The Food Safety and Standards Authority of India (“FSSAI”) through a Public Notice dated 28th May 2020 announced migration of the existing Food Licensing and Registration System (“FLRS”) to a new platform – Food Safety and Compliance System (“FoSCoS”). This new system will be a one point stop for all regulatory compliance transactions (such as licensing, registration, annual returns, etc.) of a Food Business Operator (“FBO”). It has been integrated with the mobile application – FoSCoSRIS and will soon be integrated with the present IT platforms of FSSAI such as INFOLNet, FoSTaC, FICS, FPVIS, etc.
Migration Strategy from FLRS to FoSCoS
- FoSCoS will be launched in phases. With effect from 1st June 2020, it has become operational in Tamil Nadu, Gujarat, Goa, Delhi, Odisha, Manipur, Chandigarh, Puducherry and Ladakh. The intimation of launch in remaining States/ UTs is expected to be announced soon on the FLRS website. FSSAI has also given directions to all States/ UTs to establish a “Licensing Helpdesk” at State level for addressing the queries of the users/ stakeholders.
- User IDs and Passwords will remain the same in FoSCoS, as were in FLRS. Further, mandatory documents have been rationalized and many paper-based declarations have been replaced with tick-based declaration.
- After launch in their respective states, all valid FSSAI Licensed or Registered Food Businesses have to verify the details of their existing Licenses/ Registration Certificates (such as License, Registration number, Name and Address of the Food Business, Kind of Business enrolled, validity, etc.) on the Food Safety and Compliance System i.e. https://foscos.fssai.gov.in.
- All manufactures holding valid FSSAI License will need to modify their License (without any modification fee) as per the “Standardized Food Products” available on the FoSCoS website, before 31st December 2020.
- In FLRS, there was text-box approach for writing the name of the products to be manufactured. In FoSCoS, product selection based methodology has been adopted for providing ease to the food businesses in selection of Standardized Food Products. This new approach is only for manufactures of Standardized Food Products. For manufacturers of non-specified food, supplements, proprietary food and substances added to the food, the approach shall continue to be as in the existing FLRS. Under the Food Category 15 (Ready to eat savories) and 16 (Prepared Food), there are no Standardized Food Products, hence a manufacturer under these categories will have to take Central license under proprietary food category. A new category 100 has also been introduced for the purpose of licensing, wherein Standardized Food Products which do not have a Food Category mapped, will be listed.
Concept of Standardized Food Products explained
The proposal of mapping the “Standardized Food Products” with the existing “Food Category System” was approved by FSSAI in the month of November 2019 for the purpose of licensing and registration for manufacturers. These Standardized Food Products may have variants (i.e. types & subtypes) which may have different vertical standards. To facilitate food businesses, the approach has been adopted to grant license based on description of Standardised Food Product, including its variants unless the classification under the Food Category System is different or there is a need for administrative reasons1`. This mapping will avoid need for unnecessary modification requirements, if an FBO desires to manufacture another standard variant of the food product or standards for a new variant is added with same Food Category System.
For example, “Chocolate” is under “Category 5.1.3” of the Food Category System. The FBO granted license for manufacturing of Chocolate under Category 5.1.3 can manufacture all its variants such as milk chocolate, milk covering chocolate, plain chocolate, plain covering chocolate, blended chocolate, white chocolate, filled chocolate, composite chocolate, praline, couverture chocolate. Further, if FSSAI notifies standard for any other (type or subtype) of Chocolate in addition to sub-types mentioned hereinabove, the FBO need not apply for a fresh license, provided the Food Category System of such new notified standard, remains the same.
The key change that has been incorporated through migration from FLRS to FoSCoS is that the methodology of licensing for “manufacturers” which shall now be based on the Standardized Food Products. The migration also aims at avoiding any food fraud in the future, to provide ease of compliance to the stakeholders and to enhance user experience for users.
-Archana Balasubramanian (Partner), Charulata (Associate)