FSSAI Relabeller License: Documents Required and Process

Introduction

Many food businesses today operate by creating their own brand while outsourcing the manufacturing process to another food manufacturer. In such cases, the business may not manufacture the product itself but sells the food product under its own brand name.

 

Such businesses need to understand the correct FSSAI classification before applying for a licence. If a business gets food products manufactured or processed by another licensed Food Business Operator (FBO) and sells those products under its own brand, it may fall under the relabeller category based on the applicable Kind of Business (KoB).

 

Obtaining the correct FSSAI Relabeller License helps businesses comply with food safety requirements and operate their food brand legally.

 

The documents required for an FSSAI licence depend on factors such as the nature of activity, product category, licence type, and the documents applicable through the FoSCoS portal. FSSAI has prescribed KoB-wise document requirements, meaning requirements may differ depending on the type of food business activity.

 

Businesses planning to start a food brand can complete the required FSSAI License Registration based on their actual business activity.

 

 

What Is an FSSAI Relabeller License?

An FSSAI Relabeller License is applicable to businesses that source food products from another manufacturer and sell those products under their own brand name.

 

A relabeller generally does not carry out the manufacturing process at its own premises. Instead, the product is manufactured by another licensed manufacturer, and the relabeller markets or sells the product under its own brand.

 

For example:

• A company launches a packaged food brand.
• A third-party manufacturer produces the food product.
• The company sells the product under its own brand name.

In this situation, the company may require an FSSAI Relabeller License depending on its activity classification under FSSAI.

 

The manufacturer and relabeller are separate Food Business Operators. Therefore, both parties need to ensure compliance with applicable food safety requirements.

 

A relabeller must also ensure that product labels and other food-related information comply with applicable FSSAI regulations.

 

 

Difference Between Manufacturer and Relabeller Under FSSAI

Understanding the difference between a manufacturer and a relabeller is important because the compliance requirements are different.

 

Manufacturer

A manufacturer is involved in activities such as:

• Manufacturing food products
• Processing food items
• Operating production facilities
• Using machinery and equipment for production

Manufacturing and processing units generally require documents related to their production facility, such as blueprint/layout plans, machinery details, and applicable activity-specific documents. These requirements are linked with manufacturing and processing activities.

 

Relabeller

A relabeller generally performs activities such as:

• Sourcing products from a manufacturer
• Selling products under its own brand name
• Managing branding and distribution
• A relabeller does not carry out the actual manufacturing process at its own facility.

Therefore, manufacturing-related documents generally relate to the manufacturer’s production activity. However, the relabeller must submit documents applicable to its own licence category and business activity.

 

 

Documents Required for FSSAI Relabeller License

The FSSAI Relabeller License Documents Required may vary depending on the business structure, product category, and type of licence applied.

 

Generally, the following documents may be required:

 

1. Business Constitution Documents

The applicant needs to provide business-related documents according to the legal structure of the business.

 

These may include:

• Certificate of Incorporation for Private Limited Companies
• LLP Agreement for LLPs
• Partnership Deed for partnership firms
• Proprietorship declaration for proprietorship businesses
• Memorandum and Articles of Association, wherever applicable

Businesses planning to establish a food brand may also consider MSME Registration for applicable business benefits.

 

2. Identity and Address Proof

The applicant or authorised signatory may need to provide:

• PAN Card
• Aadhaar Card or other government-issued identity proof
• Address proof
• Passport-size photograph

These documents help verify the details of the proprietor, partners, directors, or authorised representatives.

 

3. Premises Proof

The applicant may need to provide proof of possession of the premises.

 

Common documents include:

• Rent agreement
• Electricity bill
• Sale deed
• Other accepted ownership or possession documents

The exact requirement depends on the licence category and application details.

 

 

Manufacturer Documents Required for Relabeller

Since a relabeller obtains products from another manufacturer, manufacturer-related details are an important part of the application.

