Imported Food Compliance in India: Batch Numbers, Best Before Dates and the Bill of Entry Explained
FSSAI requirements, documentation expectations, and the role of the Bill of Entry
In the import of food products into India, compliance failures rarely arise from unsafe goods alone. More often, they stem from incomplete traceability. A missing batch number, an unclear best before date, or inconsistent documentation can halt a consignment even when the product itself meets all safety standards.
India’s food import regime, governed by the Food Safety and Standards Authority of India, places traceability at the centre of enforcement. Understanding how FSSAI norms interact with customs procedures is therefore essential for importers, logistics providers, and customs brokers alike.
This article examines when batch, lot and best before details are mandatory, where they must appear, and whether the Bill of Entry is legally required to carry them.
Why FSSAI places emphasis on batch and shelf-life information
Under the Food Safety and Standards Act, food safety is not limited to composition or hygiene. It also includes the ability to trace food back to its source. Batch and lot numbers are the mechanism that makes recalls possible. Best before and use by dates protect consumers from degraded or unsafe food.
FSSAI’s approach is product-centric. The primary obligation lies on the food itself and its labeling. However, during imports, documentation becomes the first point of verification, which is why authorities increasingly scrutinise shipment papers for these details.
Mandatory labeling requirements under FSSAI for imported food
FSSAI regulations require every packaged food item, whether manufactured in India or imported, to carry the following on its label:
Name of the food
List of ingredients
Net quantity
Name and address of manufacturer and importer
Country of origin for imported food
Batch number, lot number, or code number
Date of manufacture or packing
Best before or use by date
For imported food, these details may appear on the original label or be added through rectification or relabeling in a bonded warehouse, subject to approval by the authorised officer.
Batch or lot numbers are not optional. At least one traceability identifier must be present on the label in a clear and legible manner.
Shelf-life requirements at the time of import
FSSAI mandates that imported food must have a valid remaining shelf life at the time of import. While the exact percentage may vary by product category or specific order, expired food or food nearing expiry without adequate remaining life is liable for rejection.
This makes the best before or use by date a critical compliance element at the import stage. Authorities routinely verify this during document scrutiny and physical inspection.
Do FSSAI norms require batch or best before details on shipment documents
Strictly speaking, FSSAI regulations do not prescribe a mandatory format for commercial invoices, packing lists, or Bills of Entry. Their legal focus remains on labeling.
However, FSSAI import clearance operates through a risk-based assessment system, where officers examine documents to determine whether sampling, testing, or inspection is required. In this process, batch and shelf-life details become operationally significant.
If shipment documents do not clearly indicate batch numbers or best before dates, officers may:
Seek clarifications
Order additional inspection
Insist on label verification through physical examination
Delay clearance pending compliance confirmation
As a result, while not explicitly mandated in writing, inclusion of these details in shipment documents has become an accepted compliance expectation under FSSAI import procedures.
The Bill of Entry and its legal scope
The Bill of Entry is a customs document governed by customs law, not food law. Its primary function is assessment of duty, classification, and import eligibility.
There is no statutory requirement under FSSAI or customs law to declare batch number, lot number, or best before date as compulsory fields in the Bill of Entry.
However, customs authorities act as the implementing arm for FSSAI at ports. When food items are flagged for FSSAI clearance, officers may request supporting information even if it is not a predefined Bill of Entry field.
Many importers therefore voluntarily include batch or lot information in the goods description section of the Bill of Entry, particularly for regulated food categories.
This is a compliance strategy, not a legal mandate.
Recommended document format aligned with FSSAI expectations
To align with FSSAI norms and minimise clearance delays, the following format is widely considered best practice.
Commercial Invoice
Product name and brand
HS code
Batch or lot number
Date of manufacture or packing
Best before or use by date
Net quantity
Country of origin
Packing List
Package or pallet number
Product description
Batch or lot number
Quantity per batch
Gross and net weight
Bill of Entry (Description Field)
Product name and brand
Packaging type
Net quantity
Batch or lot number (recommended, not mandatory)
For consignments involving multiple batches, a separate annexure titled “Batch and Shelf-Life Details” should be referenced consistently across all documents.
FSSAI inspection and ground-level enforcement reality
In practice, FSSAI officers place strong emphasis on consistency. The batch number on the label should match the batch number on the invoice or annexure. The best before date should logically align with the manufacturing date. Discrepancies, even minor ones, often lead to sampling or reinspection.
Importers who rely solely on minimum legal requirements frequently encounter delays. Those who proactively disclose batch and shelf-life details across documents generally experience smoother clearance.
Conclusion
Under FSSAI norms, batch or lot numbers and best before dates are mandatory for imported food products at the labeling level. While the law does not compel their declaration on every shipment document or the Bill of Entry, enforcement practice strongly favours transparency and traceability.
In the Indian food import environment, compliance is no longer just about meeting the rules. It is about demonstrating control.
---
Recommendation
For food imports into India, always align your documentation with FSSAI’s traceability philosophy. Include batch or lot numbers and best before dates on invoices and packing lists, and reference them in the Bill of Entry wherever feasible. This approach goes beyond bare compliance and significantly reduces regulatory friction at the port.
Disclaimer
This article is intended solely for general informational purposes and does not constitute legal, regulatory, or professional advice of any kind. The content is based on laws, regulations, and administrative practices as generally understood at the time of writing; however, such laws, interpretations, and enforcement practices are subject to change and may vary by jurisdiction, port, or authority.
The author makes no representations or warranties, express or implied, regarding the accuracy, completeness, or current applicability of the information contained herein, and expressly disclaims all liability for any loss, damage, delay, penalty, or adverse consequence arising directly or indirectly from the use of, reliance upon, or interpretation of this article.
Readers are strongly advised to seek independent professional advice and to verify applicable legal and regulatory requirements with the appropriate authorities before acting on the basis of the information provided. The views expressed are solely those of the author and do not purport to represent any official position of any regulatory or governmental body.
