What changed
Pb limit tightened from 1.0 to 0.5 ppm in finished nutra products. This affects herbal and mineral-supplemented products most.
Mandatory testing added for two emerging contaminants: phthalate residue and microplastic load. Per-batch cost adds ₹2,400 – ₹3,800 at notified labs.
Label format updated for serving-size disclosure — brands must show per-serving and per-100g of active in standardised format.
Upstream provenance documentation now mandatory — brands must document supplier chain back to original processor.
Brand-side action
Re-test in-market SKUs within the 90-day grace window. Pull samples from current production and test against the new Pb limit.
Update label templates before October printing slots. Pre-print only once amendment text is final (expected by July).
Re-qualify raw-material suppliers against the new Pb limit. Some currently-acceptable herbal raw materials will fail at 0.5 ppm.
Partner-side action
Add the two new tests to standard COA template. Most Tier-1 notified labs already offer the assays — confirm coverage with your lab.
Update provenance documentation system. Most partners have informal supplier records; the amendment requires formal documentation suitable for audit.
Sunset timeline
October 1, 2026: amendments effective. 90-day grace for in-market inventory.
January 1, 2027: all in-market SKUs must comply or be withdrawn. Notice-period for non-compliant SKUs starts.
April 1, 2027: licences may be suspended for non-compliant manufacturers.
- ›Q2 2026: Re-qualify raw-material suppliers
- ›Q3 2026: Re-test in-market SKUs
- ›Sep 2026: Update label artwork, lock printing slots
- ›Oct 2026: Amendments effective
- ›Jan 2027: Grace window ends, sunset begins
- ›Apr 2027: Licence suspension risk for non-compliant
§ KEY TAKEAWAYS
- 01Re-test in-market SKUs in the 90-day window
- 02Update labels before October printing slots
- 03Re-qualify upstream suppliers against new Pb limit
- 04Build provenance documentation system now, not at audit
- 05Phthalate and microplastic assays add ₹2.4 – ₹3.8k per batch
- 06Q4 2026 is the highest-risk operational window — plan capacity
§ GLOSSARY
Technical jargon, acronyms and scientific terms used in this file — decoded.
- Nutraceutical licence
- FSSAI category-specific licence required to manufacture or import nutraceutical products under Schedule VIII.
- Schedule VIII
- FSSAI regulation listing permitted ingredients, dosages and label disclosures for nutraceuticals and health supplements.
- Health-claim register
- FSSAI-approved list of substantiated health claims; using an off-list claim invites notice and product recall.
- Front-of-pack labelling
- Mandatory front-facing nutritional warnings (high sugar, salt, saturated fat) being phased in for packaged foods.

