Ensuring Integrity in Food Testing: FSSAI’s Enforcement of Statutory Obligations through InFoLNet Integration and NABL Accreditation Compliance

The integrity of food safety governance in India fundamentally depends upon the reliability, transparency, and accountability of the laboratory infrastructure entrusted with the critical function of food testing and analysis. The Food Safety and Standards Authority of India, established as the apex regulatory body under the Food Safety and Standards Act, 2006, exercises comprehensive jurisdiction over the food safety ecosystem, including the recognition, notification, and supervision of laboratories authorized to conduct food safety testing. In furtherance of its statutory mandate to ensure the availability of safe and wholesome food for human consumption, and recognizing the imperative of maintaining rigorous standards in laboratory operations, the Authority has issued a significant order addressing widespread non-compliance with the obligations prescribed under the Food Safety and Standards (Recognition and Notification of Laboratories) Regulations, 2018. This regulatory intervention, issued by the Quality Assurance Division of the Authority, highlighting the binding nature of laboratory obligations and establishes stringent compliance requirements backed by enforcement mechanisms, thereby representing a decisive step toward strengthening the analytical foundation of India’s food safety regime.

The statutory architecture governing food testing laboratories in India derives its authority from Section 43 of the Food Safety and Standards Act, 2006, which empowers the Authority to recognize and notify laboratories for the purpose of carrying out food analysis and other functions entrusted to food analysts under the legislation. Section 43(1) and 43(2) of the Act specifically confer upon the Authority the power to recognize laboratories operated by government agencies and to notify private laboratories that meet the prescribed standards, thereby creating a dual-track system of public and private laboratory participation in the national food safety infrastructure. The substantive obligations of these recognized and notified laboratories are comprehensively delineated in Regulation 9 of the Food Safety and Standards (Recognition and Notification of Laboratories) Regulations, 2018, which imposes mandatory duties concerning laboratory operations, quality management, reporting protocols, and compliance with accreditation requirements. The legislative intent underlying these provisions is to ensure that all food testing activities are conducted within a framework of scientific rigor, procedural regularity, and traceability, thereby generating test results that are reliable, reproducible, and legally defensible.

Notwithstanding the clarity of these statutory obligations, the Authority has observed that several notified food testing laboratories have failed to comply with the requirements prescribed under Regulation 9 of the 2018 Regulations. This non-compliance encompasses multiple dimensions of laboratory operations, including deficiencies in reporting protocols, inadequate maintenance of accreditation standards, and failure to adhere to prescribed testing methodologies. The persistence of such violations poses significant risks to the integrity of the food safety framework, as unreliable or improperly documented test results can lead to erroneous regulatory decisions, compromise consumer protection objectives, and undermine public confidence in the food safety system. The Authority has determined that such lapses cannot be tolerated given the critical public health implications of food safety testing, and has consequently issued binding directions to all FSSAI-notified laboratories to ensure immediate and sustained compliance with their statutory obligations.

The directions issued by the Authority establish four interconnected pillars of compliance that collectively constitute the minimum standards for laboratory operations. The first pillar concerns the mandatory upload of test reports on the Information and Food Laboratory Network portal, which serves as the centralized digital infrastructure for food safety data management in India. All FSSAI-notified laboratories are directed to upload test reports of all food samples analyzed by them on the InFoLNet portal without any delay, thereby ensuring real-time transparency and creating a centralized repository of food testing data that is accessible to regulatory authorities. This requirement eliminates information asymmetries, facilitates trend analysis and risk-based surveillance, and enables rapid response to emerging food safety threats through immediate access to testing data across the national laboratory network.

The second pillar addresses the maintenance of accurate and updated laboratory profiles on the InFoLNet portal, requiring laboratories to ensure that their profile information reflects current operational realities on a real-time basis. The specific information requirements encompass accreditation validity details, which ensure that laboratories operate only within periods of valid accreditation and do not continue testing activities during periods of accreditation lapse or suspension. Contact details must be maintained current to facilitate regulatory communication and consumer access to laboratory information. Participation in Proficiency Testing and Inter-Laboratory Comparison programs must be documented, as these external quality assurance mechanisms are essential for verifying laboratory competence and detecting systematic errors or analytical drift. Manpower details, including information about qualified Food Analysts, must be updated to ensure that testing activities are conducted under the supervision of appropriately qualified personnel as required by the regulations. Finally, analytical capacity declarations must reflect the current scope of testing capabilities, preventing laboratories from undertaking analyses for which they lack demonstrated competence or accreditation.

