FSSAI’s Production Record Rule: Relief for Traders, But Dairy Industry Still Awaits Clarity

The Food Safety and Standards Authority of India (FSSAI) has finally notified the amendment mandating licensed food manufacturers to maintain daily records of production and raw material utilisation. The final gazette notification, issued on 23 June 2026, brings some welcome relief by exempting non-manufacturing food businesses from this requirement, reflecting concerns raised by industry stakeholders during the consultation process.

However, for the dairy sector, several operational questions still remain unanswered.

What Has Changed?

The amended regulation now clearly states:

"Maintain daily records of production, raw materials utilization separately: Provided that this condition shall not be applicable to non-manufacturing food businesses."

This effectively means that only manufacturing units are required to maintain such records, while traders, distributors, transporters and other non-manufacturing entities are outside its scope.

The notification also reiterates the requirement of following First-In-First-Out (FIFO) and First-Expire-First-Out (FEFO) principles for storage of raw materials, ingredients, work-in-progress and finished products, while exempting retailers from this provision.

A Partial Acceptance of Industry Concerns

When the draft notification was issued earlier this year, the dairy industry had expressed apprehensions regarding its practical implementation, particularly in a sector characterised by:

• Daily procurement from millions of smallholder farmers;
• Multiple product streams emerging from a single raw material input;
• Seasonal fluctuations in milk composition and product mix;
• Cooperative and village-level collection systems involving numerous intermediary stages.

The exemption granted to non-manufacturing businesses indicates that FSSAI has acknowledged concerns relating to excessive compliance burden on entities that merely handle or trade food products without undertaking manufacturing activities.

However, several sector-specific suggestions do not appear to have found explicit mention in the final regulation.

What the Dairy Industry Had Suggested

The dairy sector had broadly sought:

• Standardised digital formats for maintaining daily records;
• Clarification on record-keeping requirements for milk collection centres and chilling units;
• Recognition of the unique nature of dairy processing where a single input milk stream simultaneously generates multiple products and by-products;
• Reasonable flexibility for cooperative institutions handling milk procured from millions of farmers on a daily basis;
• Harmonisation with existing records already maintained under dairy quality assurance and traceability systems.

The final gazette notification remains silent on these operational aspects, leaving room for varied interpretations during enforcement.

Also Read my earlier article when suggestions were invited by FSSAI : Mandatory Daily Record of Production and Raw Material Utilisation

Dairy Plants Already Maintain Extensive Records

In reality, most organised dairy plants already maintain detailed daily production records as part of their standard operating procedures. Milk receipts, fat and SNF accounting, production planning, inventory management, by-product utilisation and batch traceability systems are integral components of modern dairy operations.

Therefore, the regulation may not significantly impact large organised dairies.

The greater challenge could emerge for smaller processors and cooperative systems where manual documentation continues to dominate and where clear implementation guidelines would be essential to avoid unnecessary compliance complications.

The Way Forward

The intent behind the regulation is undoubtedly aligned with strengthening traceability, improving food safety oversight and curbing adulteration. Better documentation can enhance accountability and facilitate quicker investigations whenever food safety incidents occur.

Yet, implementation success will depend on how practically the requirements are interpreted across different sectors.

For the dairy industry, FSSAI may still need to issue detailed guidance notes, standard record formats and sector-specific clarifications to ensure that compliance strengthens food safety without creating avoidable operational burdens.

The final notification represents a step towards greater traceability, but the journey towards truly practical and sector-sensitive implementation remains unfinished.

Download the FSSAI notification here

Comment on FSSAI Regulatory notification by Kuldeep Sharma Chief Editor Dairynews7x7