Muhammad Salman Chukkan*

Jibin Balu MT*

As per the section 31 of Food Safety Standards Act 2006 ‘No person shall commence or carry on any food business except under a licence’.FSSAI always had ensured to have system in place for licensing or registration. Earlier the licensing procedure was done manually but lately it was completely moved into online system. The online system was initially on a portal called Food Licensing and registration system (FLRS) to cater the activities related to licensing of Food Business Operators (FBOs), but now FSSAI use a system called Food Safety and Compliance System (FoSCoS) 

FoSCoS is an enhanced and improved Licensing and Registration portal of  FSSAI . The FLRS system over a period became slow  due to fact that the technology was outdated, thus it was imperative to create a new easily accessible, user-friendly and an Integrated system for the Licensing of Food Business, which led to the advent of FoSCoS. 

Most often, the process of licensing turns out to be a disaster from the perspective of a FBO, majorly attributing to the erroneous and improper application filed by an FBO due to negligence, confusion and being uninformed about the Regulations and the system itself. This article is therefore aimed at imparting the basic yet needful guidance, providing detailed information about each document based on the Kind of Business (KOB). KOB is nothing but a definitive type of business a FBO is engaged with.

Now, let’s have a look into the process in detail.

General Guidelines while applying for a license:

  • Never rush while applying, this may create Typographical errors.
  • Always submit a legible and clear document.
  • Photocopied documents shall be self-attested.
  • Submit the updated document.
  • Never provide fake information.
  • Always compare all documents and check for uniformity in data.Example :Address, Name etc
  • Never submit a fabricated or forged document, this may lead to rejection of application by the Designated Officer(DO).
  • Before applying for any License, try to go through the KOB Eligibility Document provided in the FoSCoS website. Inorder to understand the KOB and Eligibility i.e. Central License or State License or Registration. It is important to stick with the eligibility document as a mistake may stand your application rejected.

( https://foscos.fssai.gov.in/assets/docs/KindofBusinessEligibilityLatest.pdf )

  • Understand the Product Standards and Regulations.This also helps to understand the KOB.
  • Check the updated list of documents for respective KOBs. (https://foscos.fssai.gov.in/home-document )
  • Refer this link (https://foscos.fssai.gov.in/home-document) for the state specific documents (if any)
  • Documents with an asterisk symbol, shall be submitted on letterhead.(Fig.1)
  • After filing, if the Authority reverts the query try to resolve at the earliest inorder to expedite the licensing procedure.
  • A FBO’s premise shall have only one FSSAI License or Registration on which any number of kind of businesses (KoB) can be endorsed.
  • If you encounter with any queries, you may contact the FoSCoS helpline 1800112100 or helpdesk-foscos@fssai.gov.in
  • If you don’t know how to file an application, try to get help from a Food Safety Mitra (Digital Mitra) to file the application for you. (A FSSAI initiative for helping FBOs) (https://mitra.fssai.gov.in/mitra/loadIndexData)

List of Documents and guidelines for the same: 

 The below listed documents are applicable for all sort of KOB:

(Common documents irrespective of KOBs)

  1. List of Directors/Partners/Proprietor/Executive Members of Society/Trust with full address and contact details with nomination of authorized signatory.
    1. Mention their Full Name, Contact Details and address on the letterhead firm.
  2. Photo I.D and address proof issued by Government authority of Proprietor/Partner/Director(s)/Authorized Signatory.
    1. A proof with an address being mentioned on it. Aadhar suffices the requirement.
  3. Proof of possession of premises. (Sale deed/ Rent agreement/ Electricity bill, etc.)
    1. Exact address as being mentioned on the Application.
    2. Latest Document if available.
    3. If the Proof of premise is not in the name of Firm or Authorized personals of the firm, the proof of premise shall be accompanied by a No Objection Certificate.
    4. If the Proof of premise is in Regional Language, while applying for Central License can be submitted along with the Self-attested Translation of the same.
  4. Partnership Deed/Self Declaration for Proprietorship/Memorandum & Articles of Association towards the constitution of the firm / Copy of certificate obtained under Coop Act-1861/ Multi State Coop Act-2002 in case of Cooperative.
    1. Proprietorship Firm shall submit a self-declaration as per:

                        ( https://.fssai.gov.in/PDF/SelfDeclarationforProprietorship.pdf )

  1. Form IX: Nomination of Person as per Clause 2.5of FSS Rules, 2008:
    1. Not required for a Proprietorship Firm.
    2. The name of the nominee shall be the same both in Form IX and Form B.
    3. The document shall be signed by the nominee and then signed by the authorized personnel.
  2. Recall Plan:
    1. A detailed Recall plan shall be submitted along with the details of the Recall Management Team.
    2. Refer the below link for further clarification

     (https://fssai.gov.in/upload/uploadfiles/files/Guidelines_Food_Recall_28_11_2017.pdf)

The below listed documents are applicable for all sort of Manufacturing KOB:

  1. Blueprint/layout plan of the processing unit showing the dimensions in meters/square meters and operation-wise area allocation
    1. Legible and clear Layout.
    2. Mention the dimensions in meters/square meters.
    3. State operation-wise area allocation (Production, Quality, Storage, etc.).
    4. Name and address of premises should be mentioned on the blueprint and matching with form B.
  2. Name and List of Equipments and Machinery along with the number, installed capacity and horsepower used
    1. Number of each equipment (If different products are made in same premise, make separate lists of equipment for each product)
    2. Installed capacity (MT/ Day or MT/Hr)
    3. Horsepower used.
    4. Note: Capacity declared in application should be justifiable/ matching with machinery.
  3. Water Analysis Report:
    1. IS 10500 test of products with water as an ingredient/IS 14543 for Packaged Drinking Water and Mineral Water and similar products wherever standards apply.
    2. Report shall not be older than 6 months.
    3. Test report shall be from a FSSAI recognized and NABL accredited laboratory.
    4. The Lab shall have both Biological and Chemical as a scope of testing from NABL.
    5. Sample shall be drawn by the Authorized representative lab and Name of the representative shall be mentioned on the report.
    6. An opinion regarding the conformance of the sample with the IS 10500/IS 14543 (as required) shall be there on the report.
    7. Note: If water is not an ingredient, it shall be justified and a self-declaration regarding that shall be submitted.

  1. Production unit photograph
    1. The photographs of Entrance with Board,Processing lines, Laboratory (If any).
    2. Note: Preferably, compile all photographs into a single pdf not exceed the limit of 3MB.
  2. Repacker Declaration and NOC for both Repacker and Relabeller from the Manufacturer (Only applicable for Repacker business)
    1. Submit a Repacker declaration

 (  https://foodlicensing.fssai.gov.in/PDF/DeclarationforFBO.pdf )

  1. A NOC from the Manufacturer of the product on their letterhead with license copy attached.
  1. NOC from CGWA for FBO who draws Groundwater (Wherever applicable)
  2. Ingredient and Additive Statement (Only for KOB- Proprietary Food & KOB- Food or Health Supplements and Nutraceuticals) (Fig.2)

(https://foscos.fssai.gov.in/public/assets/docs/FLRS2016002691.pdf )

