The Food The Food Safety and Standards Authority of India (FSSAI) has issued an advisory on declaration of address of brand owner on labels of food products. This advisory was issued on 30th October, 2023.
It may be recalled that the Food Safety and Standards ( Labelling and Display ) Regulation 2020 stipulates labelling provisions for declaration of the address of the brand owners on the label of pre-packaged food. The present advisory emphasises the following aspect of this regulation:
- The name and complete address of the brand owner whether shall be declared on the label of the pre-packaged food products
- This is applicable even if the brand owner is also the manufacturer, marketer, packer or bottler of the product
- Such name and address shall be preceded by the qualifying words ”Manufactured by ( mfg by, mfd by ) or Marketed by ( mkt by ) or manufactured & marketed by or packed & marketed by” as the case maybe
- The labelling requirement of the declaration of the address of the brand owner is exempted if it is provided in a Barcode/Global trade Identification Number (GTIN)
Hence, in light of these provisions, the FSSAI has clarified that the Food Business Operators (FBOs) may either provide the address of the brand owner through text or Barcode/GTIN on the label. The FBO is not compelled to declare the address of the brand owner in both forms, i.e. text and barcode/ GSTIN on product labels. The FBO can choose to declare the address by any one method.
In the view of the above, while scrutinizing the labelling declaration of the FBO, the relevant food safety authorities should adhere to the abovestated regulatory provisions. Th FSSAI has directed the authorities to avoid unnecessary actions including issuance of notices to such FBOs who are compliant with these provisions, i.e. by either including the declaration of the address of the brand owner through text or Barcode/GTIN only on the product label etc.
