The recent draft notification issued by the Food Safety and Standards Authority of India (FSSAI) on 26th February 2026 and uploaded on March 11th 2026, may appear routine at first glance.
But let us be clear—this is not just a technical amendment.
This is a structural shift in how dairy products will be regulated in India.
For the first time, packaging is being brought at par with product standards and labelling, making compliance far more integrated—and far more unforgiving.
What Has Fundamentally Changed
Across the entire regulation:
- The term “labelling” is replaced with “labelling and packaging”
- All references to the old Packaging & Labelling Regulations, 2011 are now aligned with:
- Packaging Regulations, 2018
- Labelling & Display Regulations, 2020
In simple terms:
Packaging is no longer a support function. It is now a regulatory obligation embedded into product compliance.
Why This Matters to Dairy
Dairy is one of the most packaging-intensive sectors in food:
- Liquid milk (high turnover, low shelf life)
- Fermented products (sensitive to contamination)
- Fat-rich products (packaging-material interaction risks)
- Value-added products (high claims, high scrutiny)
This amendment directly impacts every SKU on the shelf.
Product-Wise Impact & Responsibilities
Liquid Milk (Pouches, Bottles, UHT Packs)
What changes:
- Mandatory alignment with Packaging Regulations, 2018 (material safety, migration limits)
- Strict adherence to Labelling & Display norms (2020)
New responsibilities:
- Validation of packaging material (especially multilayer films)
- Correct declaration format (fat, SNF, fortification, etc.)
- Traceability between packaging supplier and product batch
Risk:
- Even a compliant milk product can become non-compliant due to packaging lapses
Ghee & Butter
What changes:
- Packaging compliance becomes critical due to fat interaction with material
New responsibilities:
- Use of approved food-grade containers (tin, PET, laminates)
- Shelf-life validation linked with packaging type
- Clear label declarations (purity claims, AGMARK references if used)
Risk:
- Oxidation or migration issues may now attract regulatory scrutiny
Paneer, Cheese & Fresh Dairy Products
What changes:
- Greater focus on hygiene + packaging integrity
New responsibilities:
- Vacuum / MAP packaging validation
- Storage condition declarations (temperature-sensitive labelling)
- Date marking (packed on / use by)
Risk:
- Misleading or incomplete storage instructions = non-compliance
Ice Cream & Frozen Desserts
What changes:
- Additives and flavour declarations must align with 2020 labelling rules
New responsibilities:
- Transparent declaration of emulsifiers, stabilizers, sweeteners
- Distinction clarity (ice cream vs frozen dessert)
- Claim substantiation (premium, natural, etc.)
Risk:
- High chance of label non-compliance due to complex formulations
Flavoured Milk & Dairy Beverages
What changes:
- Specific provisions for sweeteners and additives now tied to updated labelling norms
New responsibilities:
- Mandatory declaration of artificial sweeteners (if used)
- Nutritional claims validation (protein, energy, low-fat)
- Alignment with Schedule II labelling requirements
Risk:
- Misleading health positioning may invite regulatory action
Milk Powders (SMP, WMP, Infant Foods, Dairy Ingredients)
What changes:
- Export-oriented products must also align with domestic packaging norms
New responsibilities:
- Bulk packaging compliance (bags, liners, containers)
- Re-labelling compliance for domestic vs export markets
- Ingredient and additive declarations
Risk:
- Bulk packs—often ignored—will now fall under sharper scrutiny
What This Means for Dairy Companies
1. Compliance Will No Longer Be Departmental
- QA, Regulatory, Packaging, Procurement, Marketing
→ Must work as one integrated system
2. Artwork is Now a Legal Document
- Every label approval must be regulation-backed
- No room for “market-driven shortcuts”
3. Vendor Ecosystem Comes Under Scanner
- Packaging suppliers become compliance partners
- उनकी गलती = आपका non-compliance
4. Cost of Transition is Real
- Artwork redesign
- Packaging material validation
- Possible write-offs of old inventory
5. Enforcement Will Become Easier
- With harmonised regulations, regulators now have clearer grounds for action
A Larger Message the Industry Must Not Ignore
This amendment signals a clear direction:
India is moving towards globally aligned, packaging-led food safety regulation.
For dairy—this is both:
- A risk, if ignored
- A competitive advantage, if adopted early
Call to Action for Dairy Industry
This is still a draft notification.
The window for industry feedback is 60 days from publication.
I strongly urge:
- Dairy cooperatives
- Private dairies
- Startups
- Industry bodies
to carefully evaluate the operational impact and submit:
- Practical challenges
- Implementation timelines
- Product-specific concerns
to FSSAI within the stipulated period.
Final Thought
The question is not whether this regulation will come.
The real question is:
Will the dairy industry shape it—or struggle with it later?
Source : Policy comment by Kuldeep Sharma Chief editor Dairynews7x7 April 2nd 2026