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Regulations 5–8 of the Food Safety and Standards (Organic Foods) Regulations, 2017: labelling of organic food, the in-conversion label, traceability, other regulations and display by retailers

The label of organic food must convey full and accurate information on its organic status and may carry the certification mark of the system followed along with the FSSAI organic...

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Last updated: October 2026Verified against: Government sources

Regulations 5 to 8 of the Organic Foods Regulations, 2017 say how organic food must be labelled, how far back its traceability must reach, which other regulations it must satisfy (with a special limit for insecticide residues), and how a retailer must display it. Regulation 5(3), on in-conversion products, was inserted in 2021.

The text is read as amended up to 14 October 2021 (FSSAI Compendium Version II dated 01.06.2022). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in.

Regulation 5: labelling

5(1) requires the labelling on the package of organic food to "convey full and accurate information on the organic status of the product". The product "may carry a certification or quality assurance mark of one of the systems mentioned in regulation 4 in addition to the Food Safety and Standard Authority of India's organic logo". The word "may" is printed: the marks are permitted, and the requirement is accuracy. The logo itself is not described in these Regulations; the design sits in Schedule I to the Labelling and Display Regulations, covered in our article on the fortified and organic logos.

5(2) says all organic foods "shall comply with the packaging and labelling requirements specified under the Food Safety and Standards (Packaging and Labelling) Regulations, 2011 in addition to the labelling requirements under one of the applicable systems mentioned in regulation 4." That 2011 instrument has been replaced; the current rules are the Packaging Regulations, 2018 and the Labelling and Display Regulations, 2020, covered in our articles on packaging and the labelling and display general requirements. So an organic pack carries three layers: the general label rules, the labelling requirements of the system followed, and the accurate organic status statement. Brand owners often settle those layers through FSSAI label compliance review at artwork stage.

5(3) was inserted by the notification of 14 October 2021. It reads in two halves:

  • in-conversion products under PGS-India "may be labelled as 'PGS-Green' and may also be labelled as 'In-conversion to organic'";
  • the conversion products under NPOP "may be labelled as 'In-conversion to organic'" and "shall mention the year of conversion".

Both kinds of in-conversion product "shall not carry Food Safety and Standard Authority of India's organic logo". The text names the label wording and the logo bar, and does not say how large the words must be.

ProductLabel wording permitted (5(3))Year of conversionFSSAI organic logo
In-conversion under PGS-IndiaPGS-Green; In-conversion to organicNot stated for this limbNot to be carried
Conversion under NPOPIn-conversion to organicTo be mentionedNot to be carried

The reading of the "year of conversion" requirement is tied to the NPOP limb in the printed sentence; the text of the PGS-India limb does not repeat it.

Regulation 6: traceability

"Traceability shall be established upto the producer level as applicable under the systems mentioned in regulation 4 and it shall include any other requirements prescribed by the Food Authority to maintain the organic integrity of the food product." Two things follow. The end point is the producer, not the last intermediary, and the details come from the system followed (NPOP or PGS-India), plus whatever the Food Authority prescribes. The Regulations do not themselves list a record format. For the general idea of tracing one step back and one step forward, see our piece on traceability for food businesses.

Regulation 7: other regulations and the residue limit

Regulation 7 says that, without prejudice to these Regulations, organic food "shall comply with the relevant provisions, as applicable" under the Food Products Standards and Food Additives Regulations, 2011. It must also comply with the relevant provisions of the Contaminants, Toxins and Residues Regulations, 2011, "except for residues of insecticides for which the maximum limits shall be 5% of the maximum limits prescribed or Level of Quantification (LoQ) whichever is higher."

Read the sentence in three parts: the general contaminant limits apply; for insecticide residues only, the ceiling is tightened; and the tightened ceiling is the higher of two numbers, 5% of the prescribed maximum or the LoQ. The Regulations do not show an example calculation and this article does not compute one. The prescribed maxima are in the MRL table of the Contaminants Regulations (see our article on the pesticide MRL table).

Regulation 8: display

"The seller of organic food either exclusively or as part of his retail merchandise shall display such food in a manner distinguishable from the display of non-organic food." It applies to an exclusive organic store and to a general retailer with an organic section. The text sets no shelf measurements; the test is whether a shopper can tell organic from non-organic at a glance.

An invented example: Sahyadri Naturals packs millet flour under an organic claim certified under NPOP and sells through Anand Provisions, a general store. The pack shows an accurate organic status statement and the certification mark; the store keeps the pack in a marked organic section, away from conventional flour. If a lot of the same millet were still in conversion, the pack would instead say "In-conversion to organic", mention the year of conversion and leave off the FSSAI organic logo.

What the Regulations do not say

The text does not set a form for the traceability record, a size for the label statement, or a penalty. Penalties for misbranded or sub-standard food sit in the Act; see our articles on selling misbranded food (section 52) and misleadingly labelled food (section 53). The first part of the instrument is in our article on regulations 1 to 4.

Need help with an organic label?

Organic claims invite scrutiny because the label, the certification system and the traceability file must all say the same thing. Our FSSAI label compliance service can check the wording, the logo use and the in-conversion statement before you print.

Key takeaways

  • The label must convey full and accurate information on organic status; the certification mark and the FSSAI organic logo may be carried.
  • In-conversion products use the wording in regulation 5(3) and never carry the FSSAI organic logo.
  • Traceability runs up to the producer level.
  • Insecticide residue ceiling: 5% of the maximum limits prescribed or the LoQ, whichever is higher.
  • Organic food must be displayed in a manner distinguishable from non-organic food.

Read next

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.

Quick recapKey facts & short answers

Key Facts About Organic Food

  • 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.

Can an in-conversion product carry the FSSAI organic logo?

No. Regulation 5(3) says such products "shall not carry" the logo.

What label words are allowed for in-conversion produce?

Under PGS-India, 'PGS-Green' and 'In-conversion to organic'; under NPOP, 'In-conversion to organic' with the year of conversion.

Read the notice the day it arrives; most of the damage is done by the weeks it sits unopened.

— TaxClue Compliance Desk

Organic Food: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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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.

No. Regulation 5(3) says such products "shall not carry" the logo.

Under PGS-India, 'PGS-Green' and 'In-conversion to organic'; under NPOP, 'In-conversion to organic' with the year of conversion.

Up to the producer level, as applicable under the systems in regulation 4, plus any other requirements the Food Authority prescribes.

Maximum limits of 5% of the maximum limits prescribed or the Level of Quantification, whichever is higher (regulation 7).

The text prints that reference; those 2011 Regulations have been replaced by the Packaging Regulations, 2018 and the Labelling and Display Regulations, 2020.

To display organic food in a manner distinguishable from non-organic food.