Overview
This article provides a comprehensive, plain-language explanation of Food Recall Log Template under the Food Safety and Standards (FSS) Act, 2006 and the Regulations made thereunder. Whether you are a food business operator (FBO), restaurant owner, manufacturer, importer, or food safety professional, understanding these provisions is essential for lawful operation and avoiding penalties.
The relevant provisions are found in Recall Regulations 2017, read with applicable FSS Rules, 2011 and FSSAI Regulations, Orders, and Directions. This article incorporates all amendments and FSSAI updates up to March 2026.
What the Law Requires
The Food Safety and Standards Act, 2006 (FSS Act) is the umbrella legislation governing food safety in India. It consolidated 8 earlier food laws into a single unified framework and established FSSAI as the apex regulatory body.
Key Legal Provisions
Recall Regulations 2017 establishes the framework for recall log. The provisions cover: (a) scope and applicability to different categories of food business operators, (b) specific conditions and requirements, (c) documentation and record-keeping obligations, (d) inspection and enforcement mechanisms, and (e) penalties for non-compliance.
Who Must Comply?
| FBO Category | Applicable? | License/Registration Type |
|---|---|---|
| Petty manufacturer / Street vendor / Small retailer (Turnover up to Rs. 12 lakh) | Yes | Basic Registration (Form A) via FoSCoS |
| Medium food business (Turnover Rs. 12 lakh to Rs. 20 crore) | Yes | State License (Form B) |
| Large food business (Turnover above Rs. 20 crore) | Yes | Central License (Form B) |
| Importer of food articles | Yes (mandatory Central License) | Central License irrespective of turnover |
| E-commerce food / Aggregator | Yes | Central or State License depending on scale |
| Hotels / Restaurants / Caterers / Cloud Kitchens | Yes | Registration or State License depending on turnover |
| Home-based food business / Cottage industry | Yes | Basic Registration (Form A) |
Detailed Explanation with Practical Examples
Example 1: Ramesh runs a small bakery in Faridabad with annual turnover of Rs. 8 lakh. He needs only a Basic FSSAI Registration (Form A). The registration is valid for 1-5 years and must be renewed before expiry. He must display the FSSAI registration number on all product labels and at the shop premises.
Example 2: Priya operates a packaged food brand selling snacks across Haryana and Delhi through retail stores and Amazon. Her turnover is Rs. 3 crore. She needs a State FSSAI License. All her product labels must comply with FSS (Packaging and Labelling) Regulations, 2011 -- including nutritional information, ingredients list, allergen declaration, FSSAI logo, veg/non-veg symbol, manufacture date, best before date, and net quantity.
Example 3: A restaurant chain operating in 5 states with combined turnover of Rs. 25 crore needs a Central FSSAI License. Each outlet must display the license, maintain daily records, ensure FoSTaC-trained food safety supervisor is present, and file annual returns on FoSCoS.
Step-by-Step Compliance Process
Penalties for Non-Compliance
| Offence | Penalty | Section |
|---|---|---|
| Operating without FSSAI Registration/License | Up to Rs. 5 lakh | Section 63 |
| Selling unsafe food | Rs. 1 lakh to Rs. 6 lakh + imprisonment up to 6 months | Section 50/51 |
| Selling misbranded food | Up to Rs. 3 lakh | Section 52 |
| Selling adulterated food | Rs. 1 lakh to Rs. 6 lakh + imprisonment | Section 50/51 |
| Food causing serious injury | Rs. 5 lakh + imprisonment up to 6 years | Section 58 |
| Food causing death | Rs. 10 lakh + imprisonment up to life | Section 59 |
| Obstructing Food Safety Officer | Rs. 25,000 + imprisonment up to 3 months | Section 60 |
| Late renewal of license | Rs. 100 per day of delay | Regulation |
Recent FSSAI Updates (2025-2026)
1. Front-of-Pack Nutrition Labelling (FOPNL): FSSAI has finalized Health Star Rating system for packaged foods. Phased implementation from 2025-2026.
2. Fortification Standards Updated: Revised standards for fortification of rice, wheat flour, edible oil, and milk with +F logo requirements.
3. FoSCoS Portal Enhancements: New features for online annual return filing, integrated inspection scheduling, and auto-generated compliance reports.
4. FoSTaC Training Mandatory: Every food business with State or Central License must have at least one FoSTaC-certified Food Safety Supervisor.
5. E-Commerce Directions: New FSSAI guidelines for food delivery platforms (Zomato, Swiggy) regarding display of FSSAI numbers and hygiene ratings.
6. Vegan Food Logo: Specific vegan logo notified under FSS (Vegan Foods) Regulations, 2022.
7. Safe Food in Schools: FSS (Safe Food and Balanced Diets for Children in School) Regulations, 2020 -- banning HFSS foods near schools.
How TaxClue Can Help
At TaxClue, our food safety consultants handle end-to-end FSSAI compliance for food businesses across India:
- FSSAI Registration and License application on FoSCoS portal
- License renewal, modification, and upgrade
- Product label review and compliance check
- Annual return filing (Form C)
- Food Safety Management Plan preparation
- Inspection readiness assessment
- Reply to improvement notices and show cause notices
- Appeals before Adjudicating Officer and Tribunal
Visit taxclue.in/fssai-registration or taxclue.in/fssai-license for details. Contact us at +91 98914 64610.