An FPO moving from produce aggregation to packaged food should review the entire activity, not only the brand name on the pouch. Manufacturing, packing, storing, transporting and marketing may involve different people and premises. Write down who does what, where it happens and who places the product on the market.
Start with the actual activity
Describe the product, ingredients, process, daily capacity, locations and sales channels. Identify any outside processor, warehouse or brand owner. Use FSSAI's official regulations directory and FoSCoS portal to verify the applicable registration or licence route and documents. Do not choose a category solely from an old turnover chart or another business's certificate.
Keep a dated compliance worksheet showing the requirement, source, responsible person and evidence. Where classification is uncertain, obtain written clarification from the competent authority or a qualified adviser before investing in printed packs or accepting orders. A consultant's assurance is not the same as an issued permission.
Create one product file
Include the recipe or specification, raw-material suppliers, process flow, packaging specification, testing plan and approval records. Ask a qualified food technologist about hazards relevant to the product, the controls needed and how shelf life should be supported. Avoid choosing an expiry period because a competing product uses it.
Record changes to ingredient source, recipe, processing or pack material. A change that appears small commercially can require a fresh technical or label review. Assign a person who can stop dispatch when the product's status is unclear.
Review the label as a compliance document
FSSAI's Labelling and Display Regulations compendium covers pre-packaged food information. Depending on the product and applicable exemptions, review product identity, ingredients, allergen and nutrition information, responsible-business details, licence information, quantity, batch and date declarations, and storage or use instructions. Also check applicable Legal Metrology requirements and subsequent amendments. This list is a review prompt, not a complete legal label specification.
Use the final pack dimensions when checking readability. Verify every number and claim against evidence. Do not add organic, disease-treatment, immunity or nutritional claims merely because they help marketing. Have the finished artwork reviewed before a large print run.
Prepare for the first batch
Make a batch record linking input lots, production date, process checks, packing quantity and dispatch destination. Agree who releases the batch, which evidence they check and how rejected goods are separated. Ensure staff understand cleaning, personal hygiene and the controls established for the particular operation.
For an illustrative outsourced flour product, the FPO should be able to identify the processor, received grain lots, finished batch, pack version and customers supplied. If a customer complains, this chain helps locate the affected material rather than guessing which bags were sold.
Build a response routine
Give customers a working complaint contact. Log product, batch, purchase details and the concern. A suspected safety issue needs prompt assessment, containment and the applicable reporting or recall procedure; do not simply replace the packet and erase the record. Keep personal information accessible only to authorised staff.
Does a licence mean every product claim is approved? No. Verify the product, process, labelling and claims under the relevant requirements separately.
Can we outsource all responsibility? Put responsibilities and evidence-sharing in the contract, but verify the duties that still apply to your own role. Do not assume another unit's certificate covers every activity of the FPO.
This is a preparation guide. Confirm the current product-specific requirements with the competent authority before launch.
Sources & further reading
- FSSAI: Food Safety and Standards Regulations directorySource checked: 2026-10-23
- FSSAI: Labelling and Display Regulations compendium, September 2025Source checked: 2026-10-23
- FSSAI: FoSCoS official portalSource checked: 2026-10-23
Prepared with AI assistance for the CAFIC knowledge series. Examples are illustrative. Check current official requirements and local conditions before acting on regulatory or technical guidance.
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