Identify every kind of business
Manufacturing, repacking, relabelling, storage, distribution and retail are distinct operating roles in the FoSCoS framework. Map the actual activities and premises before selecting the registration or licensing route.
Keep product and label evidence together
Maintain recipe or composition records, supplier specifications, relevant testing evidence and the final artwork. A label change should be checked against the product’s actual ingredients and claims, not just the marketing brief.
Build traceability into records
Link incoming materials to production batches and onward supplies. Preserve the information needed to investigate complaints or withdrawals, including returns and products handled by third-party warehouses.
Review the wider operation
- Premises, water, waste and safety requirements depend on the process and location.
- Staff training and employment records need assigned owners.
- Tax and stock records should reconcile with production and sales.
- Imports, exports and packaging may add separate compliance workstreams.
A change to assess
A distributor launching its own brand through a contract manufacturer should review the brand and relabelling role rather than assuming its existing distribution permission covers the arrangement.
Scope of support
Kosha can coordinate documentation and the compliance worklist. Food testing, technical safety assessments and authority decisions remain with the appropriate laboratories, specialists and regulators.
Prepare evidence for your operating role
| Operating model | Evidence to organise | Handover to clarify |
|---|---|---|
| Own manufacturing | Recipe versions, supplier specifications, production and batch records | Who confirms the product specification and releases changes? |
| Contract manufacturing | Manufacturing agreement, approved specifications, artwork and batch information | Which party supplies evidence and handles product changes or complaints? |
| Distribution and storage | Supplier records, stock receipts, batch details, storage and dispatch records | How are affected products traced through onward supplies and returns? |
Keep the premises and entity attached to each activity. A brand-level product list alone may not explain where production, storage and dispatch take place.
Connect a product change to the right support
FSSAI licensing support starts with the activity and premises facts. Food labelling and safety review starts with the product evidence and artwork. Provide both teams with the same current specification when a change affects the product and its operating arrangements.
For example, a reformulation should have a dated specification and a clear list of the artwork and production records it replaces. Keep older batches distinguishable from the revised product and record who confirms the information supplied for the review.
References and official procedures
Source material consulted 1 October 2026. Check the applicable instrument, period and portal instructions for the actual assignment.
Kosha.Services · Updated 2 October 2026