September 30, 2021

Mandatory to mention FSSAI License Number on Invoices/Bills/Receipts etc.

Food Safety and Standard Authority of India (“FSSAI”) License is mandatory to be obtained by every person who is engaged in food business operator (“FBO”), whether manufacturer or trader, such as Restaurants, cloud kitchens, manufacturers of food items, mithai shops, caterers, etc. FSSAI license must be obtained before commencement of business. FSSAI License is issued to ensure that food provided by business has undergone quality check and no food adulteration practice is adopted by business and food provided is of standard quality.

Presently, it is mandatory to mention FSSAI license Number on all Packaged food labels.

1. Issues in providing FSSAI License Number only on labels of Food packages

Presently, it is mandatory to mention FSSAI license Number on Label of food package. However, an issue will arise for FBOs where food is not provided in packages such as Restaurants, Mithai Shops, caterers etc. Further, it is also mandatory to display “Food safety Display Boards” all the time at the prominent places of the FBO.
However, Food business ecosystem is large and the FSSAI license of every FBO is not easily available and visible to consumer/service recipients.
If any consumer have any grievance and he is not available with FSSAI Number then expecting him to complain with complete details is impossible. Even it will be difficult for the regulator to trace the origin of complaint and attend to it promptly with approximate addresses.
Any Credible regulatory structure would completely depend on how strong is the consumer grievance redressal structure.
To trace database, a unique locator code is required and the same is FSSAI number for food safety.

2. Mandatory mention of FSSAI License Number on Invoices/Bill/Receipts etc.

2.1 Requirement to mention FSSAI License Number

To resolve issue of limit access of FSSAI License number to consumers, Food Safety and Standard Authority of India has made it compulsory to mention 14 digits FSSAI license or registration number on all cash receipts/purchase invoices/cash memo/bills/receipts etc. by all FBOs.
Where more than one documents are issued for a transaction eg. Invoice and Receipt voucher, then it is mandatory to mention FSSAI on both documents.
Exemption: FSSAI is not required to be mention on government documents which are system generated such as e-waybill.

2.2 Benefits of mentioning FSSAI License Number

Access to Information about Business:
- With FSSAI number, a consumer shall have access to entire information about FBO which is publically available on FSSAI portal.
- To access such information, a consumer can simply visit FSSAI portal or “Food Safety Connect” app. Information about FSSAI license can be access by entering 14 digit FSSAI registration number.
Easy Compliant Lodge:
- A consumer can lodge an online complaint against any FBO using the FSSAI Number. It is easy for the regulatory authority to trace the business unit and resolve the issue. Many complaints remained unresolved due to lack of specific information.

General awareness about FSSAI:
- General public is aware about GST number since same in mentioned on all the invoices.
- Similarly, mentioning of FSSAI on invoices and receipts will spread the awareness among consumer about FSSAI and if the same is not mentioned, it will indicate the non-compliance on part of FBO. This requirement is also expected to generate public demand and will create pressure for all FBOs to seek FSSAI License/registration.

Easy traceability of trail of pre-packaged foods from manufacturer to consumers:
- In case of pre-packaged foods, FSSAI number is available. However, it is not possible to consumer to track the complete path of package from manufacturer to consumer.
- Mentioning FSSAI on invoice will help in resolving this issue and will improve the traceability of food products.

Minimum Compliance Cost:
- No new transaction document is being mandated to be issued. Revised provisions will help to leverage the existing commercial transactions practise and the regulatory requirement under tax laws. Thus, FSSAI seek to maintain the minimum compliance cost and still have enhanced data dissemination and disclosure.

3. Date of implementation of Revised Provisions

Requirement of mentioned FSSAI on all invoices, cash receipts, bills etc. shall come into effect from 1st October 2021.

DISCLAIMER: The views expressed are strictly of the author and VJM & Associates LLP. The contents of this article are solely for informational purpose. It does not constitute professional advice or recommendation of firm. Neither the author nor firm and its affiliates accepts any liabilities for any loss or damage of any kind arising out of any information in this article nor for any actions taken in reliance thereon.

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