A food brand does not escape FSSAI requirements because another business owns the factory. If you arrange for your food products to be manufactured or packed by a third-party manufacturer or processor, the relabeller classification is the starting point. The term is wider than physically removing one label and sticking on another.
A private-label business should therefore examine its own permission, the manufacturer's permission and the approved product relationship between them. A factory's licence is essential evidence, but it is not a replacement for the brand operator's appropriate registration or licence. A trading description on a tax registration also does not decide the FSSAI kind of business.
This article addresses the position in October 2026. The revised turnover framework, continuing certificate validity and online manufacturer-consent process must be read together with the product-specific rules.
Separate four business models
Start with the physical work and commercial arrangement rather than the name used on an invoice.
| Model | What actually happens | Licensing question |
|---|---|---|
| Trading | Finished products bearing another operator's brand are bought and resold | Appropriate wholesale, distribution, retail or other trading activity |
| Relabelling | Your products are manufactured or packed by another manufacturer or processor | Relabeller activity and manufacturer/product linkage |
| Repacking | Food is transferred into different pack sizes without changing its nature, composition or formulation | Repacker activity at the actual repacking premises |
| Manufacturing | Ingredients are processed or converted into the food product | Manufacturing activity and relevant products at the actual production site |
A business buying sealed packs under a supplier's brand is different from commissioning the same supplier to produce packs under its own brand. Conversely, a retailer who buys bulk spice, blends it and fills retail pouches is doing more than arranging third-party manufacture. Calling that business a relabeller would omit its own physical operations.
More than one activity can exist. A brand may outsource biscuits, repack nuts at its warehouse and distribute another company's drinks. Its application and premises records should reflect that combination. Do not select a broad trading activity as a shortcut around product endorsement or hygiene requirements at a repacking site.
Identify the legal brand operator and application address
Record who owns or controls the brand business, enters the manufacturing agreement, pays the factory and sells the resulting product. That may be a proprietor, partnership or company. A trademark owner licensing the mark to another operator does not necessarily perform the same role as the food-business operator named in the application.
For a relabeller operating through an office, the application should describe the actual office and outsourced model. It should not invent a production line at that office. Equally, storage or repacking at that address must be disclosed if it genuinely occurs there. A certificate obtained for an administrative office should not be treated as permission for an undisclosed warehouse.
The manufacturer is separately assessed at its factory premises. Record each factory address and certificate number, not merely the supplier group's head-office name. A company with several factories can have different product endorsements and storage arrangements at each site.
Where the operator has premises in two or more States or Union territories, address the Central head-office requirement alongside the permissions for units. Do not assume every relabeller is automatically a Central head office merely because its contract manufacturer is in another State. Identify the operator's own establishments and all independent Central licensing triggers.
Apply the current eligibility to the actual products
The 2026 turnover reforms increased ordinary registration eligibility to ₹1.5 crore, with the general State band above ₹1.5 crore up to ₹50 crore and Central licensing above ₹50 crore. However, the selected product and kind of business remain important. Special categories and activities can require Central licensing irrespective of the ordinary turnover ladder.
Use the current FoSCoS eligibility schedule for the food concerned. Nutraceuticals, non-specified foods and other specialised categories should not be treated as ordinary biscuits simply because the brand has low revenue. Product approval, composition, claims and labelling questions are separate from whether a turnover band points to registration or licensing.
A new business should document its expected turnover and intended product list. Existing operators affected by revised eligibility should use the prescribed migration arrangements. The 2026 guidance provides for continuity of the certificate number and migration without a modification fee for that migration; it is not a reason to discard the previous compliance history.
Certificate validity now continues unless the certificate is suspended, cancelled or surrendered. Annual fees and applicable return obligations remain. Plan the compliance calendar around those continuing duties rather than a historical five-year renewal reminder alone.
Link every product to a willing, authorised manufacturer
Before starting the application, obtain the proposed manufacturer's current certificate and product annexure. Check that the factory is permitted to manufacture the actual product. A certificate showing a broad business name is not enough when the proposed item is absent from its endorsed products.
The online relabeller process allows the applicant to select a product, add the third-party manufacturer and provide the relevant production information. It then sends an online NOC request to that manufacturer. The manufacturer acts on the request through its own FoSCoS account and its authorised signatory.
