The Food Safety and Standards Authority of India (‘FSSAI”) has issued a Consultation Paper on compliance with provisions of ‘Analogue in Diary Context’ and invited comments/ suggestions from stakeholders in the Google Form (https://docs.google.com/forms/d/e/1FAIpQLSdFNX8oXlbhlj_PJ1CQIIpmsSmn-MP-ftbtWINrVnqRGOnnzQ/viewform?usp=header) by 15th June 2025.
The Food Safety and Standards (Food product Standards and Food Additives) Regulations, 2011 define Analogue in diary context as 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”. For labelling pre-packaged analogues the regulation mandates declaring non-milk constituents and stating the absence of replaced milk constituents. Additionally, the regulation also clarifies that dairy analogues must not be classified as milk products and prohibits using dairy terms for non-dairy products (unless referencing non-essential milk constituents in ingredients). Under Food Safety and Standards (Licensing & Registration of Food Businesses) Regulations, 2011, Food Business Operators (“FBOs”) selling cooked or prepared food shall display a notice board containing the nature of articles being exposed for sale.
In view of the existing provisions of regulations, public are invited to submit their comments on the following suggestions
- Whether words like ‘Non-dairy’ or ‘Analogue’ can be used as prefix to the dairy terminology on the label of the product.
- Whether Dairy analogue used in pre-packaged food product as an ingredient must clearly mention the nature of the ‘Dairy analogue’ in the ingredient list.
- Restaurants, caterers, and other food service establishments serving cooked and prepared food must clearly indicate the exact nature of food items on menu cards or boards or booklets or other relevant materials which are readily legible to the consumers
- Prohibition in sale of ‘Analogue in dairy context’ in loose form. Analogue must only be sold in packed condition not less than 500 grams with proper labelling declaration
- It is also suggested to restrict grant of FSSAI registration for FBOs manufacturing Dairy Analogue to curb misuse of dairy analogue as dairy products
A copy of the Notification is hyperlinked below for your ease of reference.
Source: The Food Safety and Standards Authority of India
