India Tightens Milk, Eggs, and Meat Safety and Licensing Requirements

India has introduced stricter licensing and registration requirements for Milk, Eggs, and Meat products across key HS codes, reinforcing food safety standards for domestic and imported food businesses.

Compliance Requirements for Milk, Eggs, and Meat Products in India under Recent FSSAI Draft Regulations

India has introduced stricter licensing, registration, and hygiene requirements for businesses dealing in milk, eggs, and meat products through two key draft regulations:

1. Draft Food Safety and Standards (Licensing and Registration of Food Business) Amendment Regulations, 2020^{1, 2}
2. Draft Food Safety and Standards (Licensing and Registration of Food Business) Amendment Regulations, 2024³

These amendments aim to enhance food safety standards for both domestic and imported food businesses by revising licensing conditions, digitizing registration processes, and imposing stricter sanitary requirements for slaughterhouses and primary milk producers.

Regulation Analysis

1. Key Requirements for Milk, Eggs, and Meat Businesses

The draft regulations impose the following obligations on food business operators (FBOs) handling these products:

2. Product Coverage (HS Codes and Scope)

While the draft regulations do not explicitly list HS codes for milk, eggs, or meat, they apply broadly to:

• All food products under the Food Safety and Standards Act, 2006, including:
  • Milk and milk products (e.g., HS 0401–0406)
  • Meat and edible offal (e.g., HS 0201–0210)
  • Eggs and egg products (e.g., HS 0407–0408)
• E-commerce food business operators selling these products¹.
• Slaughterhouses (small and large) processing meat^{1, 2}.

For precise HS code applicability, FBOs must refer to the Customs Tariff Act, 1975 and FSSAI’s product-specific standards (e.g., Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011).

3. Compliance Process for Businesses

A. Licensing and Registration

1. Determine Applicability:
   • Primary milk producers (farmers, cooperatives) must register under the 2024 draft regulations³.
   • Slaughterhouses, meat processors, and e-commerce sellers must obtain a license under the 2020 draft regulations^{1, 2}.
   • Importers of milk/meat/eggs must comply with FSSAI’s import licensing requirements (separate from these drafts but referenced in FSS (Import) Regulations, 2017).

1. Submit Documents:
   • For registration (primary milk producers): Basic details (name, address, product list) via the digitized portal³.
   • For licensing (slaughterhouses, e-commerce, processors):
   • Annexure-2/3 documents (e.g., layout plan, water test reports, NOC from local authority)¹.
   • Hygiene compliance certificate for slaughterhouses^{1, 2}.

1. Inspection and Approval:
   • FSSAI or State Food Safety Authorities may conduct pre- or post-issuance inspections¹.
   • Digitized licenses/registrations will be issued via the FSSAI portal (2024 draft)³.

B. Hygiene and Sanitary Requirements

• Slaughterhouses must adhere to Schedule 4 (revised) of the 2011 Regulations, covering:
  • Infrastructure: Separate areas for slaughter, storage, and waste disposal.
  • Worker hygiene: Protective clothing, handwashing facilities, medical checks.
  • Waste management: Proper disposal of blood, offal, and wastewater^{1, 2}.
• Primary milk producers must follow:
  • Clean milking practices: Sterilized equipment, udder hygiene, immediate cooling.
  • Storage/transport: Use of food-grade containers and refrigerated transport³.

4. Timelines and Enforcement

5. Penalties for Non-Compliance

While the draft regulations do not specify penalties, the Food Safety and Standards Act, 2006 imposes:

• Fines: Up to ₹5 lakh for operating without a license/registration (Section 55).
• Imprisonment: Up to 6 months for selling unsafe food (Section 59).
• License cancellation: For repeated violations (Section 32).

Summary Answer

India’s Draft Food Safety and Standards (Licensing and Registration of Food Business) Amendment Regulations, 2020 and 2024 introduce stricter licensing, registration, and hygiene standards for milk, eggs, and meat products^{3, 1, 2}. Key requirements include:

1. Digitized registration for primary milk producers and revised licensing conditions for slaughterhouses/e-commerce operators^{3, 1}.
2. Minimum sanitary standards for slaughterhouses (Schedule 4) and hygienic practices for milk producers^{1, 2}.
3. Compliance timelines are pending adoption, with a 60-day comment period for the 2024 draft³ and a 15 March 2021 deadline for the 2020 draft².

Businesses must prepare for digitized processes, documentation updates, and infrastructure upgrades to meet the proposed standards. For precise HS code applicability, refer to FSSAI’s product-specific regulations and the Customs Tariff Act, 1975. All drafts are available on the³(http://www.fssai.gov.in/)^{3, 1, 2}.

Sources

1. ↩ Draft Food Safety and Standards (Licensing and Registration of Food Business) Amendment Regulations, 2020. _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN21/IND197.DOCX
2. ↩ Draft Food Safety and Standards (Licensing and Registration of Food Business) Amendment Regulations, 2020 _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/SPS/NIND261.DOCX
3. ↩ The Draft Food Safety and Standards (Licensing and Registration of Food Business) Amendment Regulations, 2024 _notification https://docs.wto.org/imrd/directdoc.asp?DDFDocuments/T/G/TBTN24/IND349.DOCX