One Form, One Hundred Rupees, Three Months: FSSAI’s Quick-Fix for Seasonal Food Businesses

Every October small queues of hawkers appear outside puja pandals. Until now these micro food businesses lived in a strange grey zone: the Food Safety and Standards Act recognised “seasonal” operators back in 2011, yet the online portal FoSCoS had no button to register them. Vendors either paid for an annual licence they did not need or simply stayed outside the law. On 15 October 2025 the Authority quietly closed that gap with a single-page order that is already live on the dashboard since 1 August.
The legal root of the problem was never the Act itself. Section 31(2) of the 2006 statute and Regulation 2.1.2 of the Licensing & Registration Rules always allowed the Centre to create a lighter “registration” track for petty retailers. Form A in Schedule-II even carried the words “seasonal business” in plain English. What was missing was an electronic workflow and a fee line-item. State licensing officers therefore rejected online applications or pushed them into the full ₹750-plus annual stream, forcing organisers to look the other way when temporary stalls came up.
The new directive, issued under the Authority’s general power in Section 16(5) and the delegated rule-making clause in Regulation 2.1.3(3), tells commissioners of food safety to activate a “Generate Seasonal Registration” tab inside their existing FoSCoS state accounts. A registering authority now fills Form A on behalf of the applicant, chooses the correct Kind-of-Business code retail shop, tea-snack kiosk, mobile hawker or food-vending agency pins the exact stall location on a satellite map, e-signs with Aadhaar OTP and pays ₹100 through RazorPay or PayU. Hawkers continue to be fee-exempt thanks to a January 2024 circular, so for them the process is free. The certificate is auto-generated, carries a unique reference number and is valid for a maximum of ninety days, after which it simply lapses; there is no renewal, only a fresh application for the next fair.
Because the window is event-specific, the Authority has kept the paper trail minimal: one passport photo, one identity proof and a self-attested declaration that the stall will follow sanitary practices. The accompanying ten-step user manual warns applicants to react within thirty days if an inspector raises an online query, to ignore any phone demand for money and to keep a downloaded copy of Form A until the fair ends. The entire cycle from login to printable certificate takes roughly ten minutes if documents are ready.
For food-business operators the relief is immediate. A peanut-vendor who sets up shop only during Navratri no longer has to buy a five-state central licence or risk penalties under Section 55. For regulators the move plugs a long-bleeding hole: random samples collected at melas can now be traced to a registered entity, making recall and liability meaningful. Banks and event managers also gain; a valid FoSCoS number is increasingly asked for while sanctioning temporary power or space allotments.
The order is less a new law than a belated ignition of an existing one. By marrying the 2011 text to 2025 technology FSSAI has shown that compliance need not wait for another amendment; sometimes it only needs a dropdown menu. As the country braces for another season of festivals, the message to every chaat wala outside a mandap is refreshingly simple: one form, one hundred rupees, three lawful months no more hiding in the regulatory shadows.
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