India is a dominant global producer and exporter. A few structural reasons explain why this matters: India's export significance in these product categories. Importance of India's exports in these groups of products. India ranks among the world’s top producers and exporters of spices like coriander and curry leaves and among the processors of cashew kernels, which makes India highly concerned about having realistic Codex Standards. Reducing technical trade friction. Internationally agreed, science-based standards reduce the risk of inconsistent or arbitrary quality requirements imposed by individual importing countries. Strengthening India's negotiating position. Leading the technical drafting process, rather than simply reacting to standards set elsewhere, gives India and, by extension, Indian exporters more influence over eventual requirements. Institutional coordination. The joint participation of FSSAI and the Spices Board reflects a coordinated approach between India's domestic food regulator and its sector-specific export promotion body, which strengthens the credibility and technical depth of India's Codex contributions. Impact on Businesses The level of compliance with Codex Alimentarius Commission guidelines for Indian food exporters varies according to their respective food groupings and the stage of adoption of the standard by that grouping, and one must not over-emphasise the influence of such emerging issues. Dried coriander seed exporters now have an internationally adopted quality reference point they can use in specification discussions with international buyers, once the full standard text is published. Fresh curry leaf exporters gain the first-ever global Codex benchmark for this product, which previously lacked a dedicated international quality standard. Cashew kernel processors and exporters face no immediate compliance change. Still, they should treat this as an early signal that a dedicated international standard is now in development, with India in a position to influence its content. Exporters of the five unnamed additional standards cannot yet determine their specific impact and should monitor official Codex publications for clarity. Domestic food businesses generally should note that Codex adoption does not automatically alter Indian law. Any domestic regulatory impact would require a separate, distinct action by FSSAI to review and incorporate these standards into Indian food safety regulations, something this press release does not confirm has happened or is planned. How Businesses Will Achieve Compliance? Since only two of the seven adopted standards are currently identified, and the Cashew Kernels standard doesn't yet exist in draft form, "compliance" at this stage means active monitoring and positioning rather than implementing fixed new requirements. Here is a practical, honest response path: Step 1: Identify Your Product's Relevance Determine whether your business exports Dried Coriander Seeds or Fresh Curry Leaves, since these standards are confirmed and finalized at the international level. Step 2: Obtain the Adopted Standard Text When the Codex Alimentarius Commission issues the full session report and standard texts from the CAC49 session, assess the quality standards established for your product. Step 3: Review the Gaps Between Internal and Codex Standards Determine if there are any gaps between your current internal specifications for quality control and testing and the newly released Codex standards. Step 4: Follow for the Five Remaining Standards Since the press release does not list all seven adopted standards, keep an eye out for future announcements from the Codex Alimentarius Commission and the FSSAI to determine whether or not your product falls under the adopted standards. Step 5: Participate in Drafting the Cashew Kernel Standard If your business involves either cashew kernel processing or export, engage the Spices Board and industry associations while the standards are still being drafted; at this point, industry technical input is at its greatest. Step 6: Follow the FSSAI for Domestic Regulations Monitor any future communications or draft regulations from the FSSAI regarding these Codex standards since the domestic standards would be aligned through a different process. Compliance Monitoring Checklist Action Item Applicable To Priority Track official CAC49 session report publication All food exporters High Review full Dried Coriander Seeds standard text Coriander exporters High Review full Fresh Curry Leaves standard text Curry leaf exporters High Monitor for identification of remaining 5 standards All spice/herb/agri exporters Medium Engage industry body on Cashew Kernels drafting Cashew processors/exporters Medium Monitor FSSAI for domestic regulatory alignment signals All food businesses Medium Benefits for Businesses Clearer international quality reference points for coriander seed and curry leaf exporters, reducing dependence on inconsistent, country-specific import requirements. Early influence opportunity for the cashew industry, since India's leadership in drafting the new standard allows Indian stakeholders to shape requirements before they're finalized, rather than adapting after the fact. Superior negotiating power internationally because India's involvement in Codex standard-setting as a result of the growing technical credibility that will help in trade negotiations going beyond these particular products. Lesser trade friction in the long run since there is always less risk of rejection or quality disputes at the port of entry because of the internationally accepted standards. Greater coordination through FSSAI and Spices Board as the two entities work together. Opportunity or Additional Work: How Businesses Should View This Update This is fundamentally a positive development for Indian food exporters rather than an additional compliance burden, since it does not impose new mandatory requirements it creates an early-mover opportunity for businesses willing to engage proactively with the standards being shaped. Opportunity Case: With India at the forefront in the development of standards that will apply to the products that it imports in