FSSAI Relabelling License (commonly called the Relabler License) is one of the most misunderstood categories in FSSAI regulations. With the latest regulatory updates on FoSCoS, Brand Owners involved in white-labelling or contract manufacturing are now officially categorised as Relablers.
If you are a brand that does not own a manufacturing unit but sells products made by a third-party manufacturer under your label, you MUST obtain a Relabler License.
What we are going to cover in this blog:
- What is FSSAI?
- What is a Relabler License?
- What, When & Who Needs a Relabler License?
- FSSAI license for relabeller kind of businesses
- Primary Conditions to Get a Relabler License
- Want to Add a New Food Product or Change an Existing One
- Liability for Relabellers (Key Responsibilities & Compliances)
- Documents required for FSSAI license (Relabeller KOBs)
- Process for FSSAI license for relabeller
- FSSAI license fee for relabeller
- Validity of FSSAI license
- Liability for relabeller (compliances & responsibilities)
- FAQs, Top 10 most searchable questions with answers
What is FSSAI?
FSS Act is the national food regulator, created under the Food Safety and Standards Act, 2006. It lays down science-based standards for food, and regulates the manufacture, storage, distribution, sale and import of food to ensure safe, wholesome food for consumers.
Every food business operator (FBO), whether manufacturer, importer, relabeller, repacker, trader, or e-commerce, must hold FSSAI Registration or License depending on the scale and nature of their business.
What Is a Relabler License Under FSSAI?
A Relabler License is issued to brand owners who:
- Do not manufacture the food product themselves
- Get their products manufactured by a third-party FSSAI-licensed manufacturer
- Sell the product under their own brand name / label
Thus, whenever a brand enters white labelling or contract manufacturing, the brand owner becomes a Relabler.
Who is a Relabeller under FSSAI?
A Relabeller (often spelled relabbler / relabeller) is a food business that:
- Does not manufacture the food itself
- Gets products manufactured by a third-party manufacturer
- Sells those products under its own brand name and label
FSSAI treats such FBOs as “deemed manufacturers” and has created a specific Kind of Business (KoB) – Relabeller for licensing on FoSCoS.
In simple words:
Brand owner + third-party manufacturing + your label = Relabeller KoB
Who Needs a Relabler License?
You need an FSSAI Relabler License if:
i. You are a Brand Owner
You own the brand but DO NOT have your own manufacturing unit.
ii. You Use a Third-Party Manufacturer
Any product is manufactured for you by:
- Job worker
- Third-party manufacturer
- Co-packer
- Contract manufacturer
iii. Products Are Sold Under Your Brand Name
The label shows your company name as the brand owner/marketer.
When do you need a Relabeller License?
You must obtain a Relabeller License if:
- You are a brand owner (your brand name appears on the label).
- You don’t have your own factory or processing unit.
- A third-party manufacturer (with its own FSSAI manufacturing license) makes the product for you.
- The finished product is packed and sold under your brand.
FSSAI clarifications and FoSCoS FAQs make it clear that FBOs who get their products manufactured through third-party manufacturers must take license under Relabeller KoB, and this license is applied at the Head Office / Registered Office of the brand owner.
Primary Conditions to Get a Relabler License
To apply successfully, a brand owner must meet all the following conditions:
1. You Must Be a Registered Brand Owner
Your company should have a valid business registration:
- Pvt Ltd / LLP / Partnership / Proprietorship
2. The Manufacturer MUST Have a Valid FSSAI Manufacturing License
The product must be manufactured only by a facility that has:
- FSSAI Central/State manufacturing license
- Approval for the same product categories
3. You Must Apply for Only Those Products Approved for the Manufacturer
Whatever product you want to sell:
- The manufacturer must already hold an FSSAI license for that product category
- Only then YOU are eligible to apply as a Relabler for that product
No product can be relabelled unless it is first approved in the manufacturer’s license.
4. Relabler License Is Always Issued on the Company’s Registered Office Address
Unlike manufacturers (who use factory location),
Relablers receive their license based on corporate office / registered office location.
