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· State License: A state license is required for FBOs whose annual turnover is between INR 12, 00,000 to INR 20,00,00,000.

· Central License: The Central license is granted to those FBOs whose annual turnover is above INR 20, 00, 00,000. Additionally, FBOs having outlets/ units in two or more states are also required to obtain a central license along with the separate licenses from the local authorities."
    }
  },{
    "@type": "Question",
    "name": "What is the procedure for obtaining a food license?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "No undertaking, whose annual turnover is above INR 12,00,000, shall commence any food business unless they possess a valid food license. An application for a valid food license shall be made in terms of a form prescribed under the FSS (Licensing & Registration) Regulations, 2011 along with the applicable fee. The said form shall be accompanies by a self-attested declaration affirming that the food business is in accordance with the prescribed standard, laws and hygiene and sanitary practices. Additionally, the FBO is also required to enclose eighteen other documents with the application including details of the area in which the operation would be conducted, authority letter, analysis report of the water being used as an ingredient in the food business etc."
    }
  },{
    "@type": "Question",
    "name": "What are the kinds of compliances a ‘re-labeller’ or ‘re-packers’ of food products is required to adhere to?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "A Re-labeller and re-packer are the ones who do not hold any manufacturing premise or operations of their own but who takeover products from such manufacturing units and further attach their own brand’s identity to it. As per the FSS Act, a re-labeller and a re-packer are deemed manufacturers, thereby they too are required to obtain license similar to that for all FBOs."
    }
  },{
    "@type": "Question",
    "name": "What are the types of complaints/Grievance that can be addressed to the FSSAI or State Authorities?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "Any person can file complaints with respect to violation of the provisions of FSS Act and Regulations, Food Adulteration/poisoning, Misleading labelling, packaging, advertisements, Sub-standard quality of food products, Licensing and registration related grievances, Counterfeit products, Unhygienic Conditions and malpractices by FBOs, Complaints against enforcement officers of States and Centre, Unauthorized use of food ingredients etc."
    }
  },{
    "@type": "Question",
    "name": "What are the kinds of packaging and labelling requirements each FBO is required to maintain?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "While different types of foods demand very specific types of packaging and labelling requirement, there are a few factors which shall be kept in mind for all kinds of food products. They are as follows:

· All containers shall be securely packed and sealed;

· The exterior of the cans shall be free from major dents, rust, perforations and seam distortions;

· The packaged cans shall be free from leaks.

· The label must not contain information about the food that could be deemed to be false, misleading, and deceptive or otherwise create an erroneous impression regarding the product.

· The label must contain nutritional information about the products such as energy value in ‘kal’, the amounts of protein, carbohydrate (specify the quantity of sugar) and fat in ‘gram’ or ‘ml’ and lastly, the amount of any other nutrient for which a nutrition or health claim is made.

· The label(s) of the food product must also contain the following:

Ø Vegetarian or non-vegetarian symbol.

Ø Information Relating to Food Additives, Colours and Flavours

Ø Name and Complete Address of the Manufacturer

Ø Net Quantity

Ø Lot Number of Batch Identification

Ø Date of Manufacture or Packing

Ø Country of Origin for Imported Food.

Ø Instructions for Use"
    }
  },{
    "@type": "Question",
    "name": "What kind of advertisement claims are strictly prohibited under the law?",
    "acceptedAnswer": {
      "@type": "Answer",
      "text": "The following advertisement claims which are strictly prohibited by law:

· Claims made which refer to the suitability of the food for use in the prevention, alleviation, treatment or cure of a disease, disorder or particular physiological condition unless specifically permitted under any other regulations;

· Label of any package, containing any words which imply or suggest that the food is recommended, prescribed, or approved by medical practitioners or approved for medical purpose.;

· Claim of “added nutrients”, if such nutrients have been added merely to compensate the nutrients lost or removed during processing of the food ;

· Advertisements or claims for articles of foods by any FBO that undermines the products of any other manufacturer for the purpose of promoting their products or influencing consumer behavior.

Additionally, all FBOs are required to seek approval from the FSSAI for reduction of disease risk claims."
 }
 }]
}
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We advise domestic and foreign enterprises on packaging requirements in consumer goods, food products, and other items based on The Food Safety and Standards Act, 2006, The Legal Metrology Act, 2009 and Legal Metrology (Packaged Commodities) Rules, 2011.

We review and analyse the labels of various products to ensure compliance with the fundamental laws. We also assist in registration as an importer/manufacturer, registration of labels, and other regulatory compliances prescribed under the various acts.

We also counsel on misleading advertisements in case it is not in accordance with the Advertising Standards Council of India Code in the food and beverages sector amongst others. We further aid and advice clients in securing registrations and compliance management for manufacturing, advertising, selling and branding drugs, cosmetics, Ayurvedic, Unani and other medicinal preparations under the Drugs and Cosmetics Act, 1940.

We also provide legal advice and compliance strategies to clients who are engaged in virtual business through e-commerce platforms and cyberspace.

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