 

Generally, the applicant may need to provide:

• Valid FSSAI licence copy of the manufacturer
• Manufacturer details
• Product details
• Manufacturing arrangement details

The manufacturer should hold a valid FSSAI licence covering the relevant products supplied to the relabeller.

 

 

Manufacturer NOC for FSSAI Relabeller

A Manufacturer NOC for FSSAI Relabeller is an important supporting document for the application.

 

As per FoSCoS document requirements, NOC and copy of licence from manufacturer are mandatory for relabellers and repackers.

 

The NOC serves as supporting documentation confirming the arrangement between the manufacturer and relabeller for the products covered under the application.

 

Maintaining proper documentation between the manufacturer and relabeller helps establish clarity regarding product supply and compliance responsibilities.

 

 

Is Plant Blueprint Required for FSSAI Relabeller License?

A common question among businesses is whether a manufacturer’s plant blueprint is required while applying for an FSSAI Relabeller License.

 

A blueprint or layout plan of the processing unit is generally related to manufacturing and processing units because it represents the physical production facility.

 

A relabeller that does not carry out manufacturing or processing activities at its own premises generally needs to provide documents applicable to its relabelling activity along with manufacturer-related documents.

 

However, additional documents may be required depending on:

• Selected Kind of Business
• Product category
• Licence type
• Requirements raised during application review

Therefore, businesses should check the applicable FoSCoS document checklist before submitting the application.

 

 

Is Machinery Detail Required for FSSAI Relabeller License?

Machinery and equipment details are generally associated with businesses involved in manufacturing or processing activities.

 

A relabeller that only sources food products from an approved manufacturer and sells them under its own brand generally does not operate the manufacturing machinery.

 

However, if the business also carries out any manufacturing, processing, repacking, or other food-related activity, additional requirements may apply based on the selected Kind of Business.

 

Therefore, while applying for an FSSAI Relabeller License, businesses should select the correct activity and provide documents applicable to their actual operations.

 

 

Is Water Test Report Required for FSSAI Relabeller License?

Water analysis reports are generally applicable to manufacturing and processing units where water is used in food production or as an ingredient.

 

For example, where a food business manufactures or processes products using water, applicable water analysis reports may be required as part of the licensing documentation.

 

A relabeller that does not carry out manufacturing or processing activities should evaluate the requirement based on its actual business activity.

 

The requirement depends on:

• Type of food activity
• Selected Kind of Business
• Product category
• Applicable FSSAI requirements

Businesses should avoid assuming that the same documents apply to every food business category.

 

 

FSSAI Relabeller Registration Process

The FSSAI Relabeller Registration Process involves submitting the application through the FoSCoS portal along with applicable documents.

 

The general process includes the following steps:

Step 1: Identify Applicable Kind of Business

The first step is to identify whether the business activity falls under relabelling or another category. Selecting the correct Kind of Business is important because the documents and compliance requirements depend on the activity selected.

 

Step 2: Prepare Required Documents

The applicant should prepare documents including:

• Business constitution documents
• Identity and address proof
• Premises-related documents
• Manufacturer licence copy
• Manufacturer NOC
• Product details

The exact documents may vary depending on the licence category and application requirements.

 

Step 3: Submit Application on FoSCoS Portal

The applicant needs to:

• Complete the online application form
• Upload required documents
• Provide product and business details
• Pay applicable government fees

The application should contain accurate information to avoid delays during scrutiny.

 

Step 4: Application Review and Clarification

After submission, the application is reviewed by the concerned food safety authority.

 

If additional information or clarification is required, the applicant may receive a query.

 

The applicant should respond with the required documents or clarification within the applicable timeline.

 

Step 5: Licence Issuance

After successful verification and approval, the FSSAI licence is issued.

 

After receiving the licence, the business must continue following applicable food safety and labelling requirements.

 

 

Compliance Requirements After Obtaining FSSAI Relabeller License

Obtaining an FSSAI Relabeller License is not the final compliance requirement. Businesses must continue maintaining food safety standards and regulatory requirements.

 

1. Maintain Product Label Compliance

Relabellers should ensure that product labels comply with applicable FSSAI labelling regulations.

 

Labels should contain accurate information relating to:

• Product name
• Ingredients
• Manufacturer details, wherever applicable
• FSSAI licence details
• Other mandatory declarations

Incorrect or incomplete labelling may result in compliance issues.

 

2. Maintain Manufacturer Records

A relabeller should maintain proper records relating to:

• Manufacturer details
• Product batches
• Supply records
• Purchase invoices
• Agreements with manufacturers

Maintaining records helps establish product traceability.

 

3. Maintain Traceability and Recall Records

Food businesses should maintain appropriate systems for product traceability and recall, wherever applicable.

 

These records help identify products, batches, and supply channels in case any food safety issue arises.

 

4. Renew FSSAI Licence on Time

An FSSAI licence is issued for a specific validity period. Businesses should track licence expiry dates and complete FSSAI License Renewal within the applicable timeline to continue operations.

 

 

FSSAI License for Relabelling Business Through E-Commerce Platforms

Many food brands operate through online marketplaces while using third-party manufacturers.

 

For such businesses, it is important to ensure that:

• The correct FSSAI category is selected
• The manufacturer holds a valid FSSAI licence
• Product labels comply with applicable requirements
• Business registrations are maintained properly

Online food sellers should also evaluate applicable tax compliance requirements. Businesses meeting the applicable conditions can complete GST Registration to comply with GST requirements. Since relabellers generally sell products under their own brand name, protecting the brand identity is also important. Businesses can consider Trademark Registration for Food Brand to protect their brand name and identity.

 

 

Common Mistakes While Applying for FSSAI Relabeller License

 

1. Selecting the Wrong Business Category

Some businesses select manufacturing activity even when they only perform relabelling activities. Selecting the correct Kind of Business helps ensure proper documentation and compliance.

 

2. Not Providing Manufacturer Details

Incomplete manufacturer information can lead to application queries or delays. The relabeller should maintain proper manufacturer details and supporting documents.

 

3. Missing Manufacturer NOC

A missing manufacturer NOC or licence copy can affect the completeness of the application. Businesses should collect all applicable documents before submission.

 

4. Ignoring Product Label Requirements

Selling food products under a brand name requires compliance with applicable labelling requirements. Businesses should review labels before launching products in the market.

 

5. Not Maintaining Compliance After Licence Approval

Obtaining the licence is only the beginning. Businesses must continue maintaining records, product compliance, and renewal requirements.

 

 

Launch Your Food Brand? Get Your FSSAI Relabeller License the Right Way

Building a food brand is exciting, but compliance should come first. If you source products from a manufacturer and sell them under your own brand name, getting the right FSSAI Relabeller License is an important step. From document preparation to application filing, Ebizfiling helps businesses understand the requirements, arrange the necessary documents, and complete the licensing process smoothly.

 

Whether you are starting a new food brand or expanding your existing product range, our experts can assist you with FSSAI registration and compliance support.

 

Start Your FSSAI Relabeller License Process with Ebizfiling Today!

 

 

Conclusion

An FSSAI Relabeller License is required for businesses that obtain food products from another manufacturer and sell them under their own brand name, subject to the applicable FSSAI classification.

 

The requirements for relabellers are different from manufacturing units. Documents such as blueprint, machinery details, and water analysis reports are generally linked with manufacturing and processing activities, while relabellers need to provide documents applicable to their own activity along with manufacturer-related documents.

 

A proper understanding of the FSSAI License for Relabelling Business requirements helps businesses avoid incorrect applications and compliance issues. Businesses should review their actual business model, product category, and FoSCoS requirements before applying.

 

 

Frequently Asked Questions