Naturally Occurring 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.
Clauses 2 and 3 of regulation 2.2.1 add two more Tables to the one for crop contaminants. Clause 2 sets maximum limits, in ppm, for four naturally occurring toxic substances: agaric acid, hydrocyanic acid, hypericine and saffrole. Clause 3 sets limits for polychlorinated biphenyls (PCBs) and benzo(a)pyrene in fish and fishery products. Fish processors and beverage makers can ask for a specification review through FSSAI compliance support.
This article reads the text as amended up to 14 May 2026 (FSSAI Compendium Version IX dated 03.02.2026, consolidated to the notification of 17 October 2024; the Amendment Regulations, 2026 of 14 May 2026 apply from 1 December 2026). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in.
Clause 2 lists four naturally occurring toxic substances with a maximum limit in ppm for each named food. Clause 3 lists three entries for PCBs and benzo(a)pyrene in fish. Inland and migratory fish carry a PCB limit of 2.0 ppm, marine fish, crustaceans and molluscs 0.5 ppm, and smoked fishery products a benzo(a)pyrene limit of 5.0 ppb. From 1 December 2026, serial 4 (saffrole) in clause 2 is substituted. Fish processors, alcoholic beverage makers, sauce and soup makers and cassava or tapioca product makers are affected.
Clause 2: naturally occurring toxic substances
Clause 2, "Naturally occurring Toxic Substances", was substituted by the notification of 4 November 2015 (footnote 2 in the compendium). Its Table has four columns: serial number, name of the naturally occurring toxic substance (NOTS), article of food, and maximum limits (ppm).
| Serial | Substance | Foods named in the entry (limit in ppm as printed) |
|---|---|---|
| 1 | Agaric acid | Food containing mushrooms (100); Alcoholic beverages (100) |
| 2 | Hydrocyanic acid | Nougat, marzipan or its substitutes or similar products (5); Canned stone fruits (5); Alcoholic beverages (5); Confectionery (5); Stone fruit juices (5); Sago, Cassava flour, Tapioca flour, Manihot flour and their products (10) |
| 3 | Hypericine | Alcoholic beverages (1) |
| 4 | Saffrole | Meat preparations and meat products, including poultry and game (10); Fish preparations and fish products (10); Soups and sauces (10); Non-alcoholic beverages (10); Food containing mace and nutmeg (10); Alcoholic beverages (10) |
The compendium marks the sago, cassava, tapioca and manihot line as inserted by the notification of 21 July 2017 (footnote 10). An invented example: Konkan Tapioca Products makes tapioca flour. The Hydrocyanic acid entry for "Sago, Cassava flour, Tapioca flour, Manihot flour and their products" prints 10, so a lab report for the flour is read against that line in ppm.
Clause 3: PCBs and PAH in fish and fishery products
Clause 3 is headed "Polychlorinated biphenyls (PCBs) and Polycyclic Aromatic Hydrocarbon (PAH) compounds in Fish and Fishery Products". It was inserted by the notification of 4 January 2016 (footnote 5). The Table has four columns: serial number, name of the contaminant, article of food, and limit.
| Serial | Contaminant | Article of food | Limit |
|---|---|---|---|
| 1 | Polychlorinated biphenyls (Sum of PCB28, PCB52, PCB101, PCB138, PCB153 and PCB180) | Inland and Migratory Fish | 2.0 ppm |
| 2 | Polychlorinated biphenyls (same sum) | Marine Fish, Crustaceans and molluscs | 0.5 ppm |
| 3 | Benzo(a)pyrene | Smoked Fishery Products | 5.0 ppb |
Two points are worth noting when reading the Table. The PCB figure is a limit on the sum of the six PCB congeners named in column (2), so the limit applies to the six named congeners taken together. And the benzo(a)pyrene limit is stated in ppb, not ppm, so the unit in column (4) is read line by line.
Notified change, in force from 1 December 2026
The Contaminants, Toxins and Residues Amendment Regulations, 2026 (14 May 2026) come into force on 1st December, 2026. Until then the Table above stands. From that date, in clause 2 of regulation 2.2.1, the Table is changed so that serial number 4 and the entries relating to it are substituted by:
"4 | Saffrole | Beverages and foods containing mace and/or nutmeg kernel as an ingredient | 10"
The substituted entry reads as one line in the amendment. The article description changes from the six lines printed above to "Beverages and foods containing mace and/or nutmeg kernel as an ingredient", with the limit of 10 printed against it. Businesses making meat products, fish products, soups and sauces, or alcoholic beverages should read the Gazette text of the amendment on this point before 1 December 2026, since the substituted entry is the only one the amendment prints for serial 4.
Practical reading
Clause 2 groups alcoholic beverages under three of the four substances (agaric acid, hydrocyanic acid, hypericine) and under saffrole as well, so a brewer, distiller or alcoholic beverage importer has to look at every serial number, not only the first. Confectionery, stone fruit juices and canned stone fruits are named under hydrocyanic acid. Food containing mushrooms is named under agaric acid. A lab report should name the substance, the food line and the unit, since clause 2 is in ppm while clause 3 mixes ppm and ppb.
Where these sit in the Regulations
The first clause of regulation 2.2.1 (crop contaminants) is in our article on aflatoxin and crop contaminants. Pesticides follow in regulation 2.3.1, covered in our article on the pesticide MRL Table. The fish standards in the sister cluster are in fish and fish products. For the Act's rule on naturally occurring toxic substances see section 20 of the FSS Act.
Food businesses can arrange a review of their product specifications through FSSAI compliance support.
Need help with natural toxin and fish contaminant limits?
Fish processors and beverage makers often need a clear line-by-line mapping of their products against these Tables. Our FSSAI compliance support team helps prepare that mapping and the supplier specifications behind it.
Key takeaways
- Clause 2 covers agaric acid, hydrocyanic acid, hypericine and saffrole, with limits in ppm per food.
- Clause 3 covers PCBs (sum of six congeners) and benzo(a)pyrene in fish and fishery products.
- Units differ: PCB limits are in ppm and benzo(a)pyrene is in ppb.
- Serial 4 (saffrole) in clause 2 is substituted from 1 December 2026.
Read next
- Regulation 2.2.1(1): aflatoxin and crop contaminants
- Regulation 2.3.1: pesticide MRL Table
- Fish and fish products: FSSAI food standards
- Section 20, FSS Act: contaminants and naturally occurring toxic substances
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.