India Consults on Regulation of Analogue in Dairy Context

On April 16, 2025, the Food Safety and Standards Authority of India unveils a consultation paper on the provisions of ‘Analogue in Dairy Context’, in a move aimed at tightening the regulatory treatment of dairy substitutes. Comments are invited via a Google Form within 60 days of notification.

Proposed Provisions

The consultation paper lays out five main suggestions to enhance clarity, consumer transparency, and regulatory control over dairy analogue products:

1. Suggested Nomenclature on Labeling

Stakeholders are invited to suggest whether terms like “Non-dairy” or “Analogue” can be prefixed to conventional dairy terms for such products, both in cases of partial or full substitution of milk components. 

Examples: “Non-dairy Paneer”, “Analogue Cheese”

2. Declartion of Analogues in Ingredient List

When a dairy analogue is used as an ingredient in pre-packaged food, it must be labeled as “Analogue of [dairy product]” followed by a parenthetical list of its ingredients in descending order by weight. 

Example: Ingredients- Analogue of Cheese (Milk Solids, Refined Palm Oil, Hydrogenated Vegetable Fat, Modified Starch, Emulsifier)

3. Mandatory Menu Disclosures in HoReCa Industry

Hotels, restaurants, and catering services (HoReCa) must disclose the use of dairy analogues in food served, by prefixing “Non-dairy” or “Analogue” before the dairy term on menus, display boards, or booklets in a manner clearly visible to consumers.
Examples: “Analogue Paneer Tikka”, “Non-dairy Cheese Burger”

4. Prohibition on Loose Sale

The sale of dairy analogue products in loose or unpackaged form shall be prohibited. Such products must be sold only in packs of not less than 500 grams with proper label declarations.

5. Restriction in FSSAI registration

Considering the probable misuse of dairy analogue as dairy products, it is suggested to restrict grant of FSSAI registration for FBOs manufacturing Dairy Analogue (i.e., Analogue of Paneer, Analogue of Cream, Analogue of Milk, Analogue of Cheese etc.). The category of 'Analogue in dairy context' will only be considered for State and Central license, to ensure greater compliance responsibility by Food Business Operators.

Current Regulation of Dairy Analogues

According to Chapter 2.1 of the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011, analogues in the dairy context are defined as products in which constituents not derived from milk replace, either partially or wholly, any milk component(s). These products closely resemble milk or milk products both in terms of sensory characteristics and functionality. However, they are not considered milk, milk products, or composite milk products under the regulations.

The regulations also impose strict labeling and marketing requirements to prevent consumer deception. Non-dairy products cannot be misrepresented as milk or milk-based products through labels, commercial documents, publicity materials, or point-of-sale presentations. Exceptions exist only if explicitly provided for in FSSAI regulations.  Additionally, products that contain milk or milk derivatives as an essential component may use dairy-related terminology in their descriptions, provided that non-milk constituents are not intended to replace milk components. Moreover, in terms of HoReCa industry, Food Business Operators selling cooked or prepared food shall display a notice board containing the nature of articles being exposed for sale.

To ensure transparency, the labeling of dairy analogues must include specific declarations as above. These include stating the presence of any non-milk constituent that replaces a milk component and clearly indicating when a milk constituent has been entirely substituted by a non-milk alternative.