I.Background and Content Overview

On April 4,2024,the Food Safety and Standards Authority of India (FSSAI) issued an important announcement proposing to implement mandatory registration requirements for foreign food production enterprises and facilities.This announcement will take effect on September 1,2024,with the aim of strengthening the supervision of imported foods,ensuring food safety and quality,and safeguarding consumer health.The categories of imported foods covered by this new regulation include milk and milk products,meat and its products (including poultry,fish,and their products),egg powder,infant formula,and health supplements.

According to the announcement,before August 31,2024,registered and unregistered production enterprises and facilities may continue to export the aforementioned related food products.From the effective date,all relevant parties must provide the necessary information to the relevant competent authorities in accordance with the format specified by FSSAI and complete the registration process.After reviewing the information,FSSAI will generate a unique registration code for each enterprise and facility to ensure uninterrupted trade activities.

II.Specific Regulatory Provisions and Implementation Rules

(1) Registration Requirements and Procedures

According to the announcement of FSSAI,all foreign manufacturing enterprises and facilities involved in the above - mentioned food categories must be registered.The specific registration process is as follows:

Information Submission: Enterprises must submit detailed information in the format specified by FSSAI,including the enterprise name,address,details of production facilities,production processes,product types,quality control measures,etc.

Review and Approval: FSSAI will review the information submitted by the relevant competent authorities to confirm its compliance with Indian food safety standards.

Generation of Registration Code: After passing the review,FSSAI will generate a unique registration code for each registered enterprise and facility to ensure that its legal identity is recognized and approved in the import trade.

(2) Covered Food Categories

The food categories covered by this registration requirement mainly include:

(1) Milk and its products: Such as milk powder,cheese,butter,etc.

(2) Meat and its products: Including all types of meat,poultry,fish and their related products.

(3) Egg powder: Including egg powder used in baby food and other health nutritional products.

(4) Baby food: Nutritional food specifically designed for infants,ensuring that its nutritional components meet the standards.

(5) Health nutritional products: Nutritional supplement products for specific groups of people.

III.Impact and Response Suggestions

(1) Impact on Foreign Food Manufacturing Enterprises

The implementation of this announcement will have a wide - ranging impact on foreign food manufacturing enterprises,especially those that export food to India.The specific impacts include:

Increase in compliance costs: Enterprises need to invest additional resources in registration and information submission to ensure that their products meet the standards of FSSAI.

Market access barriers: Enterprises that fail to complete the registration in a timely manner may face the risk of their products being unable to enter the Indian market,affecting their market share.

Operational adjustments: Enterprises need to adjust their production and quality control processes according to the specific requirements of India to ensure compliance with local regulations.

(2) Countermeasures Suggestions

In order to ensure a smooth transition and continuous operation in the Indian market,foreign food manufacturing enterprises should take the following countermeasures:

Register in a timely manner: Prepare and submit registration materials as soon as possible according to the requirements of FSSAI to avoid affecting business due to registration delays.

Strengthen compliance management: Establish a sound compliance management system to ensure that all links from production to export of products comply with Indian food safety standards.

Cooperate with local agents: Consider cooperating with local agents familiar with Indian regulations to ensure the smooth progress of the registration process and respond promptly to any regulatory changes.

Training and education: Train relevant internal personnel of the enterprise to make them fully understand the requirements and registration process of FSSAI and improve their compliance awareness.

The mandatory registration requirements for foreign food manufacturing enterprises and facilities proposed by FSSAI are an important measure for India to strengthen food safety supervision.For foreign food manufacturing enterprises,although they face compliance challenges,through timely registration,strengthening compliance management,cooperating with local agents and other measures,they can ensure their sustainable development in the Indian market.Enterprises need to attach great importance to this regulatory change and actively respond to it to maintain and expand their market share and influence in India.