Indian labels must declare allergenic ingredients under the FSS (Labelling and Display) Regulations 2020. The declaration names the actual allergen — the cereal, the nut, the fish — in a separate “Contains” statement near the ingredient list, and a missing declaration makes the food misbranded under section 52.
The rule behind it
Allergen declaration sits in the Labelling and Display Regulations 2020, alongside the other mandatory label elements. The declarable set covers the ingredients most associated with allergic reaction — cereals containing gluten, crustacea, fish, eggs, milk, peanuts, tree nuts, soybeans and added sulphites at 10 ppm or more — together with anything derived from them that remains in the finished food.
Check the current consolidated version before an artwork goes to print: the labelling regulations have been amended repeatedly, and the version in force is the one an officer reads.
How the declaration should read
Three things distinguish a declaration that passes:
- It names the allergen, not the category. “Contains wheat” and “Contains cashew” — not “contains cereals” or “contains nuts”.
- It sits with the ingredient list. Immediately after it, in the same field of vision, not on the back of a leaflet or a website.
- It is legible. Same legibility standards as the rest of the mandatory information; a line set in 4-point grey on a photograph is a finding waiting to happen.
Cross-contact and “may contain”
A precautionary statement — the “may contain traces of…” line — is for genuine cross-contact risk that cannot be excluded by your controls. It is not a substitute for declaring an allergen that is actually in the recipe, and it is not a blanket disclaimer to paste on every SKU.
Two practical tests before you print one: can you point to the shared line, vessel or supplier that creates the risk, and is the statement consistent with your own FSMS documentation? If not, remove it — an unnecessary precautionary label is a live claim you cannot support.
Why it is the expensive defect
A missing or wrong allergen declaration makes the food misbranded. Section 52 allows a penalty of up to ₹3 lakh. But the penalty is rarely the big number: the pack is already printed, the stock is already with distributors, and the remedy is a reprint and a withdrawal, not a correction sticker.
FSSAI's permission to exhaust old packaging is narrow — it covers changes such as name, address or licence number, not a missing mandatory declaration. Imports are the one place where a limited set of elements can be corrected by sticker at the port.
Tick the fifteen mandatory elements against your pack with the free label self-check, or send one SKU for a full review.