Among the many challenges encountered while starting a food business in India is the need to have an FSSAI certification and the myriad complexities that comes with it. It is reasonable to assume that, for entrepreneurs who operate more than one outlet in the same district, the question becomes, does one FSSAI certificate for multiple locations suffices or each outlet requires its own. Although the FSSAI – and particularly the FSSAI certificate for multiple locations – is straightforward, it is often not this simple for businesses that have FSSAI licence for branches, franchises, or multiple units. This blog is one of the many that sets out the primary legal ‘do’s and ‘don’ts’ in licensing compliance rules for setting up an FSSAI multiple unit outlet and operating it within the confines of the legal jurisdiction of one district.

UNDERSTANDING FSSAI RULES FOR MULTIPLE OUTLETS

The Food Safety and Standards Act, 2006, requires any food business operator (FBO) to, before the commencement of any operations, apply for and obtain a relevant licence or registration. This rule applies, no matter the scale of a food business, be it a simple eatery, a food restaurant chain, catering, or a packed food manufacturing company.

Concerning the FSSAI certificate for multiple locations, the law says that for every premises where food is stored, distributed, retailed, or manufactured, there is a need for a separate licence. Even if the outlets are located in the same district, the compliance obligations still apply to each and every single unit.

This ensures that all food safety standards are adhered to at all outlets and that there is control over each unit.

CAN ONE FSSAI LICENCE COVER MORE THAN ONE LOCATION?

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A single food business operator licence one holder per multiple outlets is a question that is frequently posed. The question is quite complex.

For single FSSAI certificate for multiple locations contact locations that are not in close proximity, there is no restriction. For instance, if there are two kitchens located within a single campus or compound, one licence may govern the operations.
Whereas for outlets that are set at different addresses within the same district, each and every outlet is required to obtain individual FSSAI licence or registration.
There are a few exceptions to the rules for head office of franchise chains. In this instance, the head office is granted a central licence, but every branch or outlet is still required to obtain separate state licence or registration, subject to turnover.

This avoids improper use of licenses and also inspections and monitoring are kept at the level of each outlet.

SEPARATE FSSAI LICENCES FOR BRANCHES AND UNITS

The Food Safety Authority of India stipulates that every unit engaged in any of the food activities - be it production, processing, distribution, or sale - should possess a valid document. In the case of businesses operating from FSSAI certificate for multiple locations, it implies:

Each branch or outlet is required to possess a separate document from the competent authority, irrespective of the fact that the branch or outlet is situated in the same district.
In case the Head Office manages multiple outlets, in such case, the Head Office, in turn, also requires a central document if the company is operating in more than one state or the office has a turnover exceeding ₹20 crores.
In the case of franchises, the individual license must be obtained, whereas, the franchisor holds the central document for the brand operations.

In other words, a FSSAI certificate for multiple locations cannot substitute a single state license for multiple locations. Compliance is required for each individual location.

CENTRAL VS STATE LICENCE FOR MULTIPLE LOCATIONS

In attempting to assess whether the state or central license is applicable for multiple outlets, the following is the case.

FSSAI State Licence:
Compulsory for entities conducting business in a single state.
Applicable to outlets whose turnover ranges from ₹12 lakh to ₹20 crores.

If separate addresses exist within the same district then the outlets must apply individually.

FSSAI Central Licence:
If the business is in the food sector and is earning more than ₹20 crores in revenue in a year, then the licence is mandatory.
If the business is an importer, exporter, or operates in multiple states, then the licence is a requisite.
For multi-state food businesses, the headquarter must also possess a central licence in addition to the state licences for each outlet.

If a business is in the form of a chain of restaurants, bakery outlets, or packed food stores, an FSSAI certificate for multiple locations is applicable only when each branch level state licences, and where relevant, a central licence for the head office is possessed.

DOCUMENTS REQUIRED FOR MULTIPLE OUTLET FSSAI LICENCE

If you wish to apply for multiple outlet FSSAI licence for branches, the documents mentioned below are essential.

The applicant should fill and sign the form for the FSSAI licence for branches.
The applicant must provide evidence of the business’s registration in the form of a partnership deed, incorporation certificate, or business license.
The applicant must provide evidence of identity and an address of the owners as well as of the employees at the executive level.
The applicant must provide evidence of the physical location by submitting agreements of rentals, copies of electricity bills, or property tax receipts.
The applicant must provide a complete FSMS Plan and a documented FSMS.
The applicant must provide a catalogue of food items for every outlet.
The applicant must provide the operation plan of each outlet.
The applicant must provide proof of performed water tests for every outlet where food is prepared.
NOC from the municipality or local authority (if applicable).
Proof of turnover (such as an audited balance sheet or self-declaration).

Every outlet should submit their respective application within the outlined documents. The head office's role is to preserve the overall compliance for the audit and inspections.

HOW LAWFINITY HELPS BUSINESSES WITH MULTI-LOCATION FSSAI COMPLIANCE

For businesses with FSSAI certificate for multiple locations and outlets, staying on top of food business multiple outlet FSSAI compliance can be complex, Lawfinity aids in combating the challenges cross border businesses may face in the following ways.

Compliance Consultation: Assessment of the business to determine if a state or central license is to be obtained for multi-location cross border operations.
Branch Level Support: Assisting in obtaining individual licenses for each outlet in the respective district.
Document Filing: Preparing, submitting, and filing the relevant documents in the correct manner.
Central Registration: Document the central license for the businesses that operate in multiple border facilities.
Timelines and Changes: Changes to the license and its timely renewal are made easier for each respective outlet.
Real-time Guidance: Solution provision real time for FSSAI, inspections, audits, and notices.

With Lawfinity, food businesses can focus on growth while ensuring smooth functioning of food business multiple outlet FSSAI compliance.

CONCLUSION

The policies are well defined– a single state license cannot span across more than one outlet in a single district. A FSSAI certificate for a single outlet is necessary and every outlet must apply for their individual license for compliance. Businesses operating on a large scale, or present in multiple states, must also secure a central license for their head office.

Through the skillful aid of Lawfinity, compliance with FSSAI license for branches and managing food business multiple outlet FSSAI compliance is made to seem effortless, and almost without effort. Licensing goes beyond avoiding repercussions. Having proper licensing builds trust with the public as it assures them food safety is prioritized at all FSSAI licence for branches.