Fssai Compliance Requirements

FSSAI COMPLIANCE REQUIREMENTS

This Annexure forms an integral part of the LX India Seller Terms of Use and elaborates on the obligations referred to under “Category-Specific Regulatory Compliance” in relation to products listed under the Food and Nutrition category. This Annexure is binding on all Sellers who list, offer, or sell food products on the LX India Platform.

1. FSSAI Licensing and Registration Requirements

The Seller must possess and maintain a valid FSSAI license or registration at all times.
The Seller shall ensure that its valid FSSAI License Number is displayed on all food product listings published on the LX INDIA platform.
LX INDIA may verify the authenticity and validity of the Seller’s FSSAI license.
The Seller shall promptly provide any renewal, modification, amendment, or updated license documentation requested by LX INDIA.
The Seller shall ensure that it covers all food categories listed on the platform.
Listing or sale of food products without a valid FSSAI license is strictly prohibited.
The Seller shall maintain accurate and updated information on the Food Safety Compliance System (FoSCoS) portal and shall immediately update any changes in business details, product categories, manufacturing locations, or licensing particulars.

2. Listing Representations and Warranties The Seller hereby represents, warrants, and undertakes that:

All product information is true, accurate, complete, and not misleading.
Products comply with all applicable food safety and labeling laws.
Products are safe for human consumption and free from adulteration or contamination.
All food products listed on the platform are sourced only from legally authorized manufacturers, importers, distributors, or suppliers, and documentary evidence of such sourcing shall be maintained and produced upon request.

3. Regulatory Notification Obligation

The Seller shall immediately notify LX INDIA of:

suspension, cancellation, modification, expiry, or non-renewal of any licence;
any inspection, improvement notice, prosecution, seizure, enforcement action, or regulatory investigation;
any food safety complaint, illness, injury, contamination incident, product defect, adverse event, or recall situation;
any action initiated by FSSAI or any other competent authority.

4. Product Listing & Label Compliance

4.1 Mandatory Label Information All food products must display statutory information required under applicable FSSAI regulations, including but not limited to:

Product name
Ingredients
Nutritional information
Allergen declaration
Veg / Non-veg symbol
Manufacturer / importer details
FSSAI license number
Batch / lot details
Manufacturing and expiry dates
Net quantity
Country of origin (for imported goods)
Net quantity, MRP, and other declaration requirements in compliance with Legal Metrology (Packaged Commodities) Rules, 2011

4.2 Product Images Product images shall clearly display all sides of packaging and must not be edited or misleading.

4.3 Advertising and Claims Compliance

The Seller shall ensure that all advertisements, product descriptions, images, promotional content, health claims, nutrition claims, comparative claims, testimonials, endorsements, and marketing materials relating to food products comply with the Food Safety and Standards (Advertising and Claims) Regulations, 2018 and other applicable laws.
The Seller shall not make any false, misleading, deceptive, exaggerated, unsubstantiated, or scientifically unverified claims regarding the nature, quality, quantity, composition, nutritional value, health benefits, efficacy, or safety of any food product.
The Seller shall not represent any food product as preventing, treating, curing, or mitigating any disease unless expressly permitted under applicable law.

4.4 Shelf Life & Delivery Compliance

Products delivered to consumers shall comply with any minimum residual shelf-life requirements prescribed under applicable law, FSSAI guidelines, product-specific regulations, or LX INDIA policies from time to time.
The Seller shall ensure that no expired or near-expiry products are shipped or delivered.
The Seller shall ensure proper storage and transportation conditions to maintain product safety and integrity.

5. Hygiene and Manufacturing Standards

5.1 General Hygiene Requirements The Seller shall strictly comply with Schedule 4 hygiene standards under applicable FSSAI regulations.

5.2 Category-Specific Compliance

The Seller shall comply with all additional regulatory requirements applicable to specific food categories.
The Seller must ensure all required certifications, declarations, and approvals are valid and updated before listing such products.
The Seller shall ensure that food handlers and supervisory personnel receive appropriate food safety training.
Wherever required under applicable FSSAI regulations, the Seller shall appoint trained Food Safety Supervisors certified under the Food Safety Training and Certification (FoSTaC) program.
The Seller shall maintain product testing records and laboratory reports as required under applicable laws.

5.3 Imported Food Compliance

Sellers dealing with imported food products shall comply with the Food Safety and Standards (Import) Regulations, 2017 and all applicable customs and import clearance requirements.
Imported food products shall not be listed or sold unless all mandatory FSSAI import clearances have been obtained.
Sellers shall maintain records relating to import approvals, customs documentation, and regulatory clearances and provide the same upon request.

6. Packaging Compliance

All food products shall be packed in food-grade, hygienic, tamper-proof packaging suitable for storage, transport, and sale.
Packaging shall not contaminate food or affect its safety, quality, or composition.
Packaging materials shall comply with applicable Food Safety and Standards (Packaging) Regulations, 2018 and relevant Indian Standards.
Printed surfaces shall not come into direct contact with food.
Newspaper or any unsafe material shall not be used for food packaging.