A pending request is not the same as consent. The workflow permits preparatory progress while a request is pending, but submission and payment depend on the required valid consent. A rejected or pending manufacturer may be removed from the application; at least one manufacturer with a valid online NOC must remain for the described process.
Do not ask an adviser to accept a request by using the manufacturer's credentials without authority. Coordinate with the factory's nominated contact, reconcile product names in advance and keep the accepted NOC with the application papers. The NOC confirms the specified relationship; it does not itself add an unendorsed product to the manufacturer's licence.
This point matters when a supplier offers to make a new category immediately. The brand owner's accepted request cannot cure the supplier's missing product endorsement. Resolve both sides before commercial production rather than relying on a promise to regularise the product after the first batch.
Put the agreement and compliance file together
The manufacturing agreement should identify the parties, factory premises, products and specifications. Recommended commercial provisions include responsibility for ingredients, approved packaging, testing, batch release, rejected stock, complaints and recall cooperation. These are useful controls; not every suggested clause is a separately prescribed statutory form.
Specify who may approve a recipe or label change. A factory substituting an ingredient can affect allergens, nutrition, claims and shelf life. The brand's marketing team should not approve a new health claim without the technical review needed for that product.
Keep a product-to-manufacturer register with the endorsed product description, pack sizes, consent record, artwork version and first production date. Where two factories make the same product, allocate distinct batch identification and retain factory-specific manufacturing and testing evidence. A single brand SKU should not hide the origin of its individual batches.
The relabeller should nominate the appropriate officer responsible for licensing compliance. For a business that owns no manufacturing unit, do not manufacture an imaginary factory manager's qualification simply to fill an application field. Follow the current relabeller-specific nomination guidance and distinguish the brand's responsible person from the factory's production supervisor.
Labels must identify the responsible businesses
The food label should correctly identify the brand owner and the applicable manufacturing, packing or other responsible operator. The relevant rules require the brand owner's FSSAI logo and number, and the additional relevant licence number where the manufacturer, marketer, packer or bottler differs. The precise declarations should reflect the actual chain.
Avoid a design that makes an outsourced product appear to have been made at the brand's office. Distinguish the brand name from the legal entity and address. The factory details should identify the relevant production premises rather than an unrelated group company.
Other label requirements still apply, including the food's true identity, ingredients, allergens, required nutrition information, batch identification, dates and storage instructions as applicable. Legal Metrology declarations may also apply to retail packages. Approval of the FSSAI application does not amount to approval of every claim or artwork file.
Use a controlled artwork approval sheet as a recommended safeguard. Compare both certificate numbers with their current records and check the manufacturer assigned to that batch. Printing a common wrapper for several factories requires a lawful way of declaring the actual manufacturing information; do not leave consumers unable to identify who made the product.
Traceability and recall responsibilities remain with the brand
A contract can allocate work, but it cannot eliminate the operator's statutory responsibilities. The brand should be able to identify which batches came from which factory and where they were distributed. Maintain purchase records, batch release records, customer or distributor dispatch information and complaint handling evidence suited to the business.
Prepare the recall arrangements required for the operation. In practice, the agreement should ensure quick access to factory records and a clear person to contact outside normal office hours. Test the record chain using a real batch: can the business identify its factory, affected quantity, current stock and recipients without searching personal messages?
Testing duties should be assessed for the applicable product and licensing conditions. A manufacturer's report for an unrelated variant is not reliable evidence for the brand's product. Decide who obtains the report, how its relevance is checked and how the brand receives it. Keep actual technical responsibility with competent people.
Relabellers fall within the licensed manufacturing family for annual-return applicability. Do not assume that absence of machinery means no Form D-1 obligation. Reconcile outsourced production records with the manufacturer and the brand's own stock records so that returns are not based solely on sales revenue.
New factories, products and operating models
Before changing factories, check the replacement's certificate, product endorsement and consent. Complete the appropriate modification and product/manufacturer linkage before relying on the new arrangement. An old NOC from Factory A does not authorise Factory B.
For a new product, examine both the brand's scope and the factory's scope. A new flavour may or may not fit an existing product endorsement; an entirely different regulated category requires more careful review. Obtain the necessary classification and approval before labels are printed in volume.
