The Food Safety and Standards Authority of India (FSSAI) is the top regulatory body overseeing food safety and hygiene across the country. If you run a food business, whether as a manufacturer, importer, or processor, you must comply with not just licensing requirements but also periodic reporting, especially the FSSAI Annual Return. Many food business operators (FBOs) are often unaware or careless about this compliance, but the consequences of missing deadlines or skipping annual return filing can be severe. This article explains the last date for FSSAI annual return filing, the penalties for late or missed submissions, the impact on businesses, and why it is mandatory under law.
What is the FSSAI Annual Return?
The FSSAI Annual Return is a mandatory report that certain categories of licensed food businesses need to file annually or half-yearly, depending on the product and operations. It contains key details about the production, sales, imports, or handling of food products within a financial year.
Specifically, manufacturers and importers must submit the Form D1 (annual return), while manufacturers of milk and milk products also need to submit Form D2 (half-yearly return). These forms capture essential information such as:
- Quantity of food produced, handled, or imported
- Type and category of food products
- Value of food products
- Details of procurement and distribution
Filing these returns ensures that the FSSAI has updated records of the operational activities of food businesses, helping in food safety audits, traceability, and public health protection.
Who is Required to File the FSSAI Annual Return?
Not all FBOs need to file annual returns. As per the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011, only FSSAI-licensed (not registered) businesses are required to submit these returns.
This includes:
- Food manufacturers
- Food importers
- Processors
- Packers
- Repackers
- Milk and milk product manufacturers (also half-yearly return)
Retailers, food service establishments, restaurants, and petty manufacturers usually holding just FSSAI registration (not license) are exempt from this requirement.
Last Date for Filing FSSAI Annual Return for FY 2024-25
The last date for filing the FSSAI Annual Return (Form D1) is 31st May of every year for the preceding financial year (April to March). For example, for the financial year 2024-2025, the last date for filing the annual return will be 31st May 2025.
For milk and milk product manufacturers, the Form D2 half-yearly return is due twice a year:
- First half (April to September): by 30th November
- Second half (October to March): by 31st May
It is important to understand these dates because failure to submit the return on time leads to legal and financial penalties.
Penalty After the Last Date for Submission
As per Clause 2.1.13(3) of the FSS (Licensing and Registration) Regulations, 2011, if the FBO fails to file the annual or half-yearly return by the due date, they are liable to pay a penalty of Rs. 100 per day beyond the deadline.
Let’s break this down:
- If you miss the deadline by 10 days, you owe Rs.1,000
- If you delay submission by a month, the penalty rises to Rs. 3,000
- If you don’t file at all, your liability keeps increasing daily
Moreover, continued non-compliance can lead to suspension or cancellation of the FSSAI license, barring the food business from legally operating.
Thus, ignoring return filing is not just a small administrative lapse — it can escalate into a major compliance issue, affect your operations, and hurt your finances.
Impact of Not Filing or Delayed Filing of FSSAI Return
Failure to comply with FSSAI annual return requirements can impact businesses in several ways:
Financial Loss Due to Penalty
The immediate impact is the financial penalty of Rs.100 per day, which adds up quickly. For small and medium enterprises (SMEs), this is a needless financial drain.
Risk to License Renewal
When applying for FSSAI license renewal, the authority checks whether you have submitted past returns. Non-compliance can lead to delays or outright rejection of your renewal application.
Legal Consequences
Non-filing can attract legal action under the Food Safety and Standards Act, 2006, including suspension or cancellation of your license.
Damage to Reputation
In today’s consumer-sensitive market, businesses boasting of FSSAI compliance stand apart. Being flagged as non-compliant can hurt consumer trust, supplier relationships, and business opportunities.
Disqualification from Government Schemes
FBOs often apply for government tenders or benefit from food subsidy schemes. FSSAI compliance is a basic eligibility — non-compliance can lead to disqualification from such programs.
Operational Disruption
Without a valid FSSAI license (due to cancellation or suspension), the business cannot manufacture, sell, or distribute food products. This leads to revenue loss and operational disruptions.
