Six Monthly Mandatory Lab Testing Report Submission by Manufacturers As per FSSAI Guidelines

License Requirements

The Food Business Operator is required to test for relevant chemical and microbiological contaminants in food products regularly, based on historical data and risk assessment, to ensure the production and delivery of safe food.

Testing must be conducted at least once every six months, either in the operator’s own lab or in a NABL-accredited or FSSAI-notified lab. The FSSAI issued an order on January 13, 2023, mandating the uploading of lab testing reports to the FoSCoS every six months.

The Food Authority has ordered that all Manufacturers (including Repacker and Relabeller) should publish six monthly food product lab testing results through FoSCoS or link to such lab reports from the InFoLNet, depending on which labs are notified by the FSSAI and where the samples are being analysed.

The six-month lab report for April 2022 through September 2022 was required to be uploaded or linked by March 31, 2023. Subsequently, the reports had to be uploaded by the FBOs within one month of the relevant half-yearly period’s closing date, which was by October 31 for the April to September period and by April 30 for the October to March period.

Under the guidelines of FSSAI, food manufacturers are required to submit mandatory six-monthly lab testing reports regarding quality and safety. FSSAI’s effort to strengthen food safety compliance has been in the implementation of regulation over regular monitoring with respect to testing.

Fig. 1: New FSSAI Mandate for Manufacturers for Bi-annual Lab Test Reports

Key Points of FSSAI Guidelines Regarding the Submission of Mandatory Lab Testing Reports

1. Applicability

• All FBOs handling food products falling within its scope, especially categories which include nutraceuticals, dietary supplements, functional foods, and other regulated food categories must comply with the rule.
• The requirement also includes large-scale manufacturers and small and medium-sized enterprises (SMEs), when dealing with packaged foods.

2. Testing Frequency

• Manufacturers must test their products every six months and submit testing reports to FSSAI for assurance of continuous compliance with safety standards determined by the authority.
• Bi-annual testing should be conducted at laboratories that are FSSAI approved or accredited by National Accreditation Board for Testing and Calibration Laboratories (NABL).

3. Testing Parameters

• Testing will be required to cover several different parameters as outlined in the following list:
• Testing for microbiological content to identify pathogens, such as E. coli, Salmonella, etc.
• Chemical testing is provided for contaminants, such as pesticides, heavy metals, and toxins.
• Nutritional composition analysis to ensure that what the food contents are stated to be on the label match what is in the product. For instance, if the RDA mentioned of fats or protein matches to the actual quantity.
• Allergens testing if necessary
  • Residual levels of any preservatives, food additives or colorants used in the food product
  • Manufacturers of specific categories such as infant foods, fortified foods, or foods for special dietary use (FSDU) must pass additional category-specific testing according to those requirements.

4. Accredited Laboratories

• Testing should be done in laboratories recognized by FSSAI or NABL accredited laboratories. The test report should be free of any ambiguity.
• The concerned laboratory should make sure that the testing conducted are in accordance with good laboratory practices and as per the guidelines provided by FSSAI.

5. Submission of Reports

• Test reports shall be submitted to FSSAI through the FoSCos portal.
• Submission shall be done twice a year and each item manufactured by the firm during the reporting period shall be covered.

6. Documentation and Record Keeping

• The manufacturers must maintain all these test records, sample information, testing methodology, and results.
• Such records are to be maintained for a period of time stipulated by FSSAI and to be available for scrutiny during inspection.

7. Outcome of Non-compliance

• Failure to file the required six-monthly testing report submission will expose a company to charges, fines, suspension of the food business license, or even product recalls.
• The requirement of regular audits and inspections by FSSAI means that the compliance measures by manufacturers are in check, with any noticed deviations being liable for harsher actions.

8. Purpose and Benefits

• Regular lab testing ensures quality control and timely detection of potential safety issues that may arise in food products.
• It boosts consumer confidence, ensuring that products attain the level of ensuring safety standards needed to be reached.
• It accords recognition by adhering to the requirement as a means of upholding food safety and quality along with conformance to FSSAI’s standards.

Fig. 2: FSSAI Regulations for Uploading Lab Test Reports

Steps to Upload and Link Their Six-monthly Lab Testing Reports

The manufacturers of food products are required to upload and link their six-monthly lab testing reports in accordance with licence number.

1. Go to the FoSCoS Homepage and select the ‘Login Businesses’ button to access FoSCoS (https://foscos.fssai.gov.in).
2. Select “Upload Six Monthly Lab Testing Report” from the menu panel on the left, then select “Proceed.”

3. The following screen would appear when you clicked Proceed.

4. The period for which the Lab Testing report is being uploaded or linked must be chosen from the dropdown menu when you click on “Upload Six Monthly Lab Testing Report.”

5. A list of the products that your licence is endorsed for will appear. Choose the relevant product under “Uploading/Linking of Report.” A pop-up window will open below.

a) In the event that FBO has not had its food product tested by the FSSAI Notified Lab, FBO may manually upload the lab report by clicking on Choose File and uploading the following:

b.) FBOs can click on Get Sample Report to obtain the lab report from INFOLNET (https://infolnet.fssai.gov.in/) if their food product was tested through the FSSAI Notified Lab.

The sample report number (from INFOLNET) must be entered by FBO.

Additionally, confirm using the OTP that was delivered to the email address or mobile number that was supplied to the lab official when the sample was submitted to the FSSAI Notified Lab.

Conclusion

This guideline mandates the FSSAI to ensure that six monthly mandatory reporting of lab testing within the food manufacturing industry is maintained for quality and safe standards. Under its guidelines, FSSAI ensures the sustaining of safety as well as regulatory requirements for products in the Indian Market by ensuring mandatory enforcing of biannual tests and submission of reports.

Manufacturers would thus have to comply with this by conducting appropriate tests, maintaining adequate records, and submitting reports within time.