large quantities, there is an increased likelihood that the international benchmarks will consider the production practices of Indian industries. About the cashew exporting industries, participating in the drafting process is cheap yet very productive. The case for added vigilance: Businesses do need to invest time in monitoring official Codex publications and FSSAI communications, since the full detail of five of the seven adopted standards, and any domestic regulatory follow-up, is not yet public. Passive businesses risk missing the window to align specifications early or provide technical input. The balanced view: This is no compliance directive that demands an urgent response; it provides an opportunity for strategic monitoring and engagement. Those organizations that keep abreast of developments and actively engage with the Spices Board and FSSAI will have a significant competitive advantage over those firms that only respond after standards have been developed and adopted. Business Opportunities Created Compliance advisory services for exports that will assist firms in keeping track of Codex publications and specifications after the complete texts are made available. Engagement activities within industry associations for stakeholders in the cashew industry who wish to contribute to the development of the Cashew Kernels standard. Quality certification and testing services aligned to the new Dried Coriander Seeds and Fresh Curry Leaves standards, once published in full. Trade documentation and specification-sheet updating services for exporters wanting to reference the newly adopted Codex standards in buyer communications. Regulatory monitoring and alert services tracking both Codex Alimentarius Commission publications and any future FSSAI domestic alignment activity. Corpseed's Core Message India's outcomes at CAC49 reflect a genuine shift in the country's role within global food standard-setting from adapting to international rules to actively shaping them. For Indian exporters of coriander seeds, curry leaves. Eventually, cashew kernels, this is a meaningful development. Still, the smart response is measured: track official publications closely, engage early where the opportunity exists, and avoid treating early-stage developments like the Cashew Kernels "new work approval" as if they were finished, binding requirements. At Corpseed, our advice to food exporters is straightforward: build a monitoring system for official Codex Alimentarius Commission publications and FSSAI communications now, rather than waiting for a buyer dispute to force reactive compliance. Businesses that engage proactively, especially in the still-open Cashew Kernels drafting process, position themselves to shape requirements in their favor, rather than simply complying with standards decided without their input. Want help tracking these Codex developments against your export specifications? Talk to Corpseed's food compliance advisory team for a product-specific monitoring and readiness assessment.
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FSSAI Second Amendment Regulations 2026: Complete Compliance Guide for Food BusinessesSummary: On 23rd June 2026, the Food Safety and Standards Authority of India (FSSAI) notified the Food Safety and Standards (Licensing and Registration of Food Businesses) Second Amendment Regulations, 2026 in the Gazette of India. This notification brings two important changes for every food business in India, from big manufacturers to small shopkeepers. This guide breaks down the entire notification in simple language, explains what has actually changed, why it matters, and how your business can stay compliant without confusion. The Regulatory Framework Every food business in India, whether it makes food, packs food, stores food, or sells food, must follow rules made under the Food Safety and Standards Act, 2006. This is the main law that governs food safety in the country. Under this Act, FSSAI made the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011. These are the master rules that tell every Food Business Operator (FBO) what license conditions they must follow and what hygiene standards they must maintain. FSSAI has the legal power, under Section 92(2)(o) read with Section 31 of the Act, to amend these regulations whenever needed, with the Central Government's prior approval. That is exactly what has happened now. FSSAI followed the correct legal process: it first published a draft amendment on 23rd January 2026, invited objections and suggestions from the public and industry for 30 days from 27th January 2026, reviewed those responses, and only then issued the final, binding regulation on 23rd June 2026. This amends the original 2011 Regulations (notified 1st August 2011), which had last been amended on 10th March 2026. What Has Changed? The amendment touches two specific parts of the 2011 Regulations. Let's look at each one closely. 1. Daily Record-Keeping Condition (Schedule 2, Annexure 3 License Conditions) This is about Serial Number 8 under the "Conditions of License" list, which every licensed food manufacturer must follow. Earlier, this condition required maintaining daily records of production and raw material utilization. Now, it clearly requires these records to be maintained separately, meaning two distinct daily records instead of one combined entry. Importantly, this condition does not apply to non-manufacturing food businesses, so traders and distributors who don't manufacture anything are out of its scope. 