Why is FSSAI Return Filing Mandatory?
Filing the FSSAI annual return is mandatory under law. But beyond legal obligations, it serves important purposes:
Monitoring Food Safety
The return allows the regulatory body to monitor food production, sales, and imports, ensuring that food safety standards are maintained across the supply chain.
Traceability
If there is a food safety incident, the data from annual returns helps trace the source of the problem, preventing further harm.
Market Regulation
The return data helps regulators understand market trends, prevent hoarding, control food inflation, and manage food security.
Accountability and Transparency
The return system ensures that businesses are accountable for their food operations, promoting transparency.
Supporting Public Health
By ensuring that businesses report quantities, categories, and safety measures, the system ultimately protects public health.
Ignoring this responsibility undermines the overall objective of the FSSAI system and poses risks not just to the business but to society at large.
Step-by-Step Process for FSSAI Annual Return Filing
The process of filing the FSSAI annual return is straightforward if done carefully:
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Collect Required Data: Gather records of food products manufactured, handled, imported, or sold, along with quantities, values, and related details.
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Download Forms: Access Form D1 (or D2 for milk product manufacturers) from the FSSAI website.
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Fill Out the Forms: Complete the forms carefully, ensuring accurate reporting of all required fields.
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Submit Forms: Submit the filled forms to the Licensing Authority or designated Food Safety Officer either online (where applicable) or via email/post as instructed.
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Keep Acknowledgement: Always retain a copy of the submitted return and acknowledgement for records.
Consequences of Repeated Non-Compliance
Repeated failure to submit annual returns may lead the FSSAI to take harsher actions such as:
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Suspension of license until compliance is restored
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Cancellation of license for persistent offenders
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Disqualification from reapplication in severe cases
Such actions can devastate the business, as operating without a valid FSSAI license is illegal. It also exposes the promoter or directors to personal liability.
Conclusion
FSSAI annual return filing is not just a compliance activity, it plays an important role in ensuring food safety, public health, and fair market practices. FBOs must take this obligation seriously, keeping track of deadlines, penalties, and the operational impacts of non-compliance. By embedding FSSAI compliance into their business systems, companies can avoid penalties, secure smooth operations, and contribute to a healthier, safer food ecosystem in India.
If you are unsure about your obligations or how to file correctly, then you can connect with the Compliance Calendar LLP experts to ensure you meet all requirements on time.
Email: info@ccoffice.in
Call/Whatsapp: +91 9988424211
Frequently Asked Questions (FAQs)
Q1. Who needs to file the FSSAI annual return?
Ans. All licensed food manufacturers, importers, packers, and processors (excluding those with just registration) must file the annual return.
Q2. What is the last date for filing the annual return?
Ans. The deadline is 31st May every year for the preceding financial year (April–March).
Q3. What forms are used for FSSAI returns?
Ans. Form D1 is for all licensed manufacturers and importers; Form D2 is for milk and milk product manufacturers (half-yearly).
Q4. What happens if I miss the return filing deadline?
Ans. A penalty of Rs.100 per day is imposed from the date of delay, and continuous non-compliance can lead to license suspension or cancellation.
Q5. Can I file the return online?
Ans. Yes, depending on the state, online filing or email submission options may be available. Check with your Licensing Authority.
Q6. Are food retailers or restaurants required to file annual returns?
Ans. No, retailers, restaurants, and petty manufacturers with only FSSAI registration are exempt from filing annual returns.
Q7. Can the penalty be waived if I have a valid reason for the delay?
Ans. Generally, the penalty is mandatory under the law. However, you may apply for a waiver citing valid reasons, though approval is at the authority’s discretion.
Q8. How do I confirm that my return has been accepted?
Ans. You should receive an acknowledgement from the Licensing Authority. Keep this as proof of compliance.
Q9. Is filing the annual return necessary if no business activity was conducted?
Ans. Yes, even if there was no business activity, a nil return must be filed to maintain compliance.
Q10. What documents should I keep for FSSAI return filing?
Ans. Maintain production records, sales invoices, import/export documents, and any related operational data for accurate filing and future reference.