Food Imports into India: Import Licensing, Clearance, Sampling and Compliance

“Indirect Tax I Indirect Tax Litigation I Customs & FTP I Central Licensing I Arbitration I Advisory”

Dated: 12.09.2026

Food Imports into India: Import Licensing, Clearance, Sampling and Compliance

The Food Safety and Standards Authority of India (FSSAI) has issued a comprehensive Food Import Manual consolidating the regulatory and procedural framework governing the import and clearance of food products into India.

The manual is intended as a practical guidance document for food importers, Customs Brokers/CHAs, FSSAI officers and Customs officers working at ports, and covers the food-import clearance process from licensing and filing of the Bill of Entry through document scrutiny, visual inspection, sampling, laboratory testing and final clearance.

Significantly, FSSAI itself clarifies that the manual is a guidance document and does not replace statutory provisions. Where the manual conflicts with the Food Safety and Standards (Import) Regulations, 2017 or other applicable regulations, the statutory regulations will prevail.

FSSAI’s Statutory Role in Regulating Food Imports

The regulatory foundation for food imports lies in Section 25 of the Food Safety and Standards Act, 2006. The manual explains that FSSAI is responsible for ensuring that food imported into India is safe and wholesome for human consumption.
Section 25 prohibits the import of unsafe, misbranded or sub-standard food, food containing extraneous matter, food requiring a licence unless imported in accordance with licence conditions, and food imported in violation of the FSS Act, its rules or regulations, or other applicable law.
The regulatory regime therefore extends beyond Customs clearance. Importers must simultaneously consider FSSAI standards, licensing requirements, packaging and labelling rules, product-specific requirements and other applicable import restrictions.
The manual further notes that penalties under Section 67 of the FSS Act for imported food may operate in addition to liability under laws such as the Foreign Trade (Development and Regulation) Act, 1992 and the Customs Act, 1962.

Valid FSSAI Import Licence and IEC Are Fundamental Requirements

A food importer must possess a valid FSSAI import licence issued by the Central Licensing Authority as well as a valid Importer Exporter Code (IEC) issued by the Directorate General of Foreign Trade.
The manual states that no person can import an article of food without the required import licence. Food consignments requiring FSSAI intervention are referred electronically by Customs through SWIFT/ICEGATE to FSSAI’s Food Import Clearance System.
For licensing, the importer applies through the Food Safety Compliance System (FoSCoS) and selects “Importer” as the Kind of Business under Trade/Retail. The manual describes the application, DGFT authentication, documentation and fee process for obtaining the Central Licence.
It further states that an import licence can be obtained for a period ranging from one to five years, while annual returns are required to be filed online through the FoSCoS dashboard on or before 31 May for each class of food handled during the preceding financial year.

FICS Integrated With Customs ICEGATE and SWIFT

One of the central features of the import-clearance framework is the Food Import Clearance System (FICS).
FICS operates as an online system integrated with Customs ICEGATE under SWIFT – Single Window Interface for Facilitating Trade. Bills of Entry requiring FSSAI clearance are electronically referred to FSSAI through FICS; consignments not selected for such intervention may proceed through the applicable green-channel mechanism.
Once the application forwarded through ICEGATE is accepted by the Authorised Officer, it becomes visible in the importer or Customs Broker’s FICS login. Supporting documents are then uploaded electronically, and queries or requests for additional information are also communicated through FICS.
The process therefore reflects increasing integration between Customs and FSSAI clearance systems, with the Bill of Entry acting as the starting point for regulatory referral.

Pre-Requisites for Food Import

The manual identifies a valid FSSAI Import Licence and IEC as essential pre-requisites. Where a product is neither standardised nor capable of being treated as proprietary food, the importer may also require appropriate product approval under the applicable FSSAI framework.
Importers should therefore undertake regulatory classification before shipment rather than waiting for the consignment to reach an Indian port. The FSSAI classification of the food, applicable standards, ingredients and additives, packaging and labelling requirements, shelf life and any product-specific certificates can materially affect clearance.

Document Scrutiny Followed by Visual Inspection

Once the documents are uploaded, the Authorised Officer scrutinises them to verify compliance with the applicable FSS regulations and standards.
If the documents are satisfactory, the importer or CHA is asked to deposit the applicable food-import clearance fees through FICS. An appointment is thereafter fixed for inspection of the consignment. The manual states that normally two opportunities are given to acknowledge the inspection appointment; after two opportunities, the Authorised Officer may draw the sample ex parte.
Visual inspection includes checking the physical condition of the consignment, storage and transportation conditions, visible infestation, shelf life, packaging and labelling compliance.
An important requirement recorded in the manual is that the product should ordinarily have a valid shelf life of not less than 60% or three months before expiry, whichever is less, at the time of import.

