FSSAI Rules for Dairy 2026: Compliance Checklist and Batch Traceability

What changed for dairies in the past twelve months

Eight things happened between December 2025 and September 2026 that touch a dairy plant directly.

Which FSSAI licence your dairy needs now

Until March 2026, a dairy's category was set by capacity. More than 50,000 litres a day meant a Central licence. FSSAI's current eligibility chart on FoSCoS classifies dairy units by annual turnover alone.

To put that in dairy terms: a plant selling about 28,000 litres a day at ₹50 a litre already crosses ₹50 crore a year. So some dairies that held a State licence under the old litre rule may now fall in the Central category. FSSAI has said existing licences migrate automatically on FoSCoS, with no new licence number.

Many websites still quote the old litre limits, so check your category on FoSCoS itself. If you run a small processing plant with a turnover below ₹1.5 crore, ask your licensing authority whether a registration is enough. The chart is not clear on that point.

Three things follow from your category.

The licence is permanent but conditional. Pay the annual fee and file the annual return on time. Miss either and the licence is treated as suspended until you clear it with the penalty.

Dairy is a high-risk category. Under FSSAI's risk-based inspection policy, high-risk businesses are inspected at least once a year. Central-licensed dairy manufacturers must also get a third-party food safety audit every year from an FSSAI-recognised agency.

Your suppliers may need a registration too. The March advisory exempts only a registered cooperative member who supplies or sells all their milk to the society. A private dairy buying directly from farmers or vendors should collect each supplier's FSSAI registration number and store it against their code. Registration costs a farmer ₹100 a year.

The compliance checklist

Print this section. Every item is a record or a practice that an inspector or auditor can ask for. The rule it comes from is noted beside it.

1. Licence and filings

A copy of the licence displayed at the plant. Licence condition 1

The 14-digit FSSAI number which appears on all invoices, bills and cash memos, having been in effect since 1 January 2022.

Annual fee paid on time.

Annual return in Form D-1 filed on FoSCoS by 31 May. Late filing costs ₹100 a day, capped at five times the annual licence fee, and it now suspends the licence as well.

You can stop looking for the half-yearly Form D-2. FSSAI dropped it for milk products from 2020-21, though many guides still list it.

2. People

One qualified technical person must be in charge of the production, this person having a degree in science, dairy technology or a comparable subject. Licence condition 4

A Food Safety Supervisor trained under FSSAI's FoSTaC programme for every 25 food handlers.

A medical examination of every food handler once a year, signed by a registered medical practitioner. Schedule 4

3. Raw milk reception

Raw milk cooled to 4°C or lower and held there until it is processed. Schedule 4, Part III

No mild steel or plastic cans for storing or carrying milk. Schedule 4, Part III

Reception test results recorded against each tanker. FSSAI's Scheme of Testing and Inspection for dairy plants covers adulterants, antibiotics and aflatoxin. Ask your consultant for the current test schedule.

Supplier details on file, including FSSAI registration numbers for farmers and vendors who are not cooperative members.

4. Processing and storage

Daily records of production and raw material use. Licence condition 8

The pasteurized milk was cooled immediately to 4°C or below and was kept at a temperature of no more than 5°C until it left the plant. Schedule 4, Part III

Storage temperatures recorded for chilled products. Schedule 4, Part III

A documented cleaning programme with records, including CIP. Schedule 4

Pest control records showing dates and chemicals used. Schedule 4

Stock issued first-in-first-out or first-expiry-first-out.

5. Testing

Each product tested for chemical and microbiological contaminants at least once in six months, in your own lab or an NABL-accredited or FSSAI-notified lab. Licence condition 12

Aflatoxin M1 in milk at no more than 0.5 micrograms per kg.

No residues of banned antimicrobials. Since 1 April 2025, a list that includes chloramphenicol, colistin and nitrofurans cannot be used at any stage of milk production.

Fat and SNF matching the class of milk printed on the pack. See the standards table.

6. Labelling

A batch, lot or code number on every pack. Labelling Regulations, 2020

An expiry or use-by date. For products with a shelf life of seven days or less, such as pouch milk, the date of manufacture may be left out. The use-by date may not.

The class of milk and the heat treatment declared on the pack.

No "100%" claims on packs or in advertising, as in "100% pure ghee". FSSAI advised on this issue in May 2025.