What If You Want to Add a New Food Product or Change an Existing One?
This is a common scenario for brand owners.
Case 1: Adding a New Ffood Product
Steps:
1. Check if the manufacturer has that product/category on their FSSAI manufacturing license.
2. If NOT → Manufacturer must first add the product in their license.
3. Only then you can add the product to your Relabler License on FoSCoS.
Case 2: Changing Formula / Ingredients / Variants
- Any modification must first be updated in the manufacturer’s FSSAI license.
- After the manufacturer updates, you must update your Relabler license accordingly.
Case 3: Changing Packaging Size or Label Artwork
- Usually allowed without license modification,
- BUT ensure mandatory labelling declarations remain compliant.
Documents Required for FSSAI License for Relabeller KOBs
FSSAI has published a KoB-wise document list on FoSCoS.
Below is a practical summary of state license and central license requirements.
Note: Exact documents may vary slightly by State/UT and latest FSSAI orders. Always cross-check the “Documents Required” section on FoSCoS while applying.
1. General Documents (for all Relabellers – State & Central)
Required:
i. Address proof of the applicant / firm (Aadhaar, utility bill, etc.).
ii. Proof of constitution – Partnership Deed / LLP Agreement / MOA & AOA / Registration Certificate, as applicable.
iii. Form IX – Nomination/authorization of a responsible person.
iv. Government-issued photo ID (PAN, Voter ID, etc.) of the authorized signatory.
v. Details of Kind of Business (KoB) – here, Relabeller.
vi. NOC from local body / municipality / panchayat, wherever required.
2. Additional Documents for State License (Relabeller)
For a State License (turnover & criteria as per manufacturer/relabeller norms):
i. Form B – Duly filled application form under FSS Act, 2006.
ii. Layout / premises plan of office/warehouse (if applicable).
iii. Food recall plan, how you will recall products from the market if needed.
iv. Nomination through Form IX (if not already covered above).
v. List of directors / partners / office bearers.
vi. Co-operative certificate if applicant is a co-operative society.
vii. LLP Agreement, in case of LLP.
viii. Photo ID proof of key persons.
3. Additional Documents for Central License (Relabeller)
Where criteria demand Central License (e.g., multi-state presence, high turnover):
i. Self-declaration as per FSSAI format.
ii. Form IX (authorized person).
iii. NOC from Panchayat / Municipality.
iv. Proof of ownership / rent agreement / NOC from premises owner.
v. Import-Export Code (IEC) for businesses involved in export/import.
vi. Mandatory licenses for all owned units & Central License for Head Office, in case of chains across multiple states.
vii. Ministry of Commerce certificate – for 100% Export Oriented Units, where applicable.
viii. Food Safety Management System (FSMS) plan / certificate.
ix. Co-operative Act certificate if a multi-state co-operative.
4. Relabeller-Specific Documents (Very Important)
FSSAI’s “Clarification on Relabeller KoB” also requires:
- Copy of manufacturer’s FSSAI manufacturing license
- Manufacturer’s online NOC (FoSCoS NOC module)
- Comprehensive recall & traceability plan
- Agreement / contract with manufacturer (sometimes asked by authority)
Process for FSSAI License for Relabeller
Getting a Relabeller license is 100% online via FoSCoS.
Step 1 – Preparation
i. Finalise your manufacturer(s) and sign a contract.
ii. Ensure manufacturer’s FSSAI license is valid and covers all your proposed product categories.
iii. Collect soft copies of all documents listed in Section 3.
Step 2 – Create FoSCoS Login & Start Application
i. Visit FoSCoS (foscos.fssai.gov.in) and create an FBO login.
ii. Choose “Apply for License/Registration” → select State where your Head Office / Registered Office is located.
iii. Select Kind of Business: Relabeller from the dropdown.
Step 3 – Fill License Application
i. Enter premises details (HO address, contact details).
ii. Fill Form B online.
iii. Select Food Categories/Sub-categories & Products that you will get manufactured.
iv. Link Manufacturer(s) by selecting their license and sending an NOC request through the system.
v. Upload all documents & plans (FSMS, recall plan, NOCs, identity proofs, etc.).
