In recent years, the popularity of Vegan Food Products has surged globally, driven by increasing awareness about health, environmental sustainability, and ethical considerations. India, with its rich cultural heritage and diverse culinary traditions, is witnessing a growing demand for vegan alternatives across various consumer segments. However, ensuring compliance with regulatory requirements is crucial for businesses venturing into the burgeoning vegan market.
Vegan Food Product Regulations in India
The regulatory framework for vegan food products in India primarily falls under the purview of the Food Safety and Standards Authority of India (FSSAI). With the advent of the Food Safety and Standards (Vegan Foods) Regulations 2022, effective from July 2022, India has embarked on a new journey towards ensuring the safety and integrity of vegan food products. Furthermore, Vegan Food Products must adhere to the Food Safety and Standards (Labelling and Display) Regulations, 2020 and Food Safety and Standards (Food Recall) Regulations 2017.These regulations ensure that Vegan Food Products meet the required safety standards and provide accurate information to consumers.
What exactly constitutes "vegan food"?
According to the Food Safety and Standards Authority of India (FSSAI) regulations, vegan food encompasses food and/or food ingredients, additives, flavorings, enzymes, carriers and processing aids that are entirely free from animal origin throughout the production and processing stages. Moreover, these products must not undergo animal testing for any purpose including safety testing, unless mandated by regulatory authorities.
FSSAI Vegan Food Product Regulations in India
Packaging plays a vital role in maintaining the vegan integrity of food products. Every packaging material used for vegan foods must comply with prescribed regulations to uphold the quality and safety standards.
Manufacturers face stringent Good Manufacturing Practices (GMP) requirements to prevent cross-contamination with non-vegan substances. If sharing production lines with non-Vegan Food Products, thorough cleaning procedures must be adhered to before commencing Vegan Food Production. The same shall extend to all associated machinery, equipment, utensils and surfaces. Clear labeling is essential in such cases to inform consumers about potential cross-contamination risks and shall include the statement “Processed on the same line where other non-Vegan Food Products are processed”
Traceability is another critical aspect emphasized by the regulations. Food Business Operators (FBOs) must establish traceability up to the manufacturer level and comply with additional requirements specified by the Food Authority to maintain the vegan integrity of their products.
Labeling and display regulations ensure that vegan food products are clearly distinguished from non-vegan counterparts. Each package of vegan food must carry the specified vegan logo, and sellers must store and display vegan food separately from non-Vegan Food Products.
Importation of Vegan Food Products into India
Vegan food products may only be imported with a certificate issued by the recognized authorities of the exporting countries, which must adhere to the specified format accepted by the Authority.
FSSAI approval for endorsement of Vegan Food Products in India
Obtaining approval for the vegan logo entails a systematic application process, including submission of necessary documentation and adherence to prescribed fees. FBOs must ensure compliance with all regulations, including the Food Safety and Standards (Labelling and Display) Regulations 2020.
Application Process and Requirements for FSSAI Vegan Food Product Endorsement
Submitting an application for Vegan Food Product endorsement in India involves several steps and detailed information. The process begins with the completion of Form-A, which is then reviewed by the Food Safety and Standards Authority of India (FSSAI). Upon approval, the FBO must apply for a license in accordance with the FSS (Licensing and Registration of Food Business) Regulations 2011.
The application requires comprehensive details about both the applicant and the manufacturing facility. This includes the name, address, license number, authorized personnel, contact information, and email ID of the FBO. Similarly, details about the manufacturing facility, if different from the applicant (FBO), must also be provided.
Additionally, the application mandates detailed product information. This encompasses the product name, food category, list of ingredients along with their sources, manufacturing process, technical specifications of ingredients from suppliers, and certificates of analysis (CoA) for each ingredient. For domestically manufactured products, CoAs from FSSAI-notified labs are required, while imported products must provide CoAs from ISO/IEC 17025:2017 accredited laboratories.
Furthermore, the application must include existing label samples, a prototype label complying with FSS regulations, and a self-declaration from the product owner. This self-declaration asserts the non-use of animal-origin ingredients or processing aids, compliance with Food Safety Standards Act 2006, and a commitment to recall products posing risks to consumers.
CoAs submitted to the FSSAI must encompass physical, chemical, and microbiological parameters, validated test methods, analysis indicating the absence of animal sources, and relevant scientific references and evidence.
By meticulously adhering to these application requirements, FBOs can streamline the process of obtaining Vegan Food Product endorsement and ensure compliance with FSSAI regulations.
Key Considerations for FSSAI Vegan Food Product Endorsement in India
When it comes to obtaining Vegan Food Product endorsement in India, several key considerations must be taken into account. Firstly, Food Business Operators (FBOs) need to understand the application process, especially when it comes to products with multiple variants or different flavors.
Additionally, FBOs must ensure that the endorsement covers all variations in packaging size or type. While the endorsement applies to the product itself, regardless of packaging, all relevant packaging details must still be provided.
When making minor changes to ingredients, such as adjustments in sugar quantity or salt content, FBOs are not required to resubmit documents unless there are changes to the ingredients themselves. Similarly, changes in the design of the front-of-package (FOP) do not necessitate a new application, as long as the product composition remains unchanged.
For retailers or marketers with multiple manufacturing units, separate applications are required for each manufacturing site. The application process involves submitting hard copies to the Food Safety & Standards Authority of India (FSSAI) and soft copies via email.
Moreover, FBOs must be cautious about labeling terminologies. Terms like "vegan salami" or "plant-based meat" cannot be used on labels, and no comparisons to meat products are allowed. Additionally, products cannot be categorized as cheese or dairy analogs to qualify for vegan endorsement.
Furthermore, FBOs should ensure that certificates of analysis (CoA) do not depict non-vegan parameters like lactose or milk fat, as vegan endorsement cannot be granted in such cases.
By considering these key factors, FBOs can navigate the vegan endorsement process effectively and ensure compliance with regulations set forth by the FSSAI.
FSSAI Fees for Vegan Logo Endorsement
The FSSAI fees for processing applications for Vegan Logo Endorsement have undergone a revision, with a significant reduction in the fee structure. Previously set at INR 25,000/- per product, the fees were updated in November 2023 to INR 10,000/- per application. This adjustment aims to streamline the process and make it more accessible for Food Business Operators (FBOs) seeking endorsement for the 'Vegan Logo' on their food products. FBOs are required to submit the applicable application fee, or as revised by the Food Authority, through the online e-payment portal provided. The transaction receipt and generated invoice must be included as enclosures to the application, ensuring compliance with the updated fee structure.
Exemptions from Vegan Endorsement Application
Certain products are exempt from the requirement to apply for vegan endorsement. These exemptions include products that are inherently vegan, such as raw agricultural commodities like rice, cereals, pulses, oil seeds, and dry fruits. Additionally, agricultural commodities that undergo minimal processing without the addition of other ingredients, such as oil and wheat flour, are exempt. Furthermore, raw agricultural or horticultural commodities, whether singularly or in mixed form, without the addition of other ingredients, are also excluded from the endorsement requirement. It's important to note that if a Food Business Operator (FBO) still chooses to submit an application for vegan endorsement for such exempted products, the fees paid along with the application will not be refunded
As the demand for Vegan Food Products continues to grow in India, navigating the regulatory landscape becomes imperative for businesses operating in this space. By ensuring compliance with FSSAI regulations, maintaining high-quality standards, and promoting consumer awareness, businesses can capitalize on the opportunities offered by the burgeoning vegan market while contributing to a healthier, more sustainable future.
However, navigating these regulations can be complex. That's where Artixio steps in as your trusted partner. With our expertise in regulatory compliance, we assist FBOs in understanding and adhering to the intricate requirements of vegan food regulations in India.
Stay tuned with Artixio for more insights into navigating the regulatory landscape and ensuring compliance with evolving food safety standards.
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