Sampling and Laboratory Testing

Sampling constitutes a crucial stage of food-import clearance.
The manual states that the Authorised Officer or representative is required to draw two parts of the food sample of each description or measure, except in specified situations such as aseptically sealed packages, and forward the prescribed quantity to the Food Analyst.
For sealed bulk containers maintained under aseptic or hygroscopic conditions, the manufacturer may provide two representative sealed samples from the same batch together with a declaration confirming that the food in the sealed container corresponds with the representative samples.
The sample label must contain prescribed particulars, including the sample code, date and place of collection, quantity, description/category of food, details of preservative where applicable and signatures of the importer/CHA and sender.

Risk-Based Food Import Clearance Through RMS

Not every food consignment is necessarily subjected to identical intervention.
FSSAI and Customs operate a Risk Management System (RMS) under SWIFT to facilitate selective sampling and testing based upon risk profiles. The system is designed to reduce sampling and clearance time while maintaining food-safety controls.
According to the manual, the risk-management framework takes into consideration factors including the inherent nature of the food, country of origin, manufacturer and importer.
The manual further records that a list of 1,725 HSN codes, categorised into high-, medium- and low-risk food products and aligned with Customs tariff/product coverage, has been shared with Customs for implementation through ICEGATE.
This makes accurate HSN classification particularly important because classification can affect not only Customs treatment but also the level of FSSAI intervention.

High-Risk Food Products Face Additional Controls

The manual identifies certain food categories as high risk, including milk and milk products, egg powder, meat and meat products including poultry and fish, infant foods, nutraceuticals, health supplements, foods for dietary use, probiotic and prebiotic foods, and foods for special medical purposes.
Imports of such products are permitted through designated Points of Entry to ensure greater monitoring and traceability.
The manual records that food-import regulation extends across 162 Points of Entry, with FSSAI’s own Authorised Officers covering 78 points and notified Customs officials functioning as Authorised Officers at another 84 points.

Foreign Food Manufacturing Facilities Must Register for Specified Categories

A major compliance requirement concerns registration of foreign food-manufacturing facilities.
Foreign manufacturers intending to export specified categories to India must register with FSSAI before export. The manual identifies five categories for this requirement: milk and milk products; meat and meat products including poultry and fish; egg powder; infant food; and nutraceuticals.
The manual’s ReFoM workflow further states that mandatory registration on the Registration of Foreign Food Manufacturers (ReFoM) portal applies with effect from 1 September 2024 for the specified categories.
Information including competent-authority details, manufacturer details, approval/licence number, product name and HS code is submitted after verification by the competent authority of the exporting country. Upon FSSAI approval, a Unique Registration Number (URN) is generated and the registered facility is published on the ReFoM portal for verification by the Authorised Officer.
For foreign suppliers exporting regulated food categories to India, this creates an important pre-shipment compliance checkpoint.

NOC, NCC and Provisional NOC

After assessment of a food consignment, the Authorised Officer may issue different regulatory outcomes.
A compliant consignment may receive a No Objection Certificate (NOC) in Form 3, while a non-compliant consignment may receive a Non-Conformance Certificate/Report (NCC) in Form 4 specifying the grounds for rejection.
The framework also permits a Provisional No Objection Certificate (pNOC) in specified situations.
For example, pNOC may be available for food requiring special refrigerated or chilled storage, food with a shelf life of less than seven days, and certain pre-packaged retail foods, subject to the applicable declarations and safeguards.
The manual also records pNOC facilities under FSSAI orders for imported crude edible oils, food grains and Authorised Economic Operators (AEOs) following successful visual inspection and sampling, subject to final laboratory conformity.

Special-Purpose Imports Receive Separate Treatment

The regulations recognise that not every imported food consignment is intended for ordinary domestic sale.
Separate procedures are contemplated for food imported for personal consumption, quality assurance or R&D, exhibitions and tasting, sporting events, 100% export/re-export production and disaster or emergency situations.
For example, food imported for quality assurance or R&D requires an undertaking that it will be used only for that purpose and will not enter the domestic market or be used for test marketing. Food imported exclusively for exhibitions and tasting may be exempted from the normal clearance procedure subject to the prescribed undertaking.
Likewise, food ingredients or additives imported for captive use in manufacture of products meant for 100% export are subject to specific end-use declarations and supporting certification.

