In India, the Food Safety and Standards Authority of India (FSSAI) is the highest authority for food regulation. Its primary focuses are to ensure food safety, create a scientific standard, and regulate food production and distribution. FSSAI has historically focused on regulatory aspects of human food; however, the authority both enforces and supports the Bureau of Indian Standards (BIS) standard IS 11968:2019 "Pet Food for Dogs and Cats - Specification (First Revision)" indirectly. BIS introduced the IS 11968:2019 standard in support of improving quality, safety, and nutritional standards of pet-food products in India. This paper seeks to explore the authority's role of FSSAI in enforcing IS 11968:2019 and the difficulties encountered in accordance with IS 11968:2019 while also touching upon the changing contours of governance and safety of pet-food in India. [1]
FSSAI’s Role in Regulating Compliance with IS 11968:2019 for Pet Foods
In India, the Food Safety and Standards Authority of India (FSSAI) is the highest authority for food regulation. Its primary focuses are to ensure food safety, create a scientific standard, and regulate food production and distribution. FSSAI has historically focused on regulatory aspects of human food; however, the authority both enforces and supports the Bureau of Indian Standards (BIS) standard IS 11968:2019 “Pet Food for Dogs and Cats – Specification (First Revision)” indirectly. BIS introduced the IS 11968:2019 standard in support of improving quality, safety, and nutritional standards of pet-food products in India. This paper seeks to explore the authority’s role of FSSAI in enforcing IS 11968:2019 and the difficulties encountered in accordance with IS 11968:2019 while also touching upon the changing contours of governance and safety of pet-food in India. [1]
FSSAI’s Mandate and Pet Food Regulation
IS 11968:2019 is a voluntary Indian Standard (IS – Indian Standard) developed by the Bureau of Indian Standards (BIS). FSSAI intersects with IS 11968:2019 based on its mandate to protect public health against food safety hazards, which includes hazards related to animal-origin ingredients in pet foods. The Food Safety and Standards Act, 2006 establishes a broad set of provisions that deal with food safety, hygiene, contamination, adulteration, labeling, and so forth. While FSSAI does not have any statutory regulation of pet foods per se, it will have jurisdiction to enforce general safety provisions, including the following:
- Good Manufacturing Practices (GMP) for all food production facilities (including pet food facilities)
- Microbial safety and pathogens, such as Salmonella or Listeria species
- The level of chemical contaminants and heavy metals in ingredients
- Packaging and labeling requirements through multiple associated acts, including the Legal Metrology Act
- Registration and Licensing of food business operators
This framework forms a compliance baseline consistent with many IS 11968:2019 provisions, indirectly influencing pet food safety compliance and pet food product regulation services across manufacturing units. [2]
Regulatory Challenges Specific to Pet Food
FSSAI encounters notable obstacles in consistently implementing IS 11968:2019 due to:
- The voluntary nature of IS 11968:2019, which restricts mandatory enactment
- The absence of a legal framework for pet food safety in FSSAI’s regulations
- The confusion about whether pet foods are classified as food for humans, animal feed or a separate category.
- The variation in licensing and enforcement powers at state level creates inconsistency in regulation,
Some pet food types are innovating fast, often at a pace that existing laws continue to be unsuitable for innovation in regulation.
Table 1: below summarizes the regulatory gaps and challenges in FSSAI enforcement related to IS 11968:2019.
Challenge | Description | Impact on Enforcement |
Voluntary Standard | IS 11968:2019 is not legally binding | Limits mandatory compliance |
Legal Categorization Ambiguity | Pet food not clearly within food/feed laws | Confusion over applicable norms |
Licensing Variability | Inconsistent licensing across states | Patchy regulatory oversight |
Innovation & New Formulations | Rapid market evolution | Need for adaptive regulatory approach |
Resource Constraints | Limited specialized enforcement staff | Delays in inspections and testing |
FSSAI Enforcement Mechanisms Relative to IS 11968:2019
Despite recent difficulties, the FSSAI continues to advocate for the principles of food safety as it relates to pet food through:
- Licensing and Registration: Pet food producers must receive licenses to operate under FSSAI standards which implies they are subject to inspections as well as compliance checks or other obligations.
- Inspections and Surveillance: FