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Regulation 2.1.1 of the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011: general standards for milk and milk products, composite milk products and dairy terms

Only a food that meets the definition of milk may be named milk, and a product that meets a milk product's standard may carry that product's name. A product in which non-milk...

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Last updated: October 2026Verified against: Government sources

Regulation 2.1.1 is the umbrella rule for every dairy standard that follows it. It defines milk, milk product, composite milk product, analogue and the heat treatments, and it controls who may use the word "milk" or a milk product's name on a pack. A dairy, a sweet shop, a plant-based beverage brand and a packer of flavoured milk all have to read it before naming a product. Dairy manufacturers who need a licence for their product range can start with FSSAI registration for food manufacturers.

This article reads the text as amended up to 21 October 2024 (FSSAI chapter compendium consolidated to amendment 83; the amendment of 10 July 2025 does not change this chapter). Later notifications should be checked on fssai.gov.in. A compendium is a reference consolidation; the Gazette text prevails.

The definitions in item 1

Item 1 holds the vocabulary. The main terms are:

TermWhat the text says in short
Boiling, boiledheating milk continuously to bring it to boil at atmospheric pressure
Analogue (dairy context)constituents not derived from milk take the place, in part or in whole, of a milk constituent and the product resembles milk or a milk product in sensory or functional terms
Composite milk productmilk or its constituents are an essential part in quantity, and non-milk constituents do not take the place of any milk constituent; examples are shrikhand with fruits and ice cream containing fruits
Dairy termsnames, designations, symbols or pictures that refer to or suggest milk or milk products
Heat treatmentpasteurization, ultra-pasteurization, sterilisation, ultra-high temperature treatment or boiling
Milkthe normal mammary secretion from complete milking of a healthy milch animal, without addition or extraction, and not colostrum
Milk producta product obtained by processing milk, which may contain permitted additives and functionally necessary ingredients
Recombined, reconstitutedmade from milk fat and solids-not-fat in preserved forms, or from dried or concentrated milk with water restored

The analogue definition and its note were inserted by the amendment of 11 January 2023. The note excludes from "analogue" the admixtures whose sale the Prohibition and Restrictions on Sales Regulations bars; our article on the sale prohibitions on dairy and oil admixtures covers those.

The list of "milk product" examples is long: cheese, chhana and paneer, condensed milk, cream, dahi, ghee and butter oil, ice cream, khoa, malai, milk derivatives such as whey proteins, casein and lactose, kulfi, milk powders, processed cheese, table and white butter, and yoghurt. A proviso says milk products shall not contain any substance not found in milk unless these regulations specify it.

Heat treatments: the printed parameters

The definitions give working figures for three treatments. Pasteurization means heating every particle of milk to at least 63 °C held continuously for at least thirty minutes, or at least 72 °C for at least fifteen seconds, or an equivalent combination that gives a negative phosphatase test, then cooling to 4 °C or less. Sterilisation means heating in sealed containers to at least 115 °C for fifteen minutes, to preserve at room temperature for not less than thirty days. UHT means at least 135 °C for one second or more in continuous flow, packed aseptically, for preservation of not less than fifteen days. The text does not set out other heat-treatment parameters here.

Items 2 and 3: how dairy terms may be used

Item 2 states the principle: foods must be described so that dairy terms are used correctly and consumers are not confused or misled. Item 3 then sets the rules:

  1. Only a food that meets the definition of milk may be named "milk". Milk adjusted for fat or solids-not-fat may still be named milk if it stays within the limits in 2.1.2.
  2. A product that meets a milk-product standard may be named accordingly, including when made from milk whose fat or protein has been adjusted.
  3. A product modified by adding or withdrawing milk constituents may carry the product's name with a clear description of the modification, provided its essential characteristics remain and the standard allows such modification.
  4. Recombined or reconstituted products may use the relevant names.
  5. A composite milk product may be named with "milk" or the milk-product name, provided the other characterising ingredient, such as a flavouring food, spice or herb, is described close to the name.
  6. A product that is not milk, a milk product or a composite milk product may not claim, imply or suggest that it is, on a label, commercial document or point-of-sale display, unless these or other regulations allow it.

