FSSAI invites public comments on labelling and compliance standards for 'Analogue in Dairy Context' products

The Food Safety and Standards Authority of India (FSSAI) has released a consultation paper inviting public comments and stakeholder suggestions regarding the compliance provisions for products classified as ‘Analogue in the dairy context’. The move aims to address concerns about consumer deception due to misleading labelling and representation of such products as genuine dairy items.

Background

Recent media reports have highlighted the increasing sale of dairy analogues—products that resemble dairy but are made wholly or partly with non-milk constituents—being misrepresented and sold as authentic dairy products. To ensure consumer protection and transparency, FSSAI had earlier defined labelling norms for dairy analogues under its existing regulations. In light of these developments, FSSAI convened a stakeholder meeting on 7 April 2025 at FDA Bhawan, New Delhi, attended by 57 representatives from industry associations, consumer organizations, and MSMEs. Additional consultations with the HoReCa (Hotels, Restaurants, Catering) sector were also held in March 2025.

Regulatory Framework

FSSAI regulations clearly distinguish ‘Analogue in the dairy context’ from actual dairy products.

Definition:
Under sub-regulation 2.1.1(1) clause (aa) of the Food Safety and Standards (Food Product Standards and Food Additives) Regulations, 2011,states, "Analogue in the dairy context’ means a product in which constituents not derived from milk take the place, in part or in whole, of any milk constituent(s) and the final product resembles, organoleptically and/or functionally, milk or milk product or composite milk product as defined in these regulations”.

Labelling Norms:

1. Ingredient Declaration:

   • If a non-milk ingredient substitutes a milk component: The label must read “Contains [name of non-dairy ingredient]”.

   • If the product contains no milk: The label must declare “Contains no milk [name of non-dairy ingredient]”.

2. Usage of Dairy Terms:

   • Dairy terms like "milk", "cheese", "cream", etc., cannot be used on products that are not actual dairy items.

   • Such terms may only appear in the ingredient list if dairy ingredients are present but not characterizing the product.

3. False and Misleading Presentation:

   • Pre-packaged foods must not present labels that are false or misleading regarding the product’s character, as per Labelling & Display Regulations, 2020.

4. HoReCa Sector Compliance:

   • Food service establishments must display notice boards clearly indicating the nature of food items being served, especially when analogues are used in place of dairy products.

Key Proposals for Public Consultation

FSSAI seeks feedback on the following suggestions:

1. Terminology on Labels:
   Should prefixes like "Non-dairy" or "Analogue" be mandated before dairy terms in analogue products?

2. Ingredient List Declaration:
   When dairy analogue is used in composite foods (e.g., cheese analogue in pizza), it must be listed with clear labelling such as:
   Ingredients – Analogue of Cheese (Milk Solids, Palm Oil, Modified Starch, etc.)

3. Clarity in Food Service (HoReCa):
   Restaurants and food outlets must clearly mention if dairy analogue is used, such as “Non-dairy Paneer” in menu items like Kadhai Paneer.

4. Ban on Loose Sale:
   Dairy analogues should only be sold in sealed, pre-packaged formats of not less than 500 grams, bearing proper labels.

5. Licensing Restrictions:
   It is proposed to disallow FSSAI Registration for small-scale manufacturers (under ₹12 lakh turnover or 100 kg/day capacity) of dairy analogue products. Only State or Central licensing will be permitted for better regulatory oversight.

The initiative underscores the importance of protecting consumers from misleading information and ensuring they are equipped to make informed choices. By emphasizing clear and consistent labelling—particularly in the expanding market of dairy analogue products—FSSAI aims to enhance both consumer safety and regulatory transparency.

Public Participation - Google form for providing comments/ suggestions

FSSAI invites stakeholders, industry representatives, and members of the public to share their views and suggestions on the proposed measures. Comments can be submitted through the Google Form within 60 days of the release.

📄 Google Form URL:
https://docs.google.com/forms/d/e/1FAIpQLSdFNX8oXlbhlj_PJ1CQIIpmsSmn-MP-ftbtWINrVnqRGOnnzQ/viewform?usp=header
🔗 Short URL: https://forms.gle/o1yh2vCmMs7XvgEK8