The third pillar of compliance concerns adherence to validated and prescribed test methods as specified under the Food Safety and Standards Rules and Regulations. Laboratories are directed to strictly follow only those test methods that have been validated and prescribed by the Authority, ensuring standardization of analytical procedures across the national laboratory network. Furthermore, all testing activities must be conducted strictly within the scope of accreditation granted by the National Accreditation Board for Testing and Calibration Laboratories, which is the national body responsible for assessing laboratory competence against international standards. This requirement ensures that laboratories do not operate beyond their demonstrated technical competence and that all test results are generated within a framework of quality assurance that meets international benchmarks. The NABL accreditation requirement also facilitates mutual recognition of test results across jurisdictions and supports India’s participation in international food trade through confidence in the national laboratory infrastructure.

The fourth pillar establishes mandatory compliance with the prescribed test report format as stipulated under the Food Safety and Standards Rules and Regulations, without any deviation from the standardized templates. The uniformity of reporting formats serves multiple regulatory objectives, including ensuring that all essential information is captured in a consistent manner, facilitating comparison and aggregation of test results across different laboratories and time periods, and ensuring the legal admissibility of test reports in enforcement proceedings. Standardized formats also enable automated processing of test data and support the integration of laboratory information into broader food safety surveillance systems.

The Authority has explicitly warned that continued non-compliance with these requirements will attract appropriate action as per the provisions of the Food Safety and Standards Act, rules, and regulations made thereunder. This enforcement warning signals the Authority’s determination to move beyond advisory approaches and impose substantive consequences on laboratories that fail to meet their statutory obligations. The specific nature of enforcement actions available to the Authority includes suspension or cancellation of laboratory recognition or notification, imposition of penalties as prescribed under the Act, and other regulatory measures designed to protect the integrity of the food safety system. The threat of enforcement action creates strong incentives for compliance and establishes accountability mechanisms that are essential for maintaining public confidence in food testing outcomes.

The directions have been issued to all FSSAI-notified laboratories by the Advisor, Quality Assurance Division, operating from the Authority’s headquarters. The Order carries immediate effect and requires urgent attention from all affected laboratories to review their current compliance status and implement necessary corrective measures. The comprehensive nature of the directions, covering digital integration, quality assurance, methodological standardization, and reporting protocols, reflects the Authority’s holistic approach to laboratory regulation and its recognition that effective food safety governance requires excellence at every stage of the testing process.

In conclusion, the Order issued by the Food Safety and Standards Authority of India represents a critical enforcement intervention designed to address systemic non-compliance in the food testing laboratory sector and to strengthen the analytical foundation of the national food safety regime. By mandating real-time upload of test reports on the InFoLNet portal, requiring maintenance of updated and accurate laboratory profiles, enforcing strict adherence to validated test methods within NABL accreditation scope, and standardizing reporting formats, the Authority has established a comprehensive framework for laboratory accountability that addresses the full spectrum of operational requirements. The explicit warning of enforcement action for continued non-compliance underscores the binding nature of these obligations and the Authority’s commitment to maintaining the highest standards of scientific integrity in food safety testing. As the food safety landscape becomes increasingly complex with the emergence of new contaminants, novel food technologies, and expanding international trade, the reliability of laboratory testing becomes ever more critical to protecting public health and facilitating regulatory decision-making. The successful implementation of these directions will require active cooperation from laboratory operators, sustained oversight by the Authority, and continuous refinement of the regulatory framework based on technological advancements and practical experience. The Order ultimately reaffirms the principle that food safety is a shared responsibility in which laboratories play an indispensable role, and that this role must be discharged with the utmost professionalism, transparency, and accountability.

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