2. Storage Rule for Raw Materials and Food Products (Schedule 4, Part II, Para 5.2.5) This is part of the general hygiene and sanitary requirements every FBO applying for a license must follow, under the "Food Operations and Controls" section. Earlier, the storage requirement was fairly general. Now, storage of raw materials, ingredients, work-in-progress, and processed/cooked/packaged food must strictly follow FIFO (First In, First Out) and FEFO (First Expired, First Out) principles. In simple words, the oldest stock and the stock closest to its expiry date must be used or sold first. This is a globally recognized food safety practice used to cut down on spoilage and wastage. This requirement does not apply to retailers. S. No. Where What Changed Who Is Exempted 1 Schedule 2, Annexure 3, Condition 8 Separate daily record of production and raw material use Non-manufacturing food businesses 2 Schedule 4, Part II, Para 5.2.5 Mandatory FIFO and FEFO storage system Retailers Implementation Timeline/Norms Unlike many regulations that give businesses a grace period of 6 months or a year, this amendment has no separate transition period. The notification clearly states it comes into force "on the date of their publication in the Official Gazette," meaning the rule is applicable from 23rd/24th June 2026 itself, the day it was published. Date Event 23rd January 2026 Draft amendment notified for public objections 27th January 2026 Draft made available to the public (30-day clock starts) Late February 2026 30-day objection/suggestion window closes 23rd June 2026 Final regulation notified in the Gazette Immediate Regulation comes into force, no additional waiting period What this means for businesses: There is no "wait and watch" option here. Since the regulation is already in force, food businesses covered under these provisions should start aligning their record-keeping and storage practices right away to avoid compliance gaps during FSSAI inspections or license renewals. Why This Was Implemented? FSSAI did not make this change randomly. There are clear, practical reasons behind both amendments: Better traceability of food: Separate records of production and raw materials make it much easier for FSSAI to trace back a food safety issue to its source, such as a specific batch of raw material. Reducing food wastage and spoilage- making FIFO/FEFO a formal requirement (instead of just a "good practice") ensures older or near-expiry stock is used first, cutting down food waste across the supply chain. Consumer safety: When expired or near-expired ingredients don't sit at the back of the storeroom while fresh stock is used first, the chances of expired food reaching consumers go down significantly. Reducing unnecessary burden on small players- FSSAI clearly built in exemptions: non-manufacturing businesses don't need the detailed production record, and retailers don't need to implement full FIFO/FEFO systems. This shows the intent was to target actual risk points rather than adding paperwork everywhere. Global alignment- FIFO and FEFO are internationally recognised food safety and quality management practices (used in HACCP and ISO 22000 systems), bringing Indian food regulations closer to global standards. Impact on Businesses The impact of this amendment is different depending on what kind of food business you run, so it helps to break it down by category. Food manufacturers feel the full weight of both changes. They must now maintain separate daily records of production and raw material utilization, and they must also reorganize their storage practices to follow FIFO and FEFO principles strictly. This means updating internal record formats, whether on paper registers or in digital/ERP systems, so that production data and raw material consumption data no longer sit together in one combined entry. Food processors and packagers are in a similar position to manufacturers. Since they handle raw materials, work-in-progress, and packaged food, both the record-keeping conditions and the storage conditions apply to them directly. They need to plan for Labeling systems that show manufacturing and expiry dates clearly, and warehouse layouts that push older or near-expiry stock out first. Warehousing and storage businesses are affected mainly by the second change. Even if they don't manufacture anything themselves, if they store raw materials or processed and packaged food on behalf of others, the FIFO/FEFO storage requirement applies to them. Whether the record-keeping condition applies depends on whether they also carry out any manufacturing activity. Non-manufacturing food business operators, such as pure traders and distributors who don't produce or process food themselves, get relief from the record-keeping condition since it is explicitly stated not to apply to non-manufacturing businesses. However, if they store processed or packaged food, the FIFO/FEFO storage rule can still apply to them. Pure retailers, like convenience stores and supermarkets selling packaged food directly to consumers, are the least affected group. Since they don't manufacture food, the record-keeping condition doesn't apply to them. Since the notification specifically exempts retailers from the FIFO/FEFO storage requirement, they are free from that obligation too. Restaurants and food service businesses need to check their own operations carefully. If they only serve food prepared fresh for immediate consumption, they may fall closer to non-manufacturing status. But if they process, prepare in bulk, or store ingredients and packaged food over time, both conditions are likely to apply. In practical terms, this means the businesses that must act immediately are manufacturers, processors, and storage operators. They need to redesign how they record daily production and raw material figures, and how they physically arrange stock so that older or soon-to-expire items are used or sold first. Retailers and non-manufacturing traders, on the other hand, get genuine regulatory relief here. They don't need to build new systems for these two specific conditions, which meaningfully reduces their overall compliance burden compared to businesses further up the supply chain. How Will Businesses Achieve Compliance? Compliance here is achievable and doesn't require expensive overhauls if done systematically. Here's a step-by-step approach. Step 1: Identify Your Business Category First, confirm whether you are a manufacturer, non-manufacturer, or retailer under FSSAI's definitions. This decides which of the two new conditions apply to you. Step 2: Update Record-Keeping Systems (For Manufacturers) Maintain a separate daily production register and a separate daily raw material utilization register. These can be kept physically or through software/ERP tools. FSSAI does not mandate a specific format, only that the records