Schedule V 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.
Schedule V to the Advertising and Claims Regulations, 2018 is headed "Use of certain words or phrases" and sets the conditions for six groups of words that brands use constantly: natural, fresh, pure, authentic (with genuine and real), traditional and original. Regulation 9(2) makes the Schedule binding, and regulation 4(7) adds a disclaimer where a brand name is misleading.
The text is read as amended up to 13 December 2022 (FSSAI Compendium Version IV dated 14.12.2022). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in. Packs that use these words can be checked through FSSAI label compliance.
"Natural" is for a single food to which nothing has been added and which has been subjected only to listed processing; composite foods may be described as "made from natural ingredients". "Fresh" is for products not processed except washed, peeled, chilled, trimmed or cut (and a few permitted steps). "Pure" is for a single ingredient food to which nothing has been added. "Traditional" needs a product that has existed for a generation (thirty years).
The six rows
Schedule V, referred to in regulation 9(2), lists words in column 1 and conditions in column 2. The rows are described one by one.
1. Natural
The word may be used to describe:
- (a) a single food, derived from a recognised source (plant, animal, microorganism or mineral), to which nothing has been added and which has been subjected only to processing that renders it suitable for human consumption, such as: smoking without chemicals, cooking processes such as roasting, blanching and dehydration and physical refining; freezing, concentration, pasteurization, sterilisation and fermentation; and packaging done without chemicals and preservatives;
- (b) permitted food additives obtained from natural sources by appropriate physical processing;
- (c) composite foods shall not themselves be described directly or by implication as "natural", but may be described as "made from natural ingredients" if all the ingredients or food additives meet the criteria in (a) and (b).
A first proviso extends the principles to words such as "real" and "genuine" when used in place of "natural" in a way that implies similar benefits. A second proviso bars claims such as "natural goodness", "naturally better" and "nature's way".
2. Fresh
"Fresh" shall only be used on products not processed in any manner except washed, peeled, chilled, trimmed or cut, irradiated by ionizing radiation not exceeding 1 kGy, or other processing necessary for making the product safe for consumption without altering its basic characteristics. Clause (b): "fresh" or "freshly" has no other connotation than the immediacy of the action being described; a food containing additives or subjected to packaging, storing or other supply chain processes that control freshness shall not be termed "freshly stored" or "freshly packed". A proviso permits "fresh" with "frozen" if clear from context: "Frozen from fresh", "fresh frozen", "Freshly frozen".
3. Pure
"Pure" shall only be used for a single ingredient food to which nothing has been added, and which is clear of avoidable contamination, with the levels of unavoidable contaminants below the levels prescribed in the Contaminants, Toxins and Residues Regulations, 2011 or in any other standard under the Act. Compound foods shall not generally be described, directly or by implication, as "pure", but may be described as "made with pure ingredients" if all ingredients meet the criteria in (a). The contaminant limits are in our article on metal contaminants.
4. Authentic, Genuine, Real
These terms may be used only if the label or advertisement also clarifies in what way the overall quality is tangibly justified and why the particular term has been used.
5. Traditional
"The term 'traditional' shall demonstrably be used to describe a recipe, fundamental formulation or processing method for a product that has existed for a generation (thirty years), should have been available substantially unchanged, for that same period."
6. Original
- (a) "Original" shall only describe a food made to a formulation whose origin can be traced and which has remained essentially unchanged over time. It should not contain replacements for major ingredients. It may describe a process if it is the process first used in making the food and has remained essentially unchanged, although it may be mass-produced.
- (b) To be termed "original", a product shall not have changed to any material degree and shall remain available as the "standard" product when new variants are introduced. A product re-introduced after a period of absence may be described as "original" only if it can be shown to meet these criteria.
The table in short
| Word | Core condition |
|---|---|
| Natural | single food, nothing added, only listed processing; composites "made from natural ingredients" |
| Fresh | not processed beyond washing, peeling, chilling, trimming, cutting, irradiation not exceeding 1 kGy or processing for safety |
| Pure | single ingredient food, nothing added, contaminants below prescribed levels |
| Authentic / Genuine / Real | the label or advertisement must say how overall quality is tangibly justified |
| Traditional | recipe, formulation or method existing a generation (thirty years), substantially unchanged |
| Original | traceable formulation, essentially unchanged, no replacement of major ingredients |
Footnotes in the compendium show some wording as omitted by amendment against "Fresh" and "Pure"; the printed text above is what stands.
How the Schedule is triggered
Regulation 9(2) says claims containing adjectives such as these, "when used", shall accord with Schedule V. Regulation 4(7) separately requires a front-of-pack disclaimer, in the font sizes printed there, where a brand name, trade mark or fancy name containing these adjectives is likely to mislead; see our article on regulations 3 and 4. Regulation 9(2) also bars "home-made" and "home cooked" (see regulations 8 to 10).
An invented example: Kumar Spices sells a masala blend as "Pure Original Masala" and a single-origin ground turmeric as "Pure Turmeric". The turmeric, with nothing added and contaminants below the prescribed levels, can meet the "pure" condition. The blend is a compound food and cannot be called "pure", but could say "made with pure ingredients" if all ingredients meet the condition. "Original" requires a traceable, essentially unchanged formulation that stays on the market as the standard product when new variants arrive. If the name is a brand name likely to mislead, regulation 4(7) requires the disclaimer.
Where to read next
The other claim rules are in regulation 5 and Schedule I and regulations 8 to 10. For the overall labelling picture see FSSAI labelling requirements.
Need help with these words on a label?
Names and slogans using natural, fresh or pure are the commonest cause of claim queries. Our FSSAI label compliance team can check each word on your pack against Schedule V and advise on the brand-name disclaimer.
Key takeaways
- Natural, fresh, pure, authentic, genuine, real, traditional and original each have printed conditions.
- Composite foods are not "natural" or "pure" but may be "made from natural ingredients" or "made with pure ingredients" if every ingredient qualifies.
- "Traditional" needs thirty years of substantially unchanged availability.
- "Authentic", "genuine" and "real" need the label to say how quality is tangibly justified.
- A misleading brand name needs the front-of-pack disclaimer in regulation 4(7).
Read next
- Regulations 3 and 4: general principles for claims
- Regulations 8–10: dietary, conditional and prohibited claims
- FSSAI labelling requirements: complete guide
- Health and nutritional claims on food labels
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.