Sellers shall refer to the Food Safety and Standards (Packaging) Regulations, 2018 for detailed technical specifications, migration limits, packaging material standards, and category-specific requirements.

7. Traceability and Record Retention The Seller shall maintain complete and accurate traceability records including:

supplier details;
customer details;
batch and lot numbers;
manufacturing dates;
expiry dates;
distribution records;
recall records;
laboratory testing reports;
import documentation (where applicable); and
regulatory correspondence.

Such records shall be retained for the period prescribed under applicable law and produced upon request by LX INDIA or any competent authority.

8. Prohibited Products The following categories are strictly prohibited:

Products restricted under FSSAI or DGFT notifications
Unsafe or non-certified food products
Genetically modified food not legally permitted
Misbranded or adulterated food
Any product listed in LX INDIA’s restricted-products list
Any item prohibited under applicable food safety or trade regulations

9. Audit and Inspection Rights

LX INDIA reserves the right to:

Conduct audits, inspections, and compliance checks, normally with reasonable prior notice to the Seller, except in cases involving urgent food safety concerns, where LX INDIA may conduct such audits or inspections without prior notice.
Request documentation and records from Sellers
Suspend or terminate listings for non-compliance
Report violations to authorities
Require Sellers to submit corrective and preventive action plans (CAPA) and implement remediation measures within prescribed timelines
Remove, suspend, reject, modify, delist, restrict, or disable any product listing, advertisement, claim, image, promotional content, or Seller account where LX INDIA reasonably believes that such content or activity violates applicable laws, regulatory requirements, platform policies, or consumer safety standards

10. Product Testing and Verification: LX INDIA may procure product samples and conduct independent laboratory testing, and require Sellers to provide laboratory reports, certificates of analysis, quality assurance records, product specifications, and other supporting documentation to verify compliance with applicable laws, food safety requirements, product claims, and quality standards.

11. Grievance Redressal Mechanism

LX INDIA shall appoint a Grievance Officer in compliance with the Consumer Protection (E-Commerce) Rules, 2020.
All consumer complaints related to food safety, quality, labeling, expiry, or delivery shall be acknowledged and addressed within prescribed timelines under applicable law.
Sellers shall cooperate in resolution of grievances and provide necessary documentation, replacement, refund, or recall support where required.
LX INDIA may escalate unresolved complaints to regulatory authorities where necessary.

12. Seller Undertaking: The Seller confirms that all information submitted is true, accurate, and legally valid. The Seller agrees to comply with all applicable laws and accepts full responsibility for all products listed and sold.

The Seller shall indemnify, defend, and hold harmless LX INDIA, its directors, officers, employees, affiliates, and representatives from and against any claims, losses, damages, penalties, recalls, costs, expenses, regulatory actions, or liabilities arising out of:

food safety violations;
contamination or adulteration;
product defects;
inaccurate labelling or misleading claims;
product recalls;
violation of applicable laws;
breach of this Annexure; or
negligence or misconduct of the Seller.

13. Food Recall Policy

13.1 Initiation of the Food Recall Process

The Seller shall initiate and implement a structured food recall process whenever any food product is identified or reasonably suspected to be unsafe, non-compliant, or in violation of applicable food safety laws, ensuring immediate action to protect consumer health and regulatory compliance.
The recall process shall be carried out in accordance with the Food Safety and Standards Act and applicable recall regulations, including all required steps such as product withdrawal, communication, reporting, and corrective action.
A recall may be initiated voluntarily by the Seller or mandated by the Chief Executive Officer of FSSAI, the Commissioner of Food Safety of any State or Union Territory, LX INDIA, or any other competent authority based on regulatory findings, complaints, audits, or safety alerts.
The Seller shall also initiate a recall upon receipt of any complaint, adverse report, or internal quality failure indicating that the food product may pose a risk to human health or fails to meet statutory requirements.
It shall be the responsibility of the Seller and all stakeholders in the supply chain to fully comply with recall instructions issued under this Policy.