Importers Have a Statutory Review and Second-Appeal Mechanism

The manual provides an important remedy where FSSAI refuses clearance.
A food importer aggrieved by specified orders of the Authorised Officer—including rejection for non-compliance, labelling-rectification directions or rejection following a Food Analyst’s non-conformance report—may file a review application in Form 6 before the Review Officer.
The first review must ordinarily be filed within 15 working days from receipt of the rejection report. The Review Officer may admit it within a further seven working days where sufficient cause for delay is established. The manual records a review fee of ₹2,000. Both the importer and the Authorised Officer have a right to be heard.
If still dissatisfied, the importer may file a second appeal to the Chief Executive Officer, FSSAI within 15 days of receipt of the review order.
This appellate structure is particularly important for importers facing rejection because disposal of rejected consignments is not to take place until expiry of the limitation period for filing the review application.

Non-Compliance Can Lead to Suspension or Cancellation of Import Licence

The consequences of food-import violations are not confined to rejection of a particular consignment.
The manual states that the Licensing Authority may suspend or cancel an import licence where there are sufficient grounds to believe that an importer has attempted to import unsafe or prohibited food, food from prohibited sources, engaged in re-channelling or repacking, food fraud, use of fraudulent certificates, unauthorised release before NOC, misuse of pNOC or misdeclaration of end use.
This makes food-import compliance a continuing licensing obligation rather than merely a consignment-level Customs formality.

FSSAI Introduces Food Import Rejection Alert (FIRA)

The manual also highlights the Food Import Rejection Alert (FIRA) portal, a digital mechanism intended to strengthen domestic and international exchange of information relating to rejected food consignments.
FIRA operates under Regulation 11(7) of the Food Safety and Standards (Import) Regulations, 2017, which enables FSSAI to issue food-alert notifications based on risks associated with food articles.
The portal contains details of final rejected consignments after the available mechanisms of re-testing, review and appeal have been exhausted. It also facilitates two-way communication so that competent authorities in exporting countries can report corrective and preventive measures taken following rejection.
The development is significant because rejected consignments can now contribute to a wider database used for risk profiling, traceability and improvement of the RMS framework, potentially influencing the regulatory treatment of future consignments.

What Food Importers and Customs Brokers Should Take Away

The Food Import Manual demonstrates that food-import compliance begins substantially before the goods arrive at the Indian port. Importers need to verify their FSSAI Central Licence and IEC, correct HSN classification, product standards and approvals, foreign-manufacturer registration where applicable, prescribed certificates, packaging and labelling, balance shelf life and any product- or origin-specific restrictions before shipment.
Once the Bill of Entry is filed, Customs–FSSAI integration through ICEGATE, SWIFT and FICS means that documentary declarations, product classification and supporting records become directly relevant to risk assessment and clearance.
The manual also highlights the importance of responding promptly to FICS queries, attending visual inspection, preserving appropriate storage conditions and understanding the available remedies where an NOC is refused.

Regulatory Significance

The FSSAI Food Import Manual provides a consolidated operational roadmap connecting the Food Safety and Standards Act, 2006, FSS (Import) Regulations, 2017, FoSCoS, FICS, Customs ICEGATE/SWIFT, RMS, laboratory testing, ReFoM and FIRA within a single food-import compliance framework. Its contents span import licensing, clearance, review procedures, responsibilities of authorised officers, importer compliance, prescribed forms, important orders/advisories and recent regulatory initiatives.

At the same time, businesses should treat the manual as operational guidance rather than a substitute for the law. FSSAI expressly advises importers to remain updated on subsequent regulations, standards, orders, advisories and policy interventions, because information in the manual may be superseded by later regulatory developments.

In case you face any issues related to Indirect Tax-Customs, GST, Foreign Trade Policy (FTP), Arbitration matters and Central Licensing and related advisory matters in India then please feel free to get in touch with SJ EXIM Services.

We offer Legal advice and litigation support in matters related to Indirect Tax-Customs, FTP, other Indirect Tax matters & Arbitration law, all sorts of Central licensing and related matters. Come and explore the new way of doing business with us!

We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Source: FSSAI

Disclaimer

Handy Download:

Food Import ManualDownload

Connect with us for more-

@ Team S J EXIM SERVICES, New Delhi, IN

CP: Ms. Shubhra Jha, Founder

Tel: +91-11-4999 2707 I +91-9999005693

Web: www.sjexim.services

EMAIL: operations@sjexim.services I shubhra@sjexim.services

Facebook: www.facebook.com/sjeximservices

LinkedIn: https://www.linkedin.com/company/90794255/admin/feed/posts/