In Short
Food safety practice covers licensing, labelling and compliance obligations under the Food Safety and Standards Act, 2006, administered by the FSSAI. S&S Co. advises food business operators — from manufacturers to restaurants and e-commerce food platforms — across Noida, Delhi NCR and Kolkata, and represents clients in enforcement and adjudication proceedings.
What This Practice Covers
The FSSAI regulates food businesses through a licensing and registration framework tiered by turnover, alongside labelling, packaging and safety standards. The framework changed significantly in 2026: the Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, effective 1 April 2026, granted perpetual validity to licences and registrations issued thereafter, ending the previous one-to-five-year renewal cycle, introduced deemed registration for street food vendors, and moved to a risk-based inspection and audit framework.
The trade-off for perpetual validity is strict ongoing compliance — a single missed annual fee payment now triggers automatic suspension without notice. Food business operators across Noida, Delhi NCR and Kolkata need a disciplined annual compliance calendar rather than relying on the old renewal-reminder cycle.
Forums We Appear Before
FSSAI Adjudicating Officer — state-level
Food Safety Appellate Tribunal
Delhi High Court — FSSAI writ matters
Calcutta High Court — FSSAI writ matters
Consumer Disputes Redressal Commissions — food safety complaints
Judicial Magistrate courts — Food Safety Act prosecutions
Our Food Safety & FSSAI Services
- FSSAI licensing & registration — advisory on the correct licence category (Registration, State, or Central) based on turnover.
- Compliance audits — reviewing labelling, packaging and safety practices against current FSSAI regulations.
- Show-cause & adjudication defence — representing food business operators in FSSAI enforcement proceedings.
- Labelling & FOPNL advisory — guidance on front-of-pack nutrition labelling and other disclosure requirements.
- Food Safety Appellate Tribunal representation — appeals from adverse adjudication orders.
- Product recall advisory — advising on regulatory obligations in the event of a recall or contamination issue.
- E-commerce food platform compliance — advisory for online food delivery and grocery platforms.
Responding to an FSSAI Enforcement Action
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Notice Review
We review the show-cause notice or inspection report and assess the underlying compliance gap.
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Corrective Response
We draft a reasoned response, supported by corrective action taken, to the adjudicating authority.
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Adjudication Hearing
We represent the client at the hearing before the Adjudicating Officer.
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Appeal
Where the order is adverse, we appeal to the Food Safety Appellate Tribunal.
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Ongoing Compliance
We help establish an annual compliance calendar to avoid recurrence, particularly around the new perpetual-licence fee obligations.
Illustrative Scenarios
The following are hypothetical, illustrative scenarios prepared for educational purposes. They are not descriptions of actual client matters, and no outcome is guaranteed in any specific case.
Illustrative Scenario
Restaurant Chain Facing Suspension for a Missed Annual Fee Payment in Noida
A Noida restaurant chain's perpetual FSSAI licence is automatically suspended after a missed annual fee payment goes unnoticed amid a busy expansion. Prompt corrective filing, backed by a clear compliance calendar going forward, is typically the fastest path to restoring the licence and avoiding repeat suspension.
Illustrative Scenario
Food Manufacturer Contesting a Labelling Non-Compliance Notice in Kolkata
A Kolkata packaged food manufacturer receives a show-cause notice alleging non-compliant nutritional labelling. A response grounded in the specific regulatory requirement and the manufacturer's actual label content — with corrective relabelling where a genuine gap exists — can resolve the matter without escalation to formal adjudication.
Illustrative Scenario
E-Commerce Food Platform Facing a Labelling Compliance Notice
An e-commerce grocery platform operating out of Noida receives an FSSAI notice alleging non-compliant nutritional labelling across multiple private-label products. A centralised label-compliance audit across the full product catalogue — rather than responding product-by-product — is typically the faster and more defensible route to resolving a multi-product notice.
Illustrative Scenario
Restaurant Chain Expanding Into Kolkata Navigating Multi-State Licensing
A restaurant chain expanding from Delhi NCR into Kolkata must navigate separate FSSAI licensing and state-specific compliance requirements for its new outlets. Early engagement with a compliance checklist tailored to West Bengal's specific requirements avoids launch delays that a generic pan-India compliance approach might miss.
Notable Judgments
FSSAI NotificationApr 1, 2026
Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026
FSSAI Licences Become Perpetually Valid — Renewal Cycle Scrapped, Street Vendors Get Deemed Registration
Notified on 10 March 2026 and effective 1 April 2026, the amendment grants perpetual validity to FSSAI licences and registrations issued thereafter, ending the one-to-five-year renewal cycle; introduces deemed registration for street food vendors; brings in a risk-based inspection and food-safety-audit framework; and revises turnover thresholds — basic registration up to ₹1.5 crore, State Licence between ₹1.5 crore and ₹50 crore, and Central Licence above ₹50 crore.
Key Takeaway — Renewal deadlines disappear, but the trade-off is strict — a single missed annual fee payment now triggers automatic suspension without notice, so FBOs need a disciplined annual compliance calendar in place of the old renewal reminder.
Parliamentary Standing CommitteeJul 2026
Standing Committee on Consumer Affairs, Food & Public Distribution — Report to Parliament
House Panel Presses FSSAI to Notify Front-of-Pack Labelling Rules After Four-Year Delay
A parliamentary standing committee report tabled in Parliament expressed being "dismayed" that the draft Front-of-Pack Nutrition Labelling (FOPNL) Regulations — first notified in September 2022 and attracting over 14,000 stakeholder comments — remain pending, and recommended clear, colour-coded "at-a-glance" warning labels for products high in sugar, salt, or fat, together with tighter monitoring of packaged foods sold via e-commerce.
Key Takeaway — FBOs should prepare now for interpretative front-of-pack warning labels — both legislative and judicial pressure are converging to force FSSAI's hand on a long-delayed reform.
FSSAI — First Amendment RegulationsMar 30, 2026
Food Safety and Standards (Labelling and Display) First Amendment Regulations, 2026
FSSAI Tightens Rules on "Natural" Claims, Nutrition Disclosures and Infant Nutrition Labelling
Notified on 24 March 2026 and set to take force from 1 July 2027, the amendment revises the 2020 Labelling and Display Regulations across several fronts: infant nutrition products are exempted from disclosing per-serve %RDA contribution and servings-per-pack; packages up to 100 sq. cm no longer require the FSSAI logo (though multi-unit packs still must carry it); and limits are reinforced on misleading "100% natural" and similar marketing claims.
Key Takeaway — FBOs have until July 2027 to align packaging and labelling systems — but should begin artwork and claims audits now given the breadth of the changes.
FSSAI — Affidavit to Supreme CourtMar 13, 2026
In re: Front-of-Pack Labelling for HFSS Foods — SC Supervision
FSSAI Tells SC It Is Still Weighing Pictorial vs. Tabular Warning Label Formats
Responding to a 10 February 2026 Supreme Court order urging it to mandate front-of-pack labels on packaged foods high in fat, sugar, or salt, FSSAI filed an affidavit stating it was still evaluating tabular versus pictorial warning formats and sought a further six weeks to submit a detailed proposal. The Court had earlier expressed dissatisfaction that FSSAI's compliance efforts "had not yielded any positive or good result."
Key Takeaway — The Supreme Court is actively monitoring FSSAI's compliance timeline — repeated extensions raise the risk of firmer judicial directions or contempt proceedings if the regulator continues to stall.
See all Legal Updates for this practice area →
Our Approach to Food Safety & FSSAI
- Current on the 2026 regulatory overhaul — perpetual licensing, risk-based inspection, and revised turnover thresholds.
- Both compliance and enforcement-defence experience — we help clients avoid action, and defend them when it happens.
- Dual-city coverage — Delhi NCR and Kolkata FSSAI compliance and defence.
- Founders with 20 years combined experience across commercial litigation, arbitration and regulatory practice.
Frequently Asked Questions
Do FSSAI licences still need to be renewed periodically?
No — licences and registrations issued on or after 1 April 2026 carry perpetual validity, though annual fee payment remains mandatory and a missed payment triggers automatic suspension.
What are the current FSSAI turnover thresholds?
Basic registration applies up to ₹1.5 crore annual turnover; State Licence applies between ₹1.5 crore and ₹50 crore; Central Licence applies above ₹50 crore turnover.
Can street food vendors operate without a formal FSSAI licence?
The 2026 amendment introduced deemed registration for street food vendors, simplifying compliance for small, informal food businesses.
What happens if I receive an FSSAI show-cause notice?
You should respond within the specified timeline with a reasoned reply supported by corrective evidence; failure to respond can result in adverse adjudication, penalties, or licence suspension.