Three provisos soften and tighten item 3(f). The term "milk" or a milk-product name may be used to describe the true nature of a product that contains milk as an essential characterising part. Dairy terms may not be used if the product is meant to substitute milk or a milk product. Where milk is not an essential part, dairy terms may appear only in the ingredient list.

Items 4 to 7: nutrients, labels, probiotics and enzymes

  • Essential nutrients (item 4): milk and milk products may be enriched or fortified with vitamins, minerals and similar nutrients as the regulations specify, including labelling requirements.
  • Labelling (item 5): pre-packaged milk, milk products and composite milk products are labelled under the labelling regulations, subject to item 3. Under sub-item (a), all milk and milk products including composite milk products as defined in sub-items (b), (e), (f), (h) and (i) of item 1 use the prescribed logo on the label. A note in the compendium says the timeline for mandatory compliance was extended by six months from the date FSSAI issues the logo specifications (direction of 9 December 2022). Under sub-item (b), an analogue's label carries, close to the name, "Contains" followed by each non-milk constituent and its source, and "Contains no milk" followed by each milk constituent whose place is wholly taken over.
  • Probiotics and prebiotics (item 6): the Nutraceuticals Regulations, 2016 apply to their use in dairy products.
  • Enzymes (item 7): safe and suitable enzymes may be used as processing aids as the individual dairy standards specify.

Our sister article on milk, edible oil, coffee and bread labelling covers the separate label statements required for milk.

A practical example

Suppose Kaveri Foods sells a drink made from oats and calls it "oat milk". Under item 3(f) the product is not milk, so it cannot suggest that it is milk. If the same company sells dahi with a fruit layer, the product may be treated as a composite milk product, and the label must describe the fruit in close proximity to the name. The first example turns on what the product replaces; the second on what stays essential.

How this regulation connects to the others

Each individual standard in 2.1.2 to 2.1.24 uses these definitions. Our articles on milk, condensed milk, khoa and cream and ghee, butter and milk powders take the compositional standards forward. For a business-level view see our post on FSSAI compliance for dairy businesses and the overview of dairy product standards.

Need help naming a dairy or dairy-like product?

The line between milk, a composite product and an analogue decides the name, the logo and the label wording. Our team can review a product name and label against these rules and the licence category. Start with FSSAI registration for food manufacturers.

Key takeaways

  • Only a food that meets the definition of milk may be named milk.
  • Composite milk products need a clear description of the characterising ingredient near the name.
  • Analogues are not milk or milk products and carry a "Contains" declaration.
  • The compendium prints working figures for pasteurization, sterilisation and UHT.
  • Milk and milk products use the prescribed logo, on the timeline the compendium note describes.

Read next

Disclaimer: Based on the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011 as consolidated in FSSAI's chapter-wise compendium (to amendment 83 of 21 October 2024) and the First Amendment Regulations, 2025, as 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.

Quick recapKey facts & short answers

Key Facts About General Standards

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What is milk under regulation 2.1.1?

The normal mammary secretion from complete milking of a healthy milch animal, without addition or extraction, and not colostrum, unless the regulations say otherwise.

What is a composite milk product?

A product where milk or its constituents are essential in quantity and non-milk constituents do not replace any milk constituent. Shrikhand with fruits and ice cream containing fruits are the printed examples.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

The normal mammary secretion from complete milking of a healthy milch animal, without addition or extraction, and not colostrum, unless the regulations say otherwise.

A product where milk or its constituents are essential in quantity and non-milk constituents do not replace any milk constituent. Shrikhand with fruits and ice cream containing fruits are the printed examples.

A product in which non-milk constituents take the place of milk constituents and which resembles milk or a milk product. It is not treated as milk, a milk product or a composite milk product.

Item 3(f) bars a product that is not milk from claiming or suggesting it is, and bars dairy terms if the product is meant to substitute milk, unless other regulations provide otherwise.

Close to the name, "Contains" with each non-milk constituent and its source, and "Contains no milk" with the milk constituent fully replaced.

Item 5(a) requires the logo prescribed in the regulation; the compendium note extends the compliance timeline by six months from the date FSSAI issues the logo specifications.