be maintained and kept distinct. Keep records dated, signed, and ready for inspection at any time. Step 3: Redesign Storage Practices Around FIFO/FEFO Label all raw materials and finished goods with the manufacturing date and expiry date. Arrange storage racks so older stock is placed in front and used first (FIFO). Where expiry dates vary due to different batches, prioritize the stock expiring soonest (FEFO). Use colour-coded labels, batch numbers, or barcode/QR systems for easy identification. Step 4: Train Staff Warehouse and production staff must understand FIFO/FEFO practically, not just in theory. Simple visual charts near storage areas help staff follow the system correctly every day. Step 5: Conduct Internal Audits Do monthly or quarterly internal checks to confirm records are being maintained, and FIFO/FEFO is actually being followed on the ground, not just on paper. Step 6: Keep Documentation Ready for FSSAI Inspection FSSAI officers can inspect these records during routine checks or license renewal. Non-compliance can lead to license suspension, cancellation, or penalties under the FSS Act. Compliance Checklist Table Action Item Applicable To Priority Separate production & raw material registers Manufacturers High Digital/manual record-keeping system Manufacturers High FIFO/FEFO labelling and layout Manufacturers, processors, and storage units High Staff training on FIFO/FEFO Manufacturers, processors, and storage units Medium Internal compliance audit All applicable FBOs Medium Confirm exemption status Non-manufacturers, retailers High Benefits for Businesses While this looks like a compliance requirement, it actually brings real business value: Reduced food wastage and spoilage- FIFO/FEFO ensures older and near-expiry stock is used first, directly cutting down losses and improving profit margins over time. Better inventory accuracy- separate, disciplined record-keeping gives businesses a clearer picture of raw material usage and production efficiency. Faster and easier recalls- clean, separated records let a business trace and recall affected batches quickly if a food safety issue ever arises, protecting brand reputation. Smoother FSSAI inspections and audits- Businesses with organised records face fewer queries, delays, or penalties during license renewal or surprise inspections. Improved buyer and export confidence- Large retail chains, export buyers, and institutional clients increasingly expect FIFO/FEFO discipline and clean documentation as part of vendor selection. Foundation for future certifications- These practices align closely with HACCP, ISO 22000, and other recognized food safety standards, making it easier to pursue certifications later. Lower risk of penalties- Proactive compliance reduces the chances of license suspension, cancellation, or fines due to missing or disorganized records. Stronger internal control- clear separation of data helps management track production efficiency and raw material costs more precisely, supporting better business decisions. Right Decision or Additional Burden? This is a fair question that every food business owner is asking. The Case for the Right Decision The rule targets real, known risk areas, expired stock reaching consumers and untraceable production data both of which have caused food safety issues in India before. FSSAI has deliberately exempted non-manufacturers and retailers, showing the rule is proportionate rather than a blanket burden. FIFO/FEFO and separated records aren't new concepts either; most organized food businesses already follow some version of this informally, and the rule makes it a formal, enforceable requirement. The Case for Additional Burden Small and medium manufacturers without digital systems will need to invest time, and possibly money, in setting up proper record-keeping. There is no transition period, meaning businesses must comply immediately with limited preparation time. Physical redesign of storage areas for FIFO/FEFO can also involve real cost for businesses with large or complex inventories. The Balanced View Overall, this amendment leans more toward being a right regulatory decision than an unnecessary burden, because it directly targets food safety and traceability while keeping small non-manufacturing players and retailers exempted. The main challenge for businesses is the speed of compliance required, not the substance of the rule itself. Business Opportunities Created Every new compliance requirement also opens the door for new business and service opportunities. FSSAI compliance consulting and documentation support firms, inventory and warehouse management software providers, barcode/QR-based batch tracking system vendors, staff training and certification institutes, warehouse and storage rack solution providers, and food safety auditors can all find growing demand as businesses race to align with this amendment. Food businesses that act early and set up strong systems now will not only stay compliant but can also position themselves as more trustworthy suppliers to large retailers, exporters, and institutional buyers who prefer working with organized, well-documented vendors. Corpseed's Core Message Regulatory changes like the FSSAI Second Amendment Regulations, 2026, are not meant to slow businesses down; they are meant to build a safer, more transparent food ecosystem in India. The good news is that this amendment is practical, targeted, and workable, with sensible exemptions for smaller and non-manufacturing businesses. At Corpseed, our message to every food business is simple: don't wait for an inspection to discover a compliance gap. Understand exactly which part of this amendment applies to your business, set up your record-keeping and FIFO/FEFO systems correctly, and treat this as an opportunity to strengthen your food safety credibility, not just as another government formality. Whether you need help understanding your FSSAI license conditions, setting up compliant documentation systems, or getting expert guidance on the latest FSSAI regulations, staying proactive today is always cheaper and easier than fixing violations tomorrow.
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