This issue of LexCognito, which in Latin means 'awareness about law', seeks to provide you an insight into significant legal and regulatory developments that have taken place very recently in India.

Date: 14 June 2021
Lex Cognito: Food business operators to mandatorily declare FSSAI License Number on their invoices
The Food Safety and Standards Authority of India (“FSSAI”) vide its latest order dated 8th June 2021, has mandated food business operators to mention the 14-digit FSSAI license number or registration number on cash receipts or purchase invoice with effect from 1st October 2021.

Section 31 of the Food Safety and Standards Act, 2006 (“Act”) mandates that every food business operator is required to obtain FSSAI license or registration prior to commencing any food business.

FSSAI under its order mentioned that since the food business ecosystem is large, therefore the 14-digit FSSAI number of any food business operator is not "easily visible and available on consumer/service recipient. If the FSSAI number is not available to consumers, expecting them to complain with complete coordinates is an uphill task. Even regulators find it difficult to trace the origin of the complaint and attend to it promptly with approximate addresses. It further said that no database can be created without a unique locator code, which in the case of food safety is the FSSAI number.

Presently, FSSAI number is compulsory to be displayed on packaged food labels but the issue lies especially in the case of establishments such as restaurants, mithai shops, caterers, even retail stores. Further, the FSSAI said that it is amending the Food Safety and Standards (FSS) Licensing and Registration of Food Businesses Regulations to mandate the display of 'food safety display boards at all times at prominent places in case of restaurants. However, there remains a deficit of mechanism for consumers to know the FSSAI number of the service/product provider. It also mentioned that even in the case of pre-packaged food where the manufacturer's FSSAI number is printed on the pack, there exists a deficit of tract and trace mechanism whereby the path of the package from a manufacturer to the consumer can be traced.

Key highlights:
  • It shall enable the consumers to have access to information about a particular business that is publically available at FSSAI’s portals. Consumers can visit the FSSAI’s portal and ‘Food Safety Connect’ app for accessing information about FSSAI License or registration by inputting the 14-digit FSSAI License/ Registration number.
  • In case of any grievance, a consumer can lodge an online complaint against a particular food business using the FSSAI number and this will help in addressing the complaints which used to remain unresolved due to lack of specific information.
  • Mentioning the FSSAI number shall also improve the overall awareness. If not mentioned, it will indicate non-compliance or non-registration/licensing by the food business.
  • Even in the case of pre-packaged food where the manufacturer's FSSAI number is printed on the pack, there exists a deficit of tract and trace mechanism whereby the path of the package from a manufacturer to the consumer can be traced. The invoice will help in establishing this trail. Mentioning of FSSAI number will help in improving traceability for food products.
Therefore, basis this order of FSSAI, the food businesses are required to mention FSSAI License or Registration number on cash receipts/ purchase invoices/ cash memos/bills etc. Licensing and registration authorities are directed to widely publicize the policy and shall ensure its implementation mandatorily with effect from 1st October 2021.
CHRI Comment

This positive move by FSSAI will help the consumers to lodge an online complaint against a particular food business using the FSSAI number, which earlier used to remain unresolved due to lack of specific information. Further, mentioning the FSSAI number will also improve the overall awareness, improve the traceability for food products, and will indicate non-compliance or non-registration/licensing by the food business operators.
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Chambers of Rajan & Indraneel 
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Chambers of Rajan & Indraneel is a premier full service law firm headquartered at New Delhi, India. The Firm represents amalgamation of vast experiences and practices of two eminent lawyers. Indranil Ghosh is highly reputed as a disputes lawyer. He was a senior partner and head of litigation practice in one of the oldest Indian law firm Fox Mandal for several decades before setting up his own practice. Rajan D Gupta is a rank holder Chartered Accountant turned Corporate Lawyer. He is also a licensed Insolvency Resolution Professional. He has been associated with internationally renowned big law firms in past and has held senior level positions in firms like PwC, Fox Mandal, Khaitan & Co. and SRGR Law, etc. before starting the Firm.

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This newsletter contains general information available in public domain at the time of its preparation. It is intended as a general news update and is not intended to be comprehensive nor to provide specific business, financial, investment, legal, tax or other professional advice or opinion or services. This newsletter is not a substitute for such professional advice or services, and it should not be acted on or relied upon or used as a basis for any decision or action that may affect you or your business. Before making any decision or taking any action that may affect you or your business, you should consult a qualified professional adviser and refer to the source pronouncement/documents on which this business alert is based. It is also expressly clarified that this newsletter is neither a solicitation nor an invitation of any sort whatsoever or a source of advertising from our firm or any of its partners or lawyers or other professionals to create any adviser-client relationship. Whilst every effort has been made to ensure the accuracy of the information contained in this news alert, this cannot be guaranteed, and neither our firm nor any related person/entity shall have any liability to any person or entity that relies on the information contained in this publication. Any such reliance is solely at the user's risk.
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