FSSAI & Food Product Compliance Policy

This FSSAI & Food Product Compliance Policy (“Policy”) sets out the food safety, food product and FSSAI compliance requirements applicable to Distributors offering food and food-related FMCG products through SutraFin (“Platform”), owned and operated by SutraOS Technologies Private Limited (“Company”). For the purposes of this Policy, “Applicable Law” means all applicable laws, rules, regulations, notifications, orders, directions and advisories issued by any competent governmental or regulatory authority relating to food safety, food products and FSSAI requirements. Distributors shall ensure that all food products offered through the Platform are sourced, stored, handled, packaged, labelled and delivered in compliance with Applicable Law and the requirements set out in this Policy.

1. FSSAI Registration and Licence

1.1Distributors offering food products through the Platform are required to hold and maintain all FSSAI registrations, licences and other regulatory approvals applicable to the relevant food products and activities.

1.2The applicable FSSAI registration or licence should cover the relevant food business activities and categories of food products offered through the Platform.

1.3FSSAI registration or licence details provided to the Company should remain valid and current throughout the period during which the relevant food products are offered through the Platform.

1.4Any expiry, suspension, cancellation, modification or other regulatory action affecting an FSSAI registration or licence, or the ability to lawfully offer a food product through the Platform, should be notified to the Company within 24 hours.

2. Verification and Compliance Information

2.1The Company may verify FSSAI registration or licence details and other food product compliance information through FoSCoS, FSSAI databases, government databases, authorised APIs, documents or other lawful sources.

2.2Distributors may be required to confirm or update FSSAI registration or licence details and other compliance information periodically or where required for verification.

2.3The Distributor shall provide accurate, complete and current information and shall promptly provide any document or information reasonably required by the Company for compliance verification.

2.4The Company may request additional information or documents reasonably required to verify compliance with this Policy or Applicable Law.

3. Food Product Information

3.1Product information provided for listing food products on the Platform must contain all information necessary for the lawful listing, sale and supply of the relevant food product.

3.2The information provided by the Distributor shall, as applicable, include the product name, brand, ingredients, nutritional information, allergen information, net quantity, applicable declarations, FSSAI details, batch or lot information, date of manufacture or packing, expiry or use-by date, storage conditions, country of origin and other information required under Applicable Law, as applicable to the relevant food product.

3.3Product information, declarations, labels, images, descriptions and claims should accurately represent the relevant food product and should not be false, misleading or unsupported.

3.4Information displayed on the Platform should be consistent with the information appearing on the physical product label, wherever applicable.

3.5Any material change or discrepancy affecting the accuracy or validity of product information should be notified to the Company and the relevant information should be updated.

4. Product Safety and Authenticity

4.1Food products offered through the Platform should be genuine, lawfully sourced, fit for human consumption and compliant with Applicable Law.

4.2Food products that are adulterated, contaminated, counterfeit, misbranded, prohibited, unsafe, expired or otherwise non-compliant with Applicable Law should not be offered through the Platform.

4.3Food products should be supplied in appropriate packaging and should not be supplied where the packaging is damaged, tampered with, leaking or otherwise compromised in a manner that may affect food safety or product integrity.

4.4Applicable requirements relating to sourcing, packaging, labelling, quality and safety should be followed in respect of food products offered through the Platform, to the extent applicable to the activities undertaken by the Distributor.

5. Expiry and Shelf Life

5.1The Distributor shall not list, supply or deliver any expired food product through the Platform.

5.2Food products should comply with Applicable Law relating to minimum remaining shelf life at the time of dispatch and delivery.

5.3The Company may prescribe additional minimum residual shelf-life requirements for specific food categories based on applicable law, product characteristics or operational requirements. The Distributor shall comply with such requirements once communicated by the Company.

5.4Food products that do not satisfy the applicable shelf-life requirements should be removed from listing or supply through the Platform.

6. Storage, Handling and Delivery

6.1Food products should be stored, handled and transported in accordance with Applicable Law and the storage conditions specified for the relevant product.

6.2Appropriate conditions should be maintained to prevent contamination, deterioration, damage or tampering during storage, handling and transportation.

6.3Temperature-sensitive, chilled, frozen or otherwise controlled-temperature food products shall be offered through the Platform only where the Distributor has appropriate infrastructure and controls to maintain the required conditions during storage and delivery.

6.4The condition and safety of food products should be maintained until delivery to the relevant purchaser.

7. Recall and Food-Safety Incidents

7.1The Company should be promptly notified of any recall, actual or suspected contamination, food-safety incident, regulatory prohibition, safety warning, material quality issue or regulatory action affecting a food product offered through the Platform.

7.2Information reasonably required for the investigation, withdrawal or recall of an affected food product should be provided to the Company, including, where available, batch or lot details, affected inventory, orders and dates of supply.

7.3Distributors are expected to cooperate with the Company in relation to product recalls, withdrawals, delisting, corrective action, customer communication and regulatory enquiries.

7.4The Company may suspend or block orders, delist products, restrict the Distributor's access to affected listings or take other appropriate action where reasonably necessary to address a food-safety or regulatory concern.

8. Complaints

8.1Food quality, safety or authenticity complaints relating to products supplied by a Distributor may be communicated to the Distributor through the applicable Platform support or grievance process.

8.2Distributors are expected to investigate and respond to such complaints within 2 Business Days of receiving the complaint or request for information.

8.3Appropriate corrective action should be taken where a complaint identifies a genuine food-safety, quality, labelling or other product compliance issue.

9. Records and Traceability

9.1Records required under Applicable Law should be maintained in relation to food products supplied through the Platform.

9.2Records should be sufficient to support identification and traceability of food products, including, where applicable, batch or lot details, inventory information, procurement records and supply information.

9.3Relevant records and information should be made available to the Company where reasonably required for compliance verification, investigation, traceability, recall or response to a regulatory requirement.

10. Non-Compliance and Enforcement

10.1Non-compliance with this Policy or Applicable Law may result in appropriate action by the Company, including restriction or removal of food product listings, suspension or cancellation of affected orders, or restriction or suspension of access to the Platform, depending on the nature and severity of the non-compliance.

10.2The Company may take such further action as may be required under Applicable Law or reasonably necessary to address a food-safety or regulatory concern, including cooperation with competent authorities.


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