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Clarity in regulations helps support global food trade, especially in a heavily regulated country like India. Of the many rules that apply to food imports within India, labelling requirements governed by FSSAI (The Food Safety and Standards Authority of India) remain the most operationally sensitive. Even small changes will require changes to how companies package their products, move their inventory, and clear products through customs. In order to make compliance easier for businesses, the FSSAI established a timeline for making changes to FSSAI labelling requirements during the 48th meeting of the FSSAI Food Authority. In addition to being a step to reducing uncertainty around compliance timelines by companies, an essential part of this new FSSAI policy is a minimum transition period of 365 days from when the changes are announced to when they will be enforced, starting on July 1st. As a result, the structure of compliance will continue to change the way food is imported into India up to 2026. However, it is anticipated that these changes will yield the best possible benefits to importers when they are also made through the Free Trade and Warehouse Zones (FTWZ) programme.
The 365-Day Transition Rule: What It Means for FSSAI Labelling
The recently revised policy requires a minimum one-year timeframe for Food Importers to prepare for amendments to the Food Safety and Standards (Labelling and Display) Regulations and any amendments to Labelling made within other regulations of the FSSAI. The goal of this extended transition period is to establish a procedural and phased approach for Food Businesses to implement compliance with new regulatory requirements. This policy will assist Food Importers by addressing FSSAI Labelling challenges that have existed for many years, such as:
- Long manufacturing/packaging cycles abroad
- Extended times between manufacturing and selling products
- When products are packaged internationally, they may not have been packaged with the Indian Labelling Regulations in mind
- Prior manufactured labels for products that have been-
- Not properly stored after being shipped to India
The New Policy provides a degree of structure; however, how inventory is stored, managed, and sold to the Indian market will determine how effective this policy will be in assisting Food Importers with new labelling Regulations.
Why Transition Periods Alone Are Not Enough
Although the transition period of 365 days gives businesses time to transition to the new rules, it does not solve operational issues for many importers, including:
- Dedicated storage facilities to hold transitional inventory
- A compliant environment for implementing FSSAI labelling updates
- Flexibility for releasing items when they meet all compliance standards
- Protection from duty liability for inventory that does not yet meet compliance standards
If businesses do not have the appropriate structures in place to utilize the transition period effectively, it is likely an opportunity that they will miss. It is here that FTWZs play an important role.
FTWZs: Extending the Value of the 365-Day FSSAI Labelling Window
Imported products held in FTWZ are eligible to remain in the warehouse until the importer has cleared them through the local importer customs process (Domestic Tariff Area [D.T.A.]) prior to paying any duties to customs. This regulatory provision allows the transition period (365-day FSSAI Labelling Rule) to become an operational advantage for the importers.
- Duty Deferral During Transition- Goods stored in FTWZs remain under customs bond, allowing importers to defer customs duty while assessing and implementing new FSSAI labelling requirements. This is especially beneficial when imported food stock cannot be immediately cleared due to pending label updates. The combination of duty deferment and regulatory transition reduces financial exposure during compliance adjustments.
- Controlled Labelling and Re-Labelling Within FTWZs- Regulatory Supervision for FTWZs supports labelling and re-labelling and repackaging services approved by the FSSAI through a controlled environment. The 365-day transition period enables importers:
- To transition their imported products labelled in accordance with the new amendments to the FSSAI labelling system on an incremental basis.
- To segregate and categorise their transitional product inventory from their compliant product inventory.
- To avoid the need for immediate or port based Re-labeling.
- A controlled environment allows for compliance to be stored without affecting supply continuity.
- Segregation of Inventory under the FSSAI Labelling Transition- Through the 365-day transitional provision, FTWZs allow importers to manage numerous batches of inventory produced in accordance with different regulatory Schemas.
- Through FTWZs, importers are permitted to:
- Maintain segregated storage for inventory labelled in accordance with the FSSAI Labelling System.
- Release all compliant stock in the domestic market on a phased basis.
- Promote optimal inventory turnover without placing burdensome clearance time limits.
This model applies primarily to food categories that experience an excessive amount of SKU Counts or where there are frequent amendments to the labelling requirements.
- Eliminating Port-Level Delays and Risk of Noncompliance- Prior to the FSSAI Labelling Rule, cargo that was held on account of non-compliance with the FSSAI Labelling Rule was often held up at ports causing congestion, expense for storage and delays in clearing cargo. The time a product arrives at a port without any buffer for compliance creates logistical constraints on the goods being delivered to the importer. FTWZ’s move compliance activity away from the ports and into designated facilities that will provide the ability to expedite compliance-related activity without relying on the port’s infrastructure for providing labels and subsequently eliminating the risk of delays for the importer in regard to clearance of their goods. extenuating circumstances. If there is an urgent need to change the current policy due to health, safety or consumer issues, this flexibility is critical.
- Emergency Amendments and the Need for Compliance Flexibility- According to the FSSAI policy regarding emergencies, the timeline for implementing the FSSAI Labelling Rule will be determined on an individual basis, and therefore will not necessarily have to meet the 365-day transition period. In instances where an importer is unable to achieve compliance due to emergency circumstances, FTWZ’s will enable the importer to place affected inventory on hold, prevent the affected inventory from entering into the marketplace, and allow the importer to implement corrective actions for their labelling and not incur an immediate financial loss. This provides these importers with much-needed flexibility as the regulations for food continue to grow and change in light of changes in health, safety, and protection of consumers.
Why the 365-Day Rule Makes FTWZs More Relevant in 2026
FSSAI labelling regulations are becoming more structured & systemic, therefore Compliance Planning must now be built-in to the Supply Chain Design from day one and not be considered a reactive post-import activity. The 365-day Transitional Rule promotes this shift towards planned compliance versus reactive correction. The transition rule and the FTWZs create a more resilient, compliant import supply chain model through:
- Compliance Time Buffers
- Cost-Efficient Storage Under Bond
- Approved Environment for Labelling Value-Added Services
- Greater Control Over When Products Enter the Market
Role of OSV FTWZ in Supporting FSSAI Labelling Compliance
OSV FTWZ offers an FTWZ warehouse to help food importers to meet the new FSSAI Labelling amendments for their products during the 365-day transition period. OSV FTWZ allows food importers to defer their import duties until all products have been relabeled in accordance with the new FSSAI requirements. In the OSV FTWZ facility, food importers can complete approved labelling and relabelling operations in a controlled environment, which allows for a more efficient way to manage the food importers’ transition stock, and reduce delays at ports. Additionally, the OSV FTWZ facility allows food importers to separate their compliant and non-compliant stock, which further assists with the structured and compliant movement of product as the regulatory timeline evolves with the new FSSAI Labels.
Conclusion
The 365-day transition period for FSSAI labelling offers importers valuable compliance clarity, but its impact depends on effective execution. FTWZs, supported by facilities like OSV FTWZ, enable duty-deferred storage, controlled relabelling, and phased market entry—making regulatory compliance more efficient and predictable in 2026.