If a non-milk ingredient replaces any milk constituent, the product is an analogue. The label must say what it contains and which milk constituent it does not.

7. Traceability and recall

A written, up-to-date recall plan. Mandatory for manufacturers and wholesalers. Recall Regulations, 2017

Records of suppliers and customers: names, addresses, product, purchase and delivery dates, batch code, pack size, manufacture and expiry dates.

Those records kept for one year after the expiry date.

Any recall you start logged on FoSCoS.

8. Audits and record keeping

A periodic internal audit of your hygiene and food safety system. Schedule 4

A third-party audit every year, if you are a Central-licensed manufacturer.

Production, storage, distribution, quality, lab, cleaning, pest control and recall records kept for one year or the product's shelf life, whichever is longer. Schedule 4

FSSAI standards for liquid milk

These are the all-India minimums. The older state-wise figures for cow and buffalo milk were replaced by uniform standards in 2018, though some guides online still quote them.

The paneer draft, and what to do about it

The draft published in the Gazette on 23 September 2026 would add "paneer made of constituents not derived from milk" to the list of products that cannot be sold. Products already licensed in the analogue category would have to drop the word paneer from their names, labels and marketing.

It is a draft. It has no start date and no transition period yet, and FSSAI is taking comments for 60 days, which runs to about 22 November 2026. Several states have not waited. Chhattisgarh, Maharashtra, Karnataka and Telangana have issued their own bans on analogue paneer, and Gujarat has acted against unstandardised analogue paneer, cheese and butter.

What to do now:

If you make only milk paneer, nothing changes in your plant. Make sure your label and your lab reports can prove it is milk paneer.

If you make or trade an analogue product, review every name, label, price list and distributor scheme that uses the word paneer, and check the position in each state you sell in.

If you have a view, send it. Comments go to FSSAI at regulation@fssai.gov.in.

Batch traceability: what the law asks

The duties sit in the Food Recall Procedure Regulations, 2017. A manufacturer must:

keep an up-to-date recall plan;

keep supplier and customer records by batch, for one year after expiry;

inform FSSAI immediately, and within 24 hours, once it knows a product needs to be recalled;

send a status report every week while the recall runs, and a follow-up report within 30 days of finishing;

log the recall on FoSCoS, since March 2026.

None of this mentions QR codes, blockchain or any software. You can meet every one of these duties on paper. The difficulty in a dairy is not the rule. It is the milk.

Break any one link and you can no longer narrow the problem. You end up recalling a full day's production when one batch would have done.

We suggest four hours as your target. If the product is pouch milk, most of it is consumed within a day, so a trace that takes until tomorrow is too late to matter.

Run a mock recall this month

You will learn more from one drill than from any audit report. It takes half a day.

If it took a day and three registers, you have found your gap, and you found it before an inspector did.

What non-compliance costs

The fines are not the main cost. In 2024-25, enforcement authorities analysed 33,405 samples of milk and milk products and found 12,780 of them non-conforming. They launched 12,057 cases. Those are enforcement samples, taken where officers already suspect a problem, so they do not describe all the milk in the country. They do show how closely dairy is being watched.

And since March 2026 a recall is a public record on FoSCoS. For a brand that sells on trust, that is the bigger penalty.

Where software helps, and where it does not

Software does not make milk safe. Chilling, cleaning and testing do that. What a system changes is retrieval: whether the five links are captured as the work happens, and whether you can pull them together in minutes when someone asks.

In Sanskar Dair ERP, our dairy ERP built on ERPNext, the records in this guide sit in these places:

Procurement: collection data from AMCS, traceable from the collection point to the plant, with supplier registration and compliance records.

Gate: inward tanker verification and quantity logging, outward dispatch verification, and searchable audit logs.

Plant: quality inspection logs at reception, production batch tracking and yield.

Stores: batch-wise and lot-wise stock across the plant, BMCs and chilling centres, with expiry tracking and cold storage temperature monitoring.

Dispatch: each invoice and delivery tied to the batch, route and customer.

It does not file your annual return on FoSCoS, replace your lab or write your recall plan. Those stay with your quality team. If you are still deciding what kind of system you need, our buyer's guide to dairy ERP in India sets out the options.

Frequently asked questions