Step 4 – Pay Fee & Submit
i. System auto-calculates applicable license fee (see Section 5).
ii. Pay online and submit.
iii. A 17-digit application number is generated – use this to track status on FoSCoS or SMS/email alerts.
Step 5 – Scrutiny & Inspection
i. Licensing Authority verifies your form & documents.
ii. They may:
- Raise queries for clarification, or
- Schedule an inspection of your office / storage premises, or of the manufacturer’s unit (through state officers).
Step 6 – Validation and Issuance
i. After inspection and verification, the authority approves the application.
ii. Digital FSSAI License (Form C) is issued and emailed to your registered email.
iii. You must:
- Download & display it at your Head Office.
- Start using your Relabeller license number on labels along with manufacturer’s license number.
FSSAI License Fee for Relabeller
As per FSSAI order dated 10 Feb 2023:
- At the time of application, the FBO pays only ₹1,000 + 18% GST as initial fee.
- After the licensing authority processes the application, the system calculates the balance license fee (based on State/Central schedule).
- The FBO must pay this differential amount within 30 working days; otherwise, approval is auto-rejected.
In practice, FoSCoS handles this automatically, you just need to pay whatever amount appears in your “Pending Payments” tab.
Validity of FSSAI License
i. Duration
Under Regulation 2.1.7 of the Licensing Regulations, an FSSAI license:
- Can be taken for minimum 1 year and maximum 5 years
- Validity is chosen by the FBO at the time of application/renewal
ii. Renewal Window and Late Fee
Current framework:
- You can renew the license as early as 180 days before expiry.
- If renewal is not filed at least 30 days before expiry, a late fee of Rs. 100 per day may be charged for the period of delay (up to the date of filing).
- If you don’t renew within 180 days from expiry, the license lapses completely and you must apply for a fresh license.
Because FSSAI is currently consulting on further easing renewal (fixed cycles, changes to late-fee provisions), always re-check FoSCoS notices at renewal time.
Liability for Relabellers (Key Responsibilities & Compliances)
FSSAI’s clarification on Relabeller KoB and various orders make the relabeller fully responsible for safety and compliance of all products sold under their license.
Based on that, plus your screenshot points, the main liabilities are:
i. Responsibility for Safety & Standards
- The relabeller is responsible for quality, safety and standard of every product packed and sold under its license, even though manufacturing is outsourced.
ii. Use Only FSSAI-Licensed Manufacturers
- You can only get products manufactured from facilities that hold a valid FSSAI manufacturing license for those specific products.
iii. Correct Labelling, Both License Numbers
You must print on the label:
- Name & address + FSSAI license no. of the relabeller (brand owner)
- FSSAI license no. of the manufacturer / packer, if different.
iv. Mandatory License Modification for Any Change
- Any change in premise address, capacity, product category, manufacturer, or KoB must be updated through FoSCoS modification.
v. Recall & Traceability Plan
- Application must be accompanied by a comprehensive recall & traceability plan – how you will trace batches and withdraw products if they are unsafe.
vi. Appointment of Responsible Officer
- Relabeller must nominate one officer who is responsible for compliance with licensing conditions across all relabelling units.
vii. Ensure Schedule-4 Hygiene Compliance at Manufacturer’s End
- You must ensure that your contract manufacturers follow Schedule-4 hygienic and sanitary practices (premise hygiene, pest control, water quality, food handler medical fitness, etc.).
viii. Annual Return (and Other Returns Where Applicable)
- All manufacturers including Relabellers and Repackers must file Annual Return (Form D-1) by 31st May each year for the previous financial year, through FoSCoS.
- For specific categories (e.g., milk & milk products), additional half-yearly returns may apply.
ix. Lab Testing and Record-Keeping
- Regular lab testing of finished products (often done at manufacturer’s end but reports kept by relabeller) to prove due diligence.
- Regular lab testing of finished products (often done at manufacturer’s end but reports kept by relabeller) to prove due diligence.