13.2 Roles and Responsibilities of Sellers

The Seller shall establish and maintain effective systems and procedures to identify all food business operators, distributors, retailers, logistics partners, and customers to whom food products have been supplied, ensuring full traceability across the supply chain.
The Seller shall collaborate and cooperate fully with LX INDIA, FSSAI, and other competent regulatory authorities in taking necessary actions to prevent or reduce risks associated with any affected food product.
The Seller shall immediately remove any affected food product from sale, distribution, and supply upon identification of a safety issue or upon receiving recall instructions from LX INDIA or competent authorities.
The Seller shall develop, maintain, and implement a documented recall plan in accordance with FSSAI guidelines, and shall coordinate and share the recall plan with LX INDIA and regulatory authorities whenever required.
The Seller shall ensure timely and effective recall communication to all stakeholders in the supply chain, using appropriate communication channels such as email, phone, written notices, or digital and media platforms, ensuring that all communications are clearly marked as a food recall and treated as urgent.
The Seller shall provide periodic recall status reports during the recall process and ensure submission of such reports to LX INDIA and regulatory authorities at weekly intervals or as otherwise directed.
The Seller shall ensure that all recovered or returned food products are securely stored in a segregated area clearly marked as “RECALLED PRODUCT – NOT FIT FOR HUMAN CONSUMPTION” and shall prevent any possibility of re-entry into the market.
The Seller shall ensure proper investigation of the root cause of the recall and implement corrective and preventive actions to avoid recurrence of similar issues in future.
Upon completion of the recall process, the Seller shall submit a post-recall report to FSSAI within thirty (30) days and shall also provide a copy of the same report to LX INDIA within the same period.
The Seller shall designate a responsible recall coordinator or authorised representative and provide updated contact details to LX INDIA for recall management and regulatory communication purposes.

14. Additional Food Labelling and Product Information Requirements

Sellers shall ensure that all food product listings contain the mandatory information required under applicable FSSAI regulations and that the information displayed on the platform corresponds with the details available on the actual product packaging. The Seller shall provide clear, authentic, and updated product images, including images of the product packaging and labels, wherever required, to enable customers to verify important product details before purchase. All food product listings shall comply with the Food Safety and Standards (Labelling and Display) Regulations, 2020, and other applicable food safety laws.

14.1 Mandatory Product Information The Seller shall ensure that food product listings contain accurate information relating to:

Product Name and Description: accurately describing the food item, including applicable brand name, trade name, or description.
Nature and Composition: whether single-ingredient or multi-ingredient, with a complete ingredient list where applicable.
Ingredients Declaration: declared using appropriate names and arranged in order of quantity or proportion as required under applicable regulations.
Nutritional Information: energy value, protein, carbohydrate, fat, vitamins, minerals, and other required details, including supporting details for any nutritional or health-related claim.
Manufacturer, Packer, Brand Owner, or Importer Details: accurately disclosed.
Vegetarian and Non-Vegetarian Declaration: correctly displayed on packaging and reflected accurately in the listing.
FSSAI Logo and License Details: required FSSAI logo and valid FSSAI License/Registration number displayed as prescribed.
Net Quantity and Consumer Declarations: net quantity, weight, volume, number of units, MRP, consumer care details, and other mandatory declarations.
Instructions for Use and Storage Conditions: directions for preparation, usage, storage, or handling, where applicable.

14.2 Imported Food Products

Sellers dealing with imported food products shall ensure compliance with applicable FSSAI import requirements and disclose:

Importer name and address;
Importer FSSAI License details;
Country of origin;
Other mandatory declarations required under applicable laws.

14.3 Allergen Declaration Requirements

The Seller shall ensure that products containing allergens are appropriately declared, including but not limited to: cereals containing gluten, milk and milk products, eggs, fish, crustaceans, peanuts and tree nuts, soy, sulphites, and other regulated allergens. Allergen information shall be accurate, visible, and available to customers before purchase.

14.4 Food Additives Declaration

Where food additives are used, the Seller shall ensure that applicable declarations relating to the type, functional category, name, or identification details of such additives are provided in accordance with applicable FSSAI regulations.

14.5 Organic Food Products

Sellers listing organic food products shall comply with the Food Safety and Standards (Organic Foods) Regulations, 2017, and shall ensure organic claims are genuine and supported by applicable certification, required declarations and logos are displayed, and product information accurately represents organic status.

14.6 Vegan Food Products

Sellers listing vegan food products shall comply with the Food Safety and Standards (Vegan Foods) Regulations, 2022, and shall obtain applicable approvals/certifications, display required vegan logos and declarations, and ensure imported vegan products meet applicable certification requirements.

14.7 Fortified Food Products

Sellers listing fortified food products shall comply with the Food Safety and Standards (Fortification of Foods) Regulations, 2018, and shall display applicable fortification statements, logos, and declarations as required.

14.8 Ayurveda Aahara

Products Sellers listing Ayurveda Aahara products shall comply with the Food Safety and Standards (Ayurveda Aahara) Regulations, 2022, and shall ensure labels and listings contain the Ayurveda Aahara classification, intended purpose and target consumer group, recommended duration of use, required warnings/precautions/safety instructions, storage requirements, and mandatory declarations and logos.

14.9 Product Images and Listing Accuracy

The Seller shall provide genuine and accurate images of food products, including packaging and labels, wherever required. Product images, descriptions, claims, and other information shall not misrepresent the product, hide mandatory declarations, contain false or misleading information, or make unsupported health, nutritional, or therapeutic claims. The Seller remains solely responsible for the accuracy, completeness, and legal compliance of such information. LX INDIA reserves the right to remove, modify, restrict, or suspend any product listing containing inaccurate, misleading, incomplete, or non-compliant information.