  1. KOB-Proprietary Food
    1. Furnish generic name of the product. Not the Brand name. The name shall give a clear sense with respect to product.
    2. Quote nearest food category as per Food Safety & Standards Regulation (FSSR). Refer : I. FOOD CATEGORY DESCRIPTIONS in FSS(Food Product Standards & Food Additive) Regulation, 2011.
  • Quote FSSR reference of ingredients and limit of additives used (If So).
  1. Specify names of flavours (For Example Artificial Flavouring Substance-Apple) and list it under additives.
  2. Name of the product mentioned in form b should be the same as that of attachment.
  3. Different products shall have separate entries.
  1. KOB-Food or Health Supplements and Nutraceuticals
    1. Refer the Draft FSS(Nutra) 2022.This draft regulations are operationalized by order.
    2. Write the specific name of the product and type of product for ex: Amylase and VitaminE capsule (Health Supplement), Astaxanthin multivitamin Tablet. (Nutraceutical)
  • Quote nearest food category of the article as per FSSR. (Ex. 13.6 for Health Supplement, Nutraceuticals etc)
  1. Quote FSSR reference for every ingredient.
  2. State an actual component used as a source of vitamin/ minerals. (For example: Vitamin B12, Cyanocobalamin). Also, Vitamins and Minerals shall not be added more than RDA(unless specifically allowed)
  3. Enter the corresponding schedule and serial number against every ingredient and additives, whichever is applicable. (For example. Glucosamine Sulphate – Schedule 3/Part A/ Sr. no. 19)
  • State exact portion or part of Botanical used. For example instead of Tulsi Powder, you need to specifically mention Tulasi Leaf Powder, Tulasi Seed powder. (State level and limit)
  • If adding, specify Names and types of Flavours (For Example Artificial FlavouringSubstanceOrange)
  1. Specify the QUANTITY of nutrients added wherever applicable and verify that the quantity of added nutrients shall not exceed the recommended daily allowance as specified in the Nutraceutical regulations.
  2. If available, furnish purity of ingredients.

The below listed documents are applicable for specific business:

As per specific provisions and requirements specified in the Food Safety and Standard Regulations and Orders.

  1. 100% Export Unit shall submit the Certificate from the Ministry of Commerce.
  2. Packaged Drinking Water and Packaged Mineral Water shall submit BIS application letter or License.
  3. AGMARK certificate for Multi Source Edible Oil.
  4. Export Manufactures shall submit a documents:
    1. A declaration and specification as below:
  5. Name(S) of the country to which the products are exported.
  6. Copy of specifications of products of the importing country that imports the products.
  7. List of ingredients and additives of each product and whether products meet FSSAI standards.
  8. Declaration from FBO to follow standards/specifications of importing countries and not to sell/supply them in the domestic market for consumption in case the product does not meet FSSAI standards.
  9.   IE code issued by DGFT.                    
  10. Dairy Processing: A procurement plan or source of milk on letterhead.

  1. Meat Processing:
  2. Source of Raw Material on letterhead.
  3. No objection Certificate from Local Body/Municipal Corporation.
  4. Slaughter House:
  5. No objection Certificate from Local Body/Municipal Corporation.

  1. Manufacturer – Non-Specified Food
  2.      Approval for the product from FSSAI, HQ (Prerequisite for license)
  3. Vegetable Oil Processing Unit:
  4. As per Annexure 3/Other conditions/ Serial Number 4/No producer or manufacturer of vegetable oil, edible oil and their products shall be eligible for license under this Act, unless he has own laboratory facility for analytical testing of samples in his premises.List of equipment in the lab shall be submitted along of with the list of equipment document. Photographs of the lab shall also be submitted.

The below listed documents are applicable for Non Manufacturing KOBs:

  1. Importer:
  2. IE code issued by DGFT.
  3. Transporter:
  4. List of Vehicle registration numbers on letterhead.
  5. Exporter-Merchant:
  6. IE code issued by DGFT.
  7. Submit undertaking from Exporting FBO in specified format:.

(https://foodlicensing.fssai.gov.in/PDF/MerchantExpoter_Undertaking.pdf)

  1. Wholesale/Retail/Distributor/Storage:
  2. Submit a self-declaration on letterhead regarding the eligibility.

                        (https://foscos.fssai.gov.in/assets/docs/KindofBusinessEligibilityLatest.pdf)

  1. E-commerce:
  2. Submit a Declaration for Ecommerce FBO under Category 14 (Beverages excluding dairy products) (Refer: https://foscos.fssai.gov.in/home-document and find the draft format for the same) (Fig.3)

By following the above mentioned guidelines any one can apply and receive their application with ease. These guidelines would be helpful for the FBOs to get empowered. 

Acknowledgement:

I would like to thank the FSSAI Western Region family for their contribution in making the in-house comments for FoSCoS for faster application processing, from which I have taken inspiration for this article. 

Note:

Kindly consider this as a guidance document. If you have any queries kindly  contact the author on LinkedIn www.linkedin.com/in/chukkansalman or over e-mail foodenggsalman@gmail.com .

 Technical Officer,  FSSAI*