If the brand starts repacking or manufacturing itself, reassess its premises activities and documents. A relabeller application based on outsourcing cannot be used indefinitely after the office becomes a packing unit. Similarly, a change in the legal operator should be addressed through the appropriate process rather than by editing the logo.
A CA can use assureOffice alongside financial and practice records to organise the commercial side of these changes. Food-product approval, artwork assessment and manufacturer suitability remain specialist matters. Material on assureoffice.in should not be treated as a promise that the platform certifies labels or contract factories.
Frequently asked questions
1. Is a trader licence enough for my own-brand contract-manufactured food?
Do not assume so. Getting your products manufactured or packed by another operator points to Relabeller. Select the activity that describes the actual arrangement and apply current product-specific eligibility.
2. Does relabelling mean physically replacing a label?
Not necessarily. The classification includes a food operator getting its product manufactured or packed by a third-party manufacturer or processor, even when the factory applies the final label.
3. How is repacking different?
Repacking changes the pack sizes without changing the food's nature, composition or formulation. If you perform that work yourself, the repacking premises and activity need their appropriate regulatory treatment.
4. Can one brand use several factories?
Yes, subject to the appropriate permissions and product/manufacturer linkages. Keep each factory's consent and endorsed scope, and preserve batch records identifying which factory produced each consignment.
5. Does the factory's Central licence cover the brand automatically?
No. The factory's permission and the brand operator's permission address different roles. Check the brand's own activity, premises and eligibility instead of copying the factory's licensing category.
6. Is every relabeller automatically a Central licensee?
No universal conclusion follows from the word alone. Apply the current product and activity criteria, including special Central requirements and any multistate head-office requirement that actually applies.
7. Must a relabeller own machinery?
No. Outsourced manufacture is the point of the model. Describe the office and contractual arrangements truthfully, while separately disclosing any storage, packing or processing the operator actually performs.
8. Can a pending NOC be treated as accepted?
No. Follow the online workflow and obtain the necessary manufacturer acceptance. The ability to work on an incomplete application does not establish consent or permit commercial production outside approved scope.
9. Who accepts the online request?
The manufacturer acts through its FoSCoS account and authorised signatory. Agree the product details with the factory beforehand so that the request can be assessed against its actual endorsed products.
10. Does the NOC add products to the factory's licence?
No. The manufacturer must have the relevant products endorsed independently. Consent to manufacture for a brand cannot authorise production of a product outside the factory's approved scope.
11. Which FSSAI numbers belong on the label?
The brand owner's number and the additional relevant operator's number must be declared where the rules require them. Match the declarations to the real manufacturing and packing chain, not merely the brand's preferred artwork.
12. Does application approval certify every label claim?
No. Nutrition, composition, claims and category-specific declarations need their own compliance review. A certificate is not permission to make unsupported health claims or omit mandatory information.
13. What happens when the manufacturer changes?
Assess modification and update the manufacturer linkage and consent before using the new factory. Recheck artwork and batch coding, and retain records showing the final batches made by the previous manufacturer.
14. Must a new product be added on both sides?
Check both operators' scope. The brand's endorsement does not cure an omission in the manufacturer's licence, and the manufacturer's existing product permission does not automatically update the brand's application.
15. Who handles a recall?
The relevant operators retain their legal responsibilities. The agreement should assign practical contacts and records access so the brand and factory can identify affected batches, stock and recipients promptly.
16. Can all testing be ignored because manufacture is outsourced?
No. Determine the applicable testing duties and obtain relevant evidence from the manufacturer. Outsourcing production does not justify accepting an unrelated report or leaving product safety unreviewed.
17. Does a licensed relabeller file an annual return?
Relabellers are included in annual-return applicability for licensed manufacturing activities. Review the certificate and reporting period, and reconcile outsourced production rather than assuming a machinery-free office has no return duty.
18. Does perpetual validity remove annual payments?
No. Continuing validity is separate from annual fees and applicable returns. Maintain the current payment and filing position and follow the migration process if revised turnover eligibility changes the category.
19. Can a relabeller begin packing at its office later?
Only after addressing the new physical activity and premises requirements. Repacking introduces operational facts that were absent from a purely outsourced model and may require modification or other permission.
20. What should be checked before the first production order?
Confirm the legal operators, factory premises, product endorsements, accepted consent and compliant artwork. Agree batch records, testing, dispatch traceability and recall cooperation before inventory is produced and distributed.