FSSAI Compliance · Relabeller
FSSAI Relabeller License in Kerala: 2026 Rules for Brand Owners
If a contract manufacturer makes your food product and you sell it under your own brand, you need an FSSAI relabeller license. FSSAI treats you as a relabeller, which means a license under the "Relabeller" Kind of Business, an online NOC from every manufacturer you use, and labels that show both license numbers. GBS Cochin sets this up for brand owners across Kerala, from your first manufacturer to your fifth.
Who is a relabeller under FSSAI?
FSSAI defines a relabeller as a food business that does not manufacture its products itself but has them made or packed by a third-party manufacturer under an agreement or contract, then sells them under its own brand. Relabellers are deemed manufacturers. Even though the production happens in someone else's facility, you are answerable for the product's safety, standards and labelling once your brand is on it.
Typical relabellers in Kerala include:
- D2C and Instagram brands selling spices, snacks, coffee, tea or health mixes made by a contract unit
- Private-label brands supplied to supermarkets and online marketplaces
- Startups that outsource production of ready-to-cook, bakery or beverage products
- Businesses moving from a single manufacturer to several, across Kerala or other states
The category changed, and many brands are still on the wrong one. FSSAI requires businesses that get their products manufactured by third parties to hold a license under the "Relabeller" Kind of Business. FoSCoS no longer accepts new applications under the older "Marketer" or "Supplier" categories that many brand owners used before. If your license still describes you as a trader or marketer, it's worth having it reviewed.
Relabeller vs repacker vs manufacturer
| Kind of business | What you actually do | Own production premises? |
|---|---|---|
| Manufacturer | Make or process the food yourself | Yes |
| Repacker | Buy in bulk and pack into smaller sizes with your label, with only minimal processing such as sorting, grading or sieving | Yes, a repacking facility |
| Relabeller | Get the product made or packed by a licensed third-party manufacturer and sell it under your brand | No |
Some businesses do more than one of these. One FSSAI license per premises can carry several Kinds of Business, and choosing the right combination at the start saves a modification later.
Which FSSAI relabeller license do you need in 2026?
Relabelling does not automatically mean a Central License. From 1 April 2026, FSSAI's revised turnover limits decide the tier for relabellers in the same way as for other food businesses:
| Category | Annual turnover (from 1 April 2026) |
|---|---|
| FSSAI Registration | Up to ₹1.5 crore |
| State License | Above ₹1.5 crore, up to ₹50 crore |
| Central License | Above ₹50 crore |
Two things can change that answer for a relabeller:
- Where your manufacturers are. When deciding eligibility, FSSAI looks at the combined production capacity of your third-party manufacturers and the number of States/UTs they are located in, not just your own sales figure.
- Operating in more than one state. A business with premises in two or more states needs a Central License for its head office or registered office, plus the right license or registration for each other location.
Picking the wrong tier is the most common reason relabeller applications are sent back. We confirm the correct category with you before anything is filed.
What an FSSAI relabeller license involves
Online NOC from each manufacturer
Every contract manufacturer must approve your request on FoSCoS from their own login. FoSCoS won't let you submit or pay without at least one valid NOC, so the manufacturer's response often decides your timeline.
Manufacturer must hold a valid FSSAI license
You can only have products made by a manufacturer with a valid FSSAI license covering those products. We check this before you sign up a new supplier.
Every product endorsed on your license
Each product you sell must be endorsed on your license. Selling a product that isn't endorsed is treated as doing business without a license.
Changes need a modification
Adding a manufacturer, a new location or a new product category means updating your license through a modification application and getting a fresh NOC.
Labelling rules for relabelled food products
Under the FSS (Labelling and Display) Regulations, 2020, the label of a relabelled product must carry:
- The name and complete address of the brand owner (you), whether or not you manufacture the product
- The FSSAI logo and your license number as brand owner
- The license number of the actual manufacturer or packer, because it is different from yours
- All the other mandatory declarations that apply to the product: name of the food, ingredients, nutrition information, allergens, net quantity, date marking, batch number and so on
Label errors are the issue relabellers most often discover after printing. We review your label artwork against your license before it goes to the printer. Read more in our guide to the FSSAI 100% label rule.
After you're licensed: ongoing compliance
- Annual return (Form D1). Licensed relabellers must file Form D1 every year by 31 May, declaring all products made for them by third-party manufacturers. A late filing costs ₹100 per day, capped at five times the annual license fee. More on Form D1 filing →
- No more periodic renewal. Under the 2026 amendments, FSSAI licenses no longer need renewing every few years. The license still has to be kept accurate, so every new manufacturer or product needs a modification.
- Schedule 4 hygiene responsibility. As a deemed manufacturer, you are expected to make sure the hygiene and sanitary conditions FSSAI sets for manufacturers are followed at your contract units.
- License number on invoices. Your 14-digit FSSAI number must appear on bills and invoices.
How GBS Cochin gets your FSSAI relabeller license done
Right category, first time
We map your manufacturers, states and turnover to the correct tier and Kind of Business before filing, including brands moving off old Marketer or Supplier licenses.
NOC coordination
We work directly with your contract manufacturers so their NOC approvals don't stall your application.
Label review
We check your artwork for license numbers, brand-owner details and mandatory declarations before you print.
Year-round support
We handle modifications when you add manufacturers or products, Form D1 filing every May, and replies to FSSAI queries.
Frequently asked questions
Do I need an FSSAI license if a third party manufactures my product?
Yes. FSSAI requires businesses that get their products manufactured through third-party manufacturers to obtain a license under the "Relabeller" Kind of Business. The manufacturer's own license does not cover your brand.
Does a relabeller always need a Central License?
No. From 1 April 2026 the tier depends mainly on turnover: Registration up to ₹1.5 crore, State License from ₹1.5 crore to ₹50 crore, and Central License above ₹50 crore. FSSAI also considers your manufacturers' combined production capacity and how many states they are in, and businesses operating in more than one state need a Central License for their head office.
What is the NOC for relabellers?
It is an online No Objection Certificate that each third-party manufacturer grants you through FoSCoS. You add the manufacturer to your application and send the request, and they accept it from their own FoSCoS login. At least one valid NOC is needed before the application can be submitted.
Whose license number goes on the label, mine or the manufacturer's?
Both. The label must show the FSSAI logo and your license number as brand owner, along with your name and address. Because the manufacturer is a different business, their license number must also appear.
Can I still apply as a "Marketer" instead of a relabeller?
No. The older Marketer and Supplier categories are no longer open for new applications on FoSCoS. Brands that outsource manufacturing apply under Relabeller.
Do relabellers have to file an FSSAI annual return?
Yes. Licensed relabellers file Form D1 by 31 May each year. A late filing attracts a penalty of ₹100 per day, capped at five times the annual license fee.
Does my relabeller license need renewal?
Under FSSAI's 2026 amendments, licenses no longer require periodic renewal. You still need to apply for a modification whenever you add a manufacturer, product category or location.
How much does a relabeller license cost?
The government fee depends on your license tier, and our professional fee depends on how many manufacturers and products are involved. Book a free consultation and we'll give you an exact quote for your case.
Related FSSAI services
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