How to start a private-label food brand with a manufacturer in India

All three put your name on food someone else makes. The difference is whose recipe it is and how much of the product is yours alone.

Private label is the retail term. The US Department of Agriculture's Economic Research Service describes private labels as store brands, and notes that supermarkets obtain them through a form of vertical coordination or from manufacturers specialising in private-label products (USDA ERS, ERR-129). The product is sold as the retailer's or brand owner's own.

White label has no definition in the food rules cited in this guide. In this guide it means a product the maker already makes, sold under your name with little or no change. It is the quickest route to a shelf, and the least exclusive: the same product can carry several names.

Contract manufacturing is the legal shape underneath both. India's food regulator counts contract manufacturers and contract packers as manufacturers in their own right (FSSAI kind-of-business list). The label then has to say who made the food and for whom. In the US, where the named firm did not make the food, the name is qualified with a phrase such as 'Manufactured for' or 'Distributed by' (21 CFR 101.5). In India the brand owner's name and address are preceded by words such as 'Manufactured by' or 'Marketed by' (FSSAI Labelling and Display Regulations, 5(6)).

There are six: brief, sample, brand and pack, produce, certify and document, dispatch. This is how the house runs it on Make, through its circle of makers.

• Brief. You name the product, the market and the standard it must meet. That is enough to start.
• Sample. Sealed and sent for approval before anything is contracted.
• Brand and pack. To your market's labelling law, or your existing artwork applied.
• Produce. By the circle member best suited to the product, against your sealed sample.
• Certify and document. A certificate of analysis for every lot.
• Dispatch. To your warehouse or marketplace fulfilment centre in India, or FOB, CIF or C&F from Mundra for export.

Poorti Mandalam LLP is a food house, not a factory. It works through a circle of farmers, processors, manufacturers, testing laboratories and logistics partners, and you deal with one house. If you are starting a brand in India from nothing, Launch sets out fixed packages that end in a first production run, beginning with a Blueprint: a viability check, a unit-cost sheet, the FSSAI licensing route, a label and pack brief, and a manufacturing quote.

Three things: the product, the market and the standard. Everything else in the job follows from those three.

• The product. A description, a benchmark you want to match or beat, the pack format and the sizes.
• The market. Where it will be sold, and through which channel. The destination decides the label, the testing and the export papers.
• The standard. The specification it must meet, written as limits you can test: moisture, microbiology, contaminants, and any claim you intend to print.
• Your artwork, if you have it. Otherwise, your name and the words you want on the pack.
• A realistic first volume. Makers plan trials and minimum runs around it.

A vague brief is the commonest reason a first sample misses. If you cannot write the standard yet, say so. Writing it is part of the work.

The factory needs an FSSAI licence or registration for its premises, and you, as the brand owner, need your own. These are the rules; they tell you what to ask a maker to show you.

For general manufacturing, FSSAI's current list sets the level by annual turnover: registration up to ₹1.5 crore, a State licence above ₹1.5 crore up to ₹50 crore, and a Central licence above ₹50 crore (FSSAI kind-of-business list). The same list defines a relabeller as a food business operator who gets its product manufactured or packed by a third-party manufacturer or processor. That is the category for a brand owner using a contract manufacturer.

You may hear this arrangement called a loan licence. FSSAI's current kind-of-business list does not use that term. On FSSAI's online system, a relabeller adds each contract manufacturer to the application and must hold an online no-objection certificate from at least one of them before it can submit (FoSCoS relabeller manual).

Both licences then appear on the pack. The FSSAI logo and licence number of the brand owner must be displayed, and the licence number of the manufacturer or packer too, if different from the brand owner (FSSAI Labelling and Display Regulations, 5(7)).

The exporter needs an Importer Exporter Code, an FSSAI licence for export, and in some categories a registration with a commodity board. Which one applies depends on the product.

FSSAI's list also provides for an exporter-manufacturer whose products do not comply with Indian rules but do comply with the rules of the importing country (FSSAI kind-of-business list). In practice this means an export pack is built to the destination's label law, not India's. The food label requirements guide sets those out market by market.

The factory must be registered with the FDA, and your US importer must run a foreign supplier verification programme. The first is the maker's job; the second is the importer's.

Any facility, domestic or foreign, that manufactures, processes, packs or holds food for consumption in the United States must register with the FDA unless an exemption applies (21 CFR 1.225). Registration is renewed every other year, between 1 October and 31 December of each even-numbered year (21 CFR 1.230). A foreign facility must name a US agent in its registration (21 CFR 1.232).

The FSVP importer is the US owner or consignee of the food at entry, or, if there is none, the US agent or representative of the foreign owner or consignee (FDA, FSVP). That importer must analyse the hazards in each food, evaluate the foreign supplier, approve it and carry out verification activities. FDA accepts a DUNS number as the unique facility identifier the importer gives for each line entry.

Ask the maker for its FDA registration number before you plan a US shipment, and confirm who your FSVP importer will be. A shipment with no answer to either question is not ready to leave.

A sealed sample is the approved product, packed so that it cannot be opened without showing it. It is the physical reference every later lot is judged against.

When you approve a trial, the same batch is split. Part comes to you, part stays with the maker, and each is sealed, labelled with a date and a reference, and kept. Your specification describes the product in words and numbers. The sealed sample shows what those words meant on the day you said yes.

It protects you three ways. It stops drift, because production is checked against a fixed reference, not memory. It settles disputes, because both sides hold the same thing. And it gives a laboratory something to test a complaint against. On Make, the sample is sealed and sent for approval before anything is contracted, and production runs against your sealed sample.

Keep yours unopened, in the storage conditions on the label, for at least the shelf life of the lots it governs.

A certificate of analysis is the test report for one lot. It should let you match a result to a lot, a method and a laboratory, and compare it with your specification.

US rules give a useful benchmark. An FSVP importer must keep records of each sampling and testing of a food that identify the food tested, including the lot number, the number of samples, the tests and analytical methods, the test and report dates, the results, any corrective actions, and the laboratory that did the testing (21 CFR 1.506). A certificate that carries the same details will serve you in any market.

• Product name and lot or batch number, matching the pack and the invoice.
• Date of sampling and date of the report.
• Each parameter tested, with the method used.
• The result next to your specification limit, with a pass or fail.
• The laboratory's name and signature.

In India, a maker without its own laboratory must have regular testing done through an accredited laboratory notified by FSSAI (FSSAI Licensing and Registration Regulations, Schedule 4). A certificate that names no laboratory, no method or no lot number tells you very little.

Visit, or send someone to visit, while the line is running. Check the factory against the hygiene rules it is licensed under, and ask to see the documents those rules require.

In India the reference is Schedule 4 of the FSSAI licensing regulations, which sets the hygiene and sanitary practices every licensed food business must follow (FSSAI Licensing and Registration Regulations, Schedule 4). It requires the business to identify the steps in its activities that are critical to food safety. The international reference is the Codex General Principles of Food Hygiene, CXC 1-1969 (Codex Alimentarius). A HACCP plan rests on seven principles, from conducting a hazard analysis to keeping records (FDA, HACCP principles).

Ask to see the documents a manufacturer files for its FSSAI licence. The application list includes a water analysis report from a recognised laboratory, a food safety management system plan or certificate if any, and a recall plan where applicable (FSSAI Licensing and Registration Regulations). Then ask for recent certificates of analysis and the pest control records. Read the licence itself, and match the name on it to the company that will invoice you.

If you buy from outside India and cannot travel, the house sells this as a service. A factory inspection checks the licence against the invoice, sees the line running, looks at storage, handling and packing, sets claimed capacity against visible capacity, draws samples from live stock, photographs every area with the date, and records the maker's export history.

This guide is general information, not legal advice. Regulations change: it states what each rule said when the guide was checked on 13 October 2026. Read the current text of each regulation, and confirm your licensing route with the authority, before you sign a contract or print a pack.