India’s food label is about to get a lot more crowded — and a lot more contested. Between a sweeping labelling amendment notified in March, a last-minute climbdown on coffee packaging in July, and an unresolved Supreme Court battle over red warning hexagons that reached a boiling point in late September, food business operators (FBOs) are navigating one of the most active regulatory periods for packaging and labelling compliance in years.
The March 2026 Labelling and Display Amendment: What Actually Changed
On 24 March 2026, FSSAI notified the Food Safety and Standards (Labelling and Display) First Amendment Regulations, 2026, the first major revision to the labelling framework since the parent regulations came into force in 2022. The amendment touches Regulation 5 (nutritional information), Regulation 8 (display requirements), Regulation 10 (non-retail packaging), and Schedules I and II covering fortification and special declarations. Critically, these changes do not take effect until 1 July 2027 — giving FBOs a transition window, but one that requires early planning given typical packaging artwork and print lead times.
Non-Retail Containers Get a Traceability Upgrade
FSSAI’s 2026 amendment overhauls non-retail food container labelling, adding mandatory traceability and clear “NON-RETAIL CONTAINER” identification from July 1, 2027. Bulk packs, B2B shipments, and institutional-supply containers will need to carry this designation — or the alternative “NOT FOR DIRECT SALE TO CONSUMER” — alongside the name of food, FSSAI licence number, batch/lot code, date marking, and manufacturer/packer details.
Relief for Infant Nutrition and Small Packs
Businesses won’t need to declare the per-serve percentage contribution to Recommended Dietary Allowances (RDA) or the number of servings per pack for infant nutrition products covered by the Food Safety and Standards (Foods for Infant Nutrition) Regulations, 2020. Separately, FSSAI logos may be omitted if the surface area of a package is 100 square centimetres or less, though this information must still appear on multi-unit packages.
Fortification and Sweetener Declarations Tightened
Labels must now include “Fortified with (name of nutrient)” wherever fortification claims are made, and for sweetener blends, products containing Aspartame combinations must declare that they are not recommended for children, pregnant or lactating women, and individuals with phenylketonuria.
Coffee-Chicory Labelling: A Mid-Course Correction
A smaller but instructive episode unfolded with coffee-chicory mixtures. An earlier 2025 amendment had mandated a boxed front-of-pack declaration effective 1 July 2026, but industry pushed back citing space constraints on small packs. FSSAI revised the labelling requirements for coffee-chicory mixtures, replacing a previously notified front-of-pack box declaration with a simplified statement showing the percentage of coffee and chicory, applying to both regular and instant coffee-chicory mixtures effective July 1, 2027.
The revised format requires a straightforward “COFFEE …%, CHICORY …%” declaration, with minimum font size requirements of 1 mm for packages with a Principal Display Panel (PDP) of 100 cm² or less, and 2 mm for larger packages. This episode is a useful signal: FSSAI is willing to simplify prescriptive box-format rules when they create genuine production bottlenecks — but compliance deadlines still move in lockstep with the broader 2027 transition.
The Front-of-Pack Warning Label Standoff
The most consequential — and unresolved — development concerns front-of-pack warning labels (FOPL) for foods high in sugar, salt, and saturated fat. This has become a genuine courtroom drama through 2026.
It began with a Supreme Court order on 10 February 2026, after which the Court expressed dissatisfaction with FSSAI’s progress, noting that efforts so far had produced no “positive or good result,” and directed FSSAI to consider warning-based labels such as “High Sodium Level,” “High Sugar Level,” and “High Saturated Fat Level.”
Matters escalated on 13 August 2026, when a bench led by Justice J.B. Pardiwala told FSSAI, “We do not suggest, we direct,” making clear that the Court’s earlier order was binding, not a mere suggestion. The Court also rejected industry attempts to intervene directly in the case.
The design that has emerged from this process centres on a red hexagonal label indicating warnings such as “high fat,” “high sugar,” “high salt,” or “highly sweetened beverage,” in a font one point larger than the nutrition information on the back of the package. Notably, inherently high-fat products such as ghee and edible oil would be exempt under the proposed rules, subject to other applicable requirements — though basic declarations like batch numbers, dates, and licence numbers still apply to them.
On 28 September 2026, the case reached a critical juncture: Justice J B Pardiwala asked FSSAI why a year of voluntary compliance was needed, as the Supreme Court reserved its order on front-of-pack warning labels, and told the regulator that whatever order the Court passes will be binding on it. FSSAI’s proposal was reportedly for about four months to finalise draft regulations, followed by 365 days of voluntary compliance after notification — a timeline the bench appeared skeptical of. As of this writing, the Court’s final order remains pending, with parties asked to file written submissions.
Other Labelling Flashpoints Worth Tracking
Two further developments round out an unusually active quarter for FSSAI’s labelling agenda. On 25 September 2026, a prohibition was proposed on using “paneer” terminology for non-dairy analogue food products — a move that will directly affect plant-based dairy-alternative brands currently using dairy nomenclature. Separately, on 29 September 2026, the Madras High Court dismissed an FSSAI review plea on micro/nanoplastic warning labels, keeping that disclosure requirement alive for packaging manufacturers using certain plastic formats.
What Food Businesses Should Do Now
- Map your SKUs against the 2027 deadline. Even though compliance isn’t due until 1 July 2027, packaging redesign, artwork approval, and print-run depletion take months — begin now for non-retail containers, fortified products, and sweetener-containing SKUs.
- Audit bulk and institutional packaging separately. If you supply B2B, catering, or distributor-only packs, these will need the new “NON-RETAIL CONTAINER” or “NOT FOR DIRECT SALE TO CONSUMER” declarations plus full traceability details.
- Track the FOPL order closely. Once the Supreme Court issues its final ruling, the compliance window could be shorter than FSSAI’s proposed timeline — brands with products high in sugar, salt, or saturated fat should pre-emptively model hexagon placement and reformulation options.
- Reassess plant-based and analogue product naming. If your non-dairy range uses terms like “paneer,” prepare alternative nomenclature ahead of a potential ban.
- Don’t neglect routine compliance. Licence thresholds were also revised from 1 April 2026, with registration applicable up to ₹1.5 crore turnover, a state licence up to ₹50 crore, and a central licence above that, with registrations and licences now valid perpetually — confirm your licence category still matches your current turnover before your next renewal cycle.
With simultaneous amendments, judicial intervention, and shifting industry-driven revisions all in play, FSSAI’s labelling landscape in late 2026 is unusually fluid. Businesses that wait for final notifications risk compressed compliance timelines once the dust settles.
ACPL’s regulatory experts can help you navigate FSSAI labelling, packaging, and import compliance. Contact us at info@acplgroupindia.co.in or call +91-9266665201 for a consultation.