Food Grade Packaging Is Now a Critical Inspection Item: What Takeaway and Cloud Kitchens Need to Know

For many restaurants, packaging used to be a background detail. That changed with an FSSAI order dated 3 April 2025. The order reclassified the inspection checklist point on food grade packaging material as critical to food safety. For businesses that pack food for takeaway or delivery, this is now one of the eleven items that can decide the outcome of an inspection on its own.

What exactly changed

Before the order, the Catering checklist item 32 read, in short, that packaging and wrapping material coming in contact with food is clean and of food grade quality. It carried 2 marks and was not a critical item.

After the order, the requirement reads that packaging material including wrapping material coming in contact with food is clean and of food grade, and that the packaging material used shall have a certificate of conformity issued by a NABL accredited laboratory against the FSS (Packaging) Regulations, 2018, with records checked. It now carries 4 marks and is a starred, critical item.

The order made similar changes to the General Manufacturing, Milk and Milk Products, Meat Processing, and Fish and Fish Products checklists, and states that the change has been implemented in FoSCoS. All other points in the checklists remain unchanged.

Why it matters so much now

Under the FSSAI marking scheme, failure in any critical item leads to non compliance, and partial compliance is not available on critical items. So a takeaway kitchen with excellent hygiene can still end up non compliant if it cannot show that its containers and wraps are certified food grade.

Who is affected

• Cloud kitchens and delivery only brands, where almost every order is packed.
• Restaurants and cafés that offer takeaway or delivery.
• Caterers who pack meals for events, offices or schools.
• Tiffin and dabba services that pack food in disposable containers or wraps.

If your business serves food only on plates for dine in, packaging may not apply to you. In our self assessment, item 32 is automatically marked not applicable when you say you do not pack or wrap food.

How to comply, step by step

1. List every material that touches food: containers, lids, foil, butter paper, cling film, bags for hot items, cups and cutlery.
2. Ask each supplier for a certificate of conformity from a NABL accredited laboratory against the FSS (Packaging) Regulations, 2018, for the exact product you buy.
3. If a supplier cannot provide one, switch to a supplier who can.
4. Keep the certificates in your records file, together with purchase bills, so an officer can match certificates to what is on your shelf.
5. Store packaging clean, covered and away from chemicals, since the checklist also asks for separate storage for food, packaging materials and chemicals (item 13).
6. Stop using anything that is clearly not food grade, such as printed newspaper or unknown recycled plastic, for food contact.

Common questions

Is an invoice that says food grade enough?

The order asks for a certificate of conformity issued by a NABL accredited laboratory, and says inspectors will check for records. An invoice or a printed claim on the box is not the same thing. Ask the supplier for the certificate itself and keep a copy.

What if I do not pack food at all?

Then the requirement does not apply to you. Under the FSSAI order of 2 November 2022, requirements that are not applicable to a business are left out when the score and grade are worked out, so they neither add nor remove marks.

What if I cannot get the certificates straight away?

Treat it as a priority. Partial compliance is not available on critical items, so an inspector can only record this item as compliant or non compliant. Keep written requests to your suppliers as proof that you are acting, and change suppliers if needed.

How does this connect to the rest of the checklist?

Packaging links to two other items. Item 13 asks for adequate and separate storage for food, packaging materials and chemicals, and item 47 asks for documentation and records to be available and retained. Your certificates belong in the same records file as your water tests and pest control reports.

A quick self check

• Could you show a certificate for every type of container and wrap you used this week?
• Do the product names on the certificates match the products in your store?
• Is your packaging stored clean and covered?

If the answer to any of these is no, treat it as an urgent fix rather than routine paperwork.