FSSAI releases consultation paper on analogue dairy product compliance issues
The paper has proposed that, for example, when analogue paneer is used to make a kadhai paneer dish, the exact nature of the ingredient should be declared.
The Food Safety and Standards Authority of India (FSSAI) has floated a consultation paper seeking comments from stakeholders on compliance issues related to analogue dairy products. The paper proposes to prohibit sale of analogue dairy products in loose form and restrict licensing for such products only to State and Central licensees for better compliance. It has also sought comments on issues related to nomenclature, labelling and declarations at hotels and restaurants.
The consultation paper has come at a time when there are rising concerns about analogue dairy products being sold as dairy products, misleading consumers.
In the dairy context, “analogue” refers to a product where ingredients not derived from milk replace some or all of the milk components, resulting in a product that mimics the sensory and functional properties of milk or a milk product.
Usage of ‘non-dairy’
FSSAI had held a meeting attended by 57 participants including industry bodies, consumer organisations and MSMEs in April to discuss the issue. It also held a separate meeting with hotel, restaurants, catering services (HoReCa) players labelling requirements of dairy analogues. Post which, it released the consultation paper.
The paper has sought suggestions on the “terminology” for analogue dairy products. “Whether words like ‘non-dairy’ or ‘analogue’ can be used as prefix to the dairy terminology, in both cases, where any milk constituents are substituted partially or wholly,” the paper stated.
It has also sought views on declarations on labels when analogue dairy ingredients are used in packaged food products. It has proposed that “dairy analogue used in pre-packaged food products as an ingredient, shall clearly mention the nature of the ‘dairy analogue’ in the ingredient list”. This, it said, should be accompanied by a list in brackets of its ingredients in descending orders of proportions.
Labelling declaration
The paper has also sought views on declarations required when analogue dairy products are served or used as ingredients in food items at restaurants among others (HoReCa). It has proposed that restaurants, caterers and other food service establishments must clearly indicate the exact nature of food items and ingredients by prefixing terms ‘non-dairy’ or ‘analogue’. This should be done through declarations on menu cards, boards or booklets, or other relevant materials and should be legible to consumers. For example, when analogue paneer is used to make a kadhai paneer dish, the exact nature of the ingredient should be declared.
The paper has also proposed prohibition of sale of analogue dairy products in the loose form. It suggests such products be sold only in packed form not less than 500 gms with proper labelling declaration.
For better compliance, FSSAI has proposed that licenses allowing manufacturing of dairy analogue food products should be given only to food business operators that have State and Central licenses. It proposes to prohibit “petty food manufacturers” from being given such licences. These are FBOs whose turnover is up to ₹12 lakh per annum, or the production capacity is up to 100 kg/litres per day.
Published on April 20, 2025
