Regulations 10 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Regulations 10 to 13 cover labels that never reach a consumer shelf in the usual way: bulk and trade packs (regulation 10), food additives sold at retail (regulation 11) and sold otherwise (regulation 12), and the rule that these Regulations prevail where another regulation's labelling rule is repugnant (regulation 13).
The text is read as amended up to 24 March 2026 (FSSAI Compendium Version VIII dated 09.09.2025; the First Amendment Regulations, 2026 apply from 1 July 2027 and replace parts of regulation 10). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in. Manufacturers who supply bulk packs can have the labels checked through our FSSAI label compliance service.
A non-retail package must show six particulars: name of the food, net quantity, FSSAI logo and licence number, date marking, lot number, and manufacturer or packer name and address. Every non-retail package must bear "NOT FOR RETAIL SALE". A food additive pack carries "FOR USE IN FOOD". From 1 July 2027 regulation 10 is replaced with new lists, including a "NON-RETAIL CONTAINER" statement option.
Regulation 10: non-retail containers (text today)
"Non-retail containers" are defined in regulation 2(1)(n) as containers not intended to be offered for direct sale to the consumer, the food in them being for further business activities before it reaches the consumer; see regulations 1 to 4.
| Sub-regulation | Rule |
|---|---|
| 10(1) | Every packaged food meant for non-retail sale shall provide, on the container or pasted on the label thereto: (a) name of the food; (b) net quantity; (c) FSSAI logo and licence number; (d) date marking; (e) lot no.; (f) name and address of the manufacturer or packer (including country of origin for imported packages) |
| 10(2) | If not provided on the label, the following shall be in the accompanying documents: (a) list of ingredient; (b) declaration regarding veg or non-veg; (c) nutritional information |
| 10(3) | Exempt if provided in a barcode or Global Trade Identification Number (GTIN): (a) the address of the brand owner (whether or not the manufacturer, marketer, packer or bottler); (b) the licence number of the manufacturer, marketer, packer or bottler, if different from the brand owner |
| 10(4) | Every package meant for non-retail sale shall bear a statement "NOT FOR RETAIL SALE" |
Regulation 11: food additives for retail sale
11(1) Every package of a food additive meant for retail sale to the consumer shall be labelled in accordance with the Labelling and Display Regulations, 2020, except for sub-regulations 5(1) and 5(3) (the text says "of this regulation"; it is read as printed).
11(2)(a) Name of food additive. The specific name as in the Food Products Standards and Food Additives Regulations, 2011 and amendments shall be used, with provisos: (i) where the name is not listed there, the name established in international regulations; (ii) in other cases the common or commercial name; (iii) for synthetic food colours, the chemical name and the colour index of the dye stuff; (iv) where two or more food additives are present, their names in descending order of composition by weight or volume, and where an additive is subject to a quantitative limitation in a food under the 2011 Regulations, the quantity or proportion of that additive shall be stated; food ingredients that are part of the preparation are declared in the list of ingredients in descending order of proportion by weight.
11(2)(b) Other mandatory declarations. (i) Every package of a food additive sold in retail or non-retail sale shall be marked prominently with the words "FOR USE IN FOOD". (ii) In mixtures of flavourings, the name of each flavouring need not be given, but the common or generic expression "flavour" or "flavouring" may be used with a true indication of the nature of the flavour, and the expression is qualified by "natural", "nature-identical", "artificial" or a combination, except for flavour modifiers.
Our article on section 19 of the Act explains how the Act treats additives.
Regulation 12: food additives sold other than by retail
Every package of a food additive meant for sale other than in retail shall carry a label in accordance with chapter 4 and regulation 10, except clause 10(2)(c) (nutritional information).
Regulation 13: overriding effect
The provisions of these Regulations shall supersede, if repugnant to the labelling requirement prescribed in any regulations made under the Food Safety and Standards Act, 2006 (34 of 2006). Where an older instrument, such as one that cites the Packaging and Labelling Regulations, 2011, prescribes a different labelling rule, these Regulations prevail to the extent of the repugnancy. The packaging side is dealt with in the Packaging Regulations, 2018.
Notified change, in force from 1 July 2027
The First Amendment Regulations, 2026 (F. No. STD/SP-08/A1.2022/N-01, 24 March 2026), in force on 1 July 2027, substitute regulation 10(1), (2) and (4) and insert a new regulation 10(5). The new words are:
10(1) "Every packaged food meant for non-retail sale shall provide the following mandatory information either on the container or pasted on the label thereto: (a) Name of the food; (b) FSSAI Logo and License number; (c) Date marking and storage instructions, when required for the safety or integrity of the product; (d) Lot number or Batch number or Code number; and (e) Name and address of the manufacturer or packer (including country of origin for imported packages)". Two provisos: where a non-retail container holds multiple types of food, the mandatory information shall be provided for all the types; and a non-retail container that gives access to all the information required by 10(1) on the labels of the pre-packaged foods inside need not carry it again. Net quantity no longer appears in this list.
10(2) "The following information if not provided on the label shall be provided in the accompanying documents: (a) List of ingredient; (b) Declaration regarding Veg or Non-Veg and (c) Net Quantity". Provisos: the information shall be traceable to the food in the non-retail container; sub-regulation (2) does not apply if all that information is on the label of the non-retail container or the pre-packaged foods inside; and for a non-retail container used as a food transportation unit that is not amenable to possess a label, all information under 10(1) and (2) shall be provided in the accompanying documents or through appropriate other means (for example electronically between food businesses) and shall be effectively traceable to the food. Nutritional information no longer appears in the list.
10(4) "Every package meant for non-retail sale shall be clearly identifiable as such. If the container is not clearly identifiable as a non-retail container, the container shall (a) bear a statement to indicate that the food is not intended to be sold directly to the consumer or to clearly identify it as a non-retail container. Some examples of such statements are: (i) NON-RETAIL CONTAINER; (ii) NON-RETAIL CONTAINER - NOT FOR DIRECT SALE TO CONSUMER; or (b) carry any other mark that indicates that the container is not intended to be sold directly to the consumer."
10(5) General Information (inserted). "(a) Information and the statements required to appear on the label by virtue of these Regulations or any other Regulations shall be clear, prominent, readily legible and applied in such a manner that any tampering with it will be evident. (b) The mandatory information required on the label under sub-regulation (1) of regulation 10 shall appear in a prominent position on the non-retail container and shall be readily accessible under normal handling and use of the container."
Sub-regulation 10(3) (barcode or GTIN) is not changed by the amendment. Until 1 July 2027 the text in the table above applies.
An invented example
Prime Bulk Foods supplies 25 kg sacks of wheat flour to bakeries. Today each sack carries the six particulars in 10(1) and "NOT FOR RETAIL SALE", and the ingredients and nutrition may travel in the delivery documents. After 1 July 2027, the sack carries name, FSSAI logo and licence number, date marking with storage instructions where needed for safety, batch and manufacturer details; net quantity, ingredients and veg declaration may move to accompanying documents, and the sack must be clearly identifiable as non-retail, for example by "NON-RETAIL CONTAINER". Prime Bulk also sells a leavening additive, which carries "FOR USE IN FOOD" and the additive name as listed in the 2011 Regulations.
Need help with trade pack and additive labels?
Bulk, ingredient and additive labels sit between product law and trade practice, and the 2027 changes move particulars into documents. Our FSSAI label compliance team can prepare labels and shipping documents so both generations of the rule are met.
Key takeaways
- Non-retail packs carry six particulars today and the words "NOT FOR RETAIL SALE".
- Food additive packs carry "FOR USE IN FOOD"; flavour mixtures use "flavour" or "flavouring" with a nature qualifier.
- Regulation 12 applies chapter 4 and regulation 10, except nutritional information, to additives sold other than by retail.
- Regulation 13 makes these Regulations prevail over repugnant labelling rules in other regulations.
- From 1 July 2027 regulation 10(1), (2) and (4) are substituted and 10(5) is inserted.
Read next
- Regulation 9: display in food service establishments
- Schedule II, part 1: mandatory label declarations
- Regulations 7 and 8: mandatory declarations and exemptions
- Food additives and processing aids: section 19
Disclaimer: Based on the FSSAI regulations named above as consolidated in FSSAI's compendium versions or as published in the Gazette, with the later notifications the article names (consulted on fssai.gov.in on 2-3 October 2026). Later notifications and the Food Safety and Standards Act, 2006 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.