It is essential to know who a Repacker under FSSAI Act for anyone in the food business involved in repacking of food products. The expressions, duties, licensing and the compliance under FSSAI (Food Safety and Standards Authority of India) regime carries much legal significance. In this blog, read for details – who is a repacker under FSSAI Act what are the responsibilities of such entities and how our business can ensure food repacker compliance FSSAI with expert help from Lawfinity.

DEFINITION OF A REPACKER UNDER FSSAI

A Repacker as per FSSAI Act means Food Business Operator (FBO) that processes packed food products from a manufacturer or sells/prepares such product for sale in the market, but does not change its composition and characteristics. These procedures helped maintained a minimum handling, including sorting, grading, sieving and cleaning as well as relabeling and repackaging bulk products.

Some key points:

The food is already processed when it arrives.
The repacker will not alter the character or grade of the product.
Only minimal physical handling and packaging are allowed.
The repacker may use a different brand name or packaging, label it, and market it.

Hence, the Repacker under FSSAI Act is a sort of “deemed Manufacturer” for many regulation purposes such as Licensing, Labelling, Traceability and Food Safety Standards.

ROLE AND RESPONSIBILITIES OF FSSAI REPACKERS

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For those who are a Repacker under FSSAI Act there should be following Roles & Responsibilities:

Licensing / Registration – You will require the appropriate FSSAI registration or license based on turnover and capacity.
Labelling – All repacked goods must have proper labels with mandatory information provided.
Traceability -Keep purchase and supply records for recall purposes.
Hygiene & Safety – Facility hygiene, people health, and sterilization of the tools.
Other Legislations as applicable – comply with Legal Metrology, Environmental and Packaging laws.
Product Standards - Complies to food standards of FSSAI and approvals wherever applicable.
Renewal & Inspections – Renew your licenses on time and get ready for inspections.

All these combined add up to full-fledged food repackers compliance FSSAI.

FSSAI LICENSE REQUIREMENT FOR REPACKERS

Any FBO engaging in repacking must obtain a food repacker compliance FSSAI license or registration, depending on scale and turnover.

Types of license:

Type	Eligibility	Notes
Basic Registration	Turnover below ₹12 lakh/year	For very small businesses or startups.
State License	Turnover ₹12 lakh – ₹20 crore	For medium-scale repackers within one state.
Central License	Turnover above ₹20 crore, or inter-state/import/export	For large-scale operations or multi-state activities.

DOCUMENTS NEEDED FOR REPACKER FSSAI LICENSE

Documents required include:

Photo ID and address proof of proprietor/partners/directors.
Proof of business premises (rent agreement, sale deed, electricity bill).
Business constitution documents (Partnership Deed, Incorporation Certificate, MoA/AoA, GST registration).
Blueprint/layout plan of premises and list of machinery/equipment.
List of food products to be repacked, sample labels, and declarations.
Food Safety Management System (FSMS) plan, water test report, pest control details.
Local authority NOCs if applicable.
Filled application form (Form A for registration, Form B for license).

COMPLIANCE GUIDELINES FOR REPACKERS UNDER FSSAI

For food Repacker under FSSAI Act, the repackers need to keep:

Keep a track of FSSAI News and changes.
All labels should mention the food repacker compliance FSSAI license number.
Keep clean, pest controlled, and staff trained.
Maintain batch/lot traceability for recalls.
Apply FSMS plans commensurate with their size.
Abide by the environmental standards for water and waste use.
Renew and amend FSSAI repacker licenses promptly.
Do not misbrand, adulterate or use another person’s license number.

HOW LAWFINITY ASSISTS IN OBTAINING FSSAI REPACKER LICENSE

We help businesses with at Lawfinity:
Selecting proper type of Repacker under FSSAI Act License.
Drafting and confirming all necessary documentation.
Designing FSMS plans with proper labelling etc.
In todoing, we will be also filing and tracking the applications in FoSCoS portal.
Handling inspections, renewals, and modifications.
Securing total food Repacker under FSSAI Act as per the recent act.

CONCLUSION

Food repacker compliance FSSAI is an important cog under FSSAI Act to keep packaged foods safe, traceable and compliant. If you are repacking food then you should have the associated license, properly maintain hygiene and moreover, they need to be labelled as per the FSSAI standards.
We are very welcoming at Lawfinity, we offer assistance to food businesses for acquiring and retaining their Repacker under FSSAI Act license, organizing the file work and become a 100% full food repacker compliance FSSAI.