Regulations 2 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.
Regulation 2.1.5 allows one licence to cover several premises and articles in the same local area, and lets the FSSAI appoint officers for large Central government food establishments such as Railways and Defence. Regulation 2.1.6 says an applicant may commence business if the licence is not issued within 60 days and no defect has been notified. This article is based on the 2017 compendium (Version II, 09.11.2017); later amendments may have changed it, verify on fssai.gov.in. For help with a pending application, see our basic FSSAI registration service, which covers the registration track, and the licence articles before it.
Under 2.1.5, a single licence may cover one or more articles of food and different establishments or premises in the same local area, including collection and chilling units run by milk cooperatives or their members. The CEO of the FSSAI, as Food Safety Commissioner, may appoint a Designated Officer or Food Safety Officer for Central government bodies such as Railways and Defence. Under 2.1.6, an applicant may commence business if, from the date of a completed application, no licence is issued within 60 days and no intimation of inadequacy or inspection report with defects has been received. All as per the 2017 compendium.
Regulation 2.1.5: procedure for licence in certain local areas
One licence, several premises (sub-regulation (1))
A single licence may be issued for one or more articles of food and also for different establishments or premises in the same local area. The text expressly includes collection and chilling units run by milk cooperatives or its members. This mirrors section 31(6) of the Act, which allows a single licence for one or more articles and for different establishments in the same area. Section 31(7) adds the other side: where premises fall in more than one area, separate applications and separate licences are needed. For the Act text, see section 31. Businesses with many branches should also read our page on multiple branches.
Central government establishments (sub-regulation (2))
The CEO of the FSSAI, in the capacity of Food Safety Commissioner, may appoint a Designated Officer or Food Safety Officer for Central government organisations like Railways and Defence, which have a large number of food establishments. Their job is to ensure food safety in those establishments and that all other conditions under the Act and the Regulations are complied with. A proviso lets the Food Authority carry out a food safety audit of these establishments once a year, through its own or accredited agencies.
Regulation 2.1.6: commencement of business
The full rule is short. The applicant may commence the food business, and the Licensing Authority shall not deny the applicant that right, if, from the date of making the completed application:
- a licence is not issued within 60 days, or
- the applicant has not received any intimation of inadequacy under Regulation 2.1.4(2), or an inspection report indicating defects under Regulation 2.1.4(4).
The text is written with "or" between the items, so read it with care. In the structure of Regulation 2.1.4, a notice of inadequacy or an inspection report with defects is what stops the start. Silence, with no such notice, is what allows it.
How it matches the Act
Section 31(4) of the Act has a proviso: if a licence is not issued within two months of the application, or the application is not rejected, the applicant may start the business after that period. In that case the Designated Officer shall not refuse to issue a licence, but may, if considered necessary, issue an improvement notice under section 32. Regulation 2.1.6 is the regulatory counterpart.
What the rule does not say
The 2017 text does not turn silence into a licence. It allows commencement; it does not say a licence certificate has been issued. Keep proof of your filing date and Application ID, and the authority's messages (or the absence of them). A business that begins on this basis remains subject to Schedule 4 and to an improvement notice if defects are later found. Compare the petty registration rule in Regulation 2.1.1, which has its own 7-day and 30-day triggers.
| Point | Regulation 2.1.6 position |
|---|---|
| Clock starts | From the date of the completed application |
| Period | 60 days without licence |
| Blocking events | Intimation of inadequacy (2.1.4(2)) or inspection report with defects (2.1.4(4)) |
| Effect | Applicant may commence; authority shall not deny |
| Later | Improvement notice possible under section 32 |
Practical examples
Example 1. A small dairy cooperative runs three chilling units in one district. Regulation 2.1.5(1) allows a single licence to cover them as units in the same local area, if the authority issues it on that basis.
Example 2. A restaurant filed a complete application 65 days ago, received no query and no inspection report with defects. Under 2.1.6, it may commence, and the authority shall not deny that.
Example 3. Another applicant received a notice of inadequacy on day 12. That is an intimation under Regulation 2.1.4(2), so the 2.1.6 route is not available until the application is completed and the position changes.
Need help with a stalled application?
If 60 days have passed and you are unsure whether you can open, TaxClue can review your filing history and the authority's messages before you decide. For smaller operators the basic FSSAI registration route has its own deadlines, and we will say which one applies. The 2017 text may have been amended, so we check the current rule first.
Key takeaways
- One licence may cover several premises and articles in the same local area.
- Milk cooperative collection and chilling units are expressly included.
- Separate areas need separate licences under section 31(7) of the Act.
- After 60 days of silence on a complete application, you may commence business.
- A notice of inadequacy or an inspection report with defects stops that route.
- Commencement does not remove the duty to meet Schedule 4 or respond to an improvement notice.
Read next
- Regulation 2.1.4: processing of application
- Regulation 2.1.7: validity and renewal
- Section 31: licensing and registration of food business
- FSSAI licence process step by step
Disclaimer: Based on the Food Safety and Standards Act, 2006 as enacted, read with the Jan Vishwas (Amendment of Provisions) Act, 2023 where it applies (ss.59, 61 and 63 only), and the FSS (Licensing and Registration of Food Businesses) Regulations, 2011 as per the 2017 compendium (Version II, 09.11.2017). Later amendments may have changed the Regulations (fees, forms, validity, portal steps and thresholds); verify on fssai.gov.in. Verify current notifications, regulations and FSSAI orders before acting.
