A Landmark Shift for India’s Packaged Water Industry
For decades, every packaged drinking water and mineral water manufacturer in India had to carry two separate approvals — an FSSAI licence and a BIS ISI mark under IS 14543. That dual-compliance era has effectively ended. India’s food safety regulator has formally ended the long-standing requirement for mandatory Bureau of Indian Standards (BIS) certification for packaged drinking water and mineral water, while simultaneously tightening regulatory oversight through a detailed and compulsory scheme of testing that will come into force from January 1, 2026.
This is not a case of deregulation reducing scrutiny — quite the opposite. The BIS Certification Mark is no longer required for PDW and MW, but to compensate for this change and maintain consumer safety, FSSAI has introduced a mandatory testing and control framework, effective 1 January 2026. For the hundreds of bottling units, 20-litre jar suppliers, and branded water manufacturers operating across India, this changes almost everything about how compliance is documented and audited.
What the Order Actually Says
FSSAI issued this direction under File No. RCD 15001 19 2025 Regulatory FSSAI dated 17 December 2025. The move builds on an earlier policy signal — the change comes after a notification issued by the FSSAI on October 17, 2024 — but it is this December 2025 order and its January 2026 implementation date that FBOs must act on immediately.
The New Scheme of Testing — What FBOs Must Now Do
Removing the BIS mark does not mean less paperwork; it means different paperwork, and arguably more of it. FSSAI has prescribed standardized formats for monthly testing reports, six-monthly test records, source water monitoring, and packaging conformity documentation, all of which must be available for inspection.
Source Water Testing Requirements
Source water must be tested for all parameters specified under FSSR 2.10.8 (for PDW) and FSSR 2.10.7 (for MW) before use. Any change to the water source triggers a fresh compliance cycle: any change in source water or addition of a new source requires full retesting before commercial production can resume. Radioactive contamination is treated as a red-line issue — if radioactive residues are detected, the source must be abandoned immediately, products recalled, and FSSAI informed without delay.
Documentation & Reporting Obligations
Packaging is now a distinct compliance checkpoint rather than an afterthought. Packaging materials — including plastic bottles, jars, pouches, glass bottles, cartons and aluminium cans — must conform to existing food packaging regulations, with additional scrutiny during inspections. Units that fail to maintain clean records will find themselves under heavier scrutiny: in cases of repeated non-compliance over consecutive six-month testing cycles, manufacturing units may be subjected to risk-based inspections by FSSAI.
FSSAI has made clear this is a whole-of-system rollout. The authority has directed all FBOs, State and UT Food Safety Commissioners, notified laboratories, and licensing authorities to ensure strict implementation of the scheme from January 1, 2026.
High-Risk Classification & Tighter Inspection Regime
Bottled water has not become a lighter-touch category — it has moved into a stricter one. Because packaged drinking water is classified as a high-risk category, FSSAI has moved from a one-time check to a risk-based audit framework in 2026. In practice, FSSAI now requires high-risk units to undergo an annual audit by FSSAI-recognized auditing agencies. Businesses should budget for this as a recurring operational cost rather than a one-off compliance expense: stricter oversight includes mandatory annual audits, monthly microbiological testing, and a higher risk of random market sampling by Food Safety Officers.
Should a brand still want the ISI mark for commercial reasons, that door remains open but is now optional: certain corporate clients or contract-packing agreements may still insist on a BIS certification for brand value and quality assurance. Modern trade chains, export buyers, and large institutional clients frequently still ask for it, so exporters and B2B suppliers should not assume BIS is irrelevant simply because it is no longer legally compulsory.
Licensing Requirements That Still Apply
The FSSAI licence itself has not disappeared — if anything, it now carries more weight since it is the primary legal instrument for this category. Packaged water plants must also track the broader overhaul of India’s food licensing framework. On 10 March 2026, FSSAI notified the Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, with changes taking effect from 1 April 2026 — arguably the most consequential update to India’s food licensing framework in more than a decade.
Two changes matter most for water bottlers:
- Perpetual validity: any FSSAI licence or registration issued on or after 1 April 2026 stays valid indefinitely, with no more renewals every one to five years.
- Revised turnover thresholds: the turnover limit for FSSAI registration has increased to ₹1.5 crore, State licence applies up to ₹50 crore, and Central licence is required above ₹50 crore. Most commercial bottling plants, given their production volumes, will continue to require a Central or State licence rather than basic registration.
Annual FSSAI licence fees for water units are relatively modest compared to the earlier BIS marking costs — commonly cited at roughly ₹7,500 per annum plus GST for a standard unit, a meaningfully lower entry cost than the BIS marking and registration fees that could previously run well over a lakh annually. However, the savings on certification fees are increasingly offset by recurring testing, auditing, and laboratory costs under the new scheme.
Practical Compliance Checklist for Water Bottlers
- Discontinue reliance on the BIS ISI mark as a standalone compliance shield — it is no longer the operative legal requirement.
- Set up monthly and six-monthly testing schedules matching FSSR 2.10.7/2.10.8 parameters, with records retained in FSSAI’s prescribed formats.
- Document source water monitoring continuously, and immediately retest whenever a new source is added or an existing one changes.
- Verify all packaging materials (bottles, caps, jars, cartons) against current food-grade packaging regulations before every production run.
- Engage an FSSAI-recognized auditing agency for the mandatory annual high-risk audit, and budget for this as a recurring line item.
- Review your FSSAI licence category against the revised turnover thresholds — many mid-sized bottlers may now sit comfortably within the State licence band rather than needing a Central licence.
- If licences are due for renewal after 1 April 2026, factor in the shift to perpetual validity and the corresponding annual fee obligations that keep such licences active.
Why This Matters Now
The combination of a scrapped certification mark, a brand-new testing scheme, high-risk classification, and an overhauled licensing framework means packaged drinking water businesses face a genuinely different compliance map in 2026 than they did just twelve months ago. Units that treat this as “one less certificate to worry about” risk missing the substantially heavier documentation and audit burden that has replaced it. Conversely, businesses that build robust testing and record-keeping systems now will be far better positioned during risk-based inspections and market sampling drives.
ACPL’s regulatory experts can help you navigate FSSAI licensing for packaged drinking water and mineral water. Contact us at info@acplgroupindia.co.in or call +91-9266665201 for a consultation.