Every food business in India -- from a roadside dhaba to a five-star hotel kitchen -- must comply with the Food Safety and Standards Authority of India (FSSAI) regulations on packaging. These rules govern what materials can touch food, how products must be labelled, what testing is required, and what happens when businesses fail to comply. Yet, a significant number of food businesses remain unaware of the specific requirements that apply to them.
This guide provides a comprehensive overview of FSSAI packaging regulations as they stand in 2025, with practical guidance on achieving and maintaining compliance.
The Regulatory Framework
FSSAI packaging regulations are primarily governed by the following:
- Food Safety and Standards (Packaging) Regulations, 2018: The primary regulation covering food contact materials, migration limits, and approved substances.
- Food Safety and Standards (Packaging and Labelling) Regulations, 2011 (amended): Covers labelling requirements for packaged food products.
- Food Safety and Standards (Food Products Standards and Food Additives) Regulations: Sets standards for specific food categories and their packaging requirements.
- IS 9845:1998 (BIS Standard): The Bureau of Indian Standards specification for food-grade plastics, referenced by FSSAI regulations.
Approved Food Contact Materials
FSSAI Regulation 2.4.1 specifies that food contact materials must not transfer substances to food in quantities that could endanger human health, cause unacceptable changes in food composition, or deteriorate the sensory characteristics of food (taste, smell, texture).
The following material categories are approved for food contact when they meet prescribed standards:
| Material | Applicable Standard | Key Requirements |
|---|---|---|
| Paper and Board | IS 6615 (food-grade paper) | Must not contain recycled materials with printing ink residues; fluorescent whitening agents limited |
| Plastics | IS 9845:1998 | Overall migration limit of 60 mg/kg; specific migration limits for individual substances |
| Metal (Aluminium, Tin) | IS 15495 (aluminium foil) | Lead content below 10 ppm; arsenic below 2 ppm; lacquer coatings must be food-grade |
| Glass | IS 2467 | Lead and cadmium release limits; thermal shock resistance |
| Ceramics | IS 4853 | Lead and cadmium release limits based on vessel category |
| Natural Materials (Bagasse, Leaf, Wood, Bamboo) | General FSSAI food safety standards | Must not release harmful substances; no chemical treatment unless food-safe |
Migration Testing: The Core Compliance Requirement
Migration testing measures how much material transfers from packaging to food under simulated use conditions. This is the most critical compliance parameter for any food packaging product.
Overall Migration Limit (OML)
The total quantity of all substances that migrate from packaging to food must not exceed 60 mg/kg (or 10 mg/dm2 of surface area). This is tested using food simulants -- liquids that mimic different food types:
| Food Simulant | Represents | Common Test Conditions |
|---|---|---|
| Distilled water | Aqueous foods (beverages, soups) | 40°C for 10 days (long-term storage) |
| 3% Acetic acid | Acidic foods (pickles, citrus juices, curds) | 40°C for 10 days |
| 15% Ethanol | Alcoholic beverages | 40°C for 10 days |
| n-Heptane or olive oil | Fatty foods (oil-based preparations, fried items) | 40°C for 10 days (or 2 hours at higher temps) |
Specific Migration Limits (SML)
Certain individual substances have their own maximum migration limits. For example, lead migration must not exceed 1 mg/kg from any food contact material. Bisphenol A (BPA) migration must not exceed 0.6 mg/kg. Phthalates have specific limits depending on the compound. These specific limits apply in addition to the overall migration limit.
Who Needs Migration Testing?
Packaging manufacturers are responsible for conducting migration testing and providing compliance certificates. Food businesses (restaurants, caterers, cloud kitchens) are responsible for sourcing packaging that comes with valid test reports. If a food safety inspector finds non-compliant packaging in your establishment, the penalty applies to you regardless of the manufacturer's failings.
Labelling Requirements for Packaged Food
While disposable food service packaging (plates, containers, cups) is not required to carry consumer labelling on each unit, the packaging material itself must meet labelling standards. For pre-packaged food products (sealed items sold through retail), comprehensive labelling rules apply:
Mandatory Label Information
- Product name
- List of ingredients (in descending order of composition)
- Nutritional information
- Net quantity
- FSSAI licence/registration number with logo
- Name and address of the manufacturer/packer
- Date of manufacture and best before/use by date
- Lot/batch number
- Veg/non-veg symbol (green/brown dot)
- Allergen declarations
FSSAI Logo Usage
The FSSAI licence or registration number must be displayed on the label of all packaged food products. The logo must be in the prescribed format: the FSSAI "F" logo followed by "FSSAI Lic No." and the 14-digit licence number. Using the FSSAI logo without a valid licence is a prosecutable offence.
Specific Rules for Food Service Packaging
For restaurants, caterers, and cloud kitchens, the packaging rules focus on material safety rather than consumer labelling:
Material Compliance
All disposable packaging used for serving or delivering food must be made from food-grade materials that meet IS or FSSAI standards. This applies to plates, bowls, cups, containers, cutlery, wrapping materials, carry bags, and any other material that contacts food directly.
Newspaper Ban
FSSAI explicitly prohibits the use of newspapers and recycled paper for wrapping or serving food. The printing inks used in newspapers contain lead, cadmium, and other heavy metals that migrate into food on contact. This common practice in many small food establishments is a clear regulatory violation. The FSSAI issued an advisory in 2019 specifically addressing this issue, and enforcement has increased since.
Recycled Material Restrictions
Recycled plastic and recycled paper must not be used for direct food contact unless they meet specific FSSAI and BIS standards for recycled food-contact materials. In practice, most recycled materials in the Indian market do not carry food-contact certification, making virgin or certified-recycled materials the safe choice.
Printing Inks on Food Packaging
Any printed packaging (branded containers, printed paper cups, custom carry bags) must use food-safe inks that comply with IS 15495. The printed surface should not come in direct contact with food. For containers with printed exteriors, the interior surface must be unprinted and food-grade.
Penalties for Non-Compliance
The Food Safety and Standards Act, 2006, prescribes penalties for packaging-related violations:
| Violation | Penalty | Section of Act |
|---|---|---|
| Using packaging that does not meet standards | Up to Rs 5 lakh fine | Section 52 |
| Selling food in contaminated packaging | Up to Rs 1 lakh fine and/or 6 months imprisonment | Section 50 |
| Misleading labelling | Up to Rs 3 lakh fine | Section 53 |
| Operating without FSSAI licence | Up to Rs 5 lakh fine and/or 6 months imprisonment | Section 63 |
| Selling food injurious to health (packaging-related contamination) | Up to Rs 5 lakh fine and/or 6 months imprisonment | Section 50 |
Beyond monetary penalties, non-compliance can result in licence suspension or cancellation, product seizure and destruction, closure notices for repeated violations, and reputational damage if violations become public.
How to Ensure Your Packaging Is Compliant
Step 1: Source from Certified Suppliers
The simplest path to compliance is sourcing from suppliers who provide proper documentation. Reputable wholesale distributors maintain FSSAI food-contact certificates, BIS certification, and migration test reports for their product range. Always ask for these documents and keep them on file.
Step 2: Maintain Documentation
Keep a file containing FSSAI food-contact certificates for every packaging product you use, supplier invoices with product descriptions and material specifications, and test reports (if available) from the manufacturer. This documentation should be readily available for inspection. FSSAI food safety officers conduct random inspections, and having organised documentation demonstrates compliance commitment.
Step 3: Train Staff on Prohibited Practices
Ensure all kitchen and service staff understand these prohibitions: no newspaper for food wrapping, no recycled/non-food-grade materials for food contact, no aluminium foil with acidic foods for extended periods (short-term wrapping is acceptable), and no printed surfaces in direct contact with food.
Step 4: Stay Updated
FSSAI regulations are actively evolving. Subscribe to the FSSAI website notifications, follow industry associations like the Indian Institute of Packaging, and maintain a relationship with your packaging supplier who should alert you to regulatory changes affecting their products.
The Intersection of FSSAI and Environmental Regulations
Food businesses must comply with both FSSAI packaging standards and environmental regulations (single-use plastic ban, Plastic Waste Management Rules). These regulatory frameworks occasionally overlap:
- Thermocol (EPS) packaging is banned under environmental rules and is also not food-grade under FSSAI standards -- creating dual non-compliance.
- Eco-friendly materials like bagasse, areca leaf, and bamboo must still meet FSSAI food-contact standards. Being "natural" does not automatically mean FSSAI-compliant -- manufacturers must still ensure migration limits are met.
- PLA bioplastics are exempt from the plastic ban but must meet FSSAI food-contact migration requirements.
For a comprehensive understanding of the single-use plastic ban and its alternatives, refer to our dedicated guide on that topic.
FSSAI Licensing: The Foundation of Compliance
Before worrying about packaging specifics, ensure your food business has the correct FSSAI licence or registration:
- FSSAI Registration: Required for food businesses with annual turnover up to Rs 12 lakh. Applies to small restaurants, street food vendors, and small caterers.
- State FSSAI Licence: Required for food businesses with annual turnover between Rs 12 lakh and Rs 20 crore. Applies to most restaurants, hotels, mid-sized caterers, and cloud kitchens.
- Central FSSAI Licence: Required for businesses with turnover above Rs 20 crore, or those operating in multiple states. Applies to large chains, multi-state caterers, and import/export operations.
Your FSSAI licence number must be displayed prominently at your business premises and on all packaged food products. Operating without a valid FSSAI licence is itself a serious offence, regardless of the quality of your packaging.
Staying Ahead of Regulatory Changes
FSSAI continues to strengthen packaging regulations. Expected developments include mandatory third-party testing for all food contact packaging (currently self-certification is common), stricter limits on specific chemical migration from newer packaging materials, mandatory sustainability labelling (compostable, recyclable, etc.) on food packaging, and harmonisation with international standards (EU food contact regulations, FDA standards).
Food businesses that proactively maintain high packaging standards will find compliance with new regulations straightforward. Those relying on the cheapest available packaging without documentation will face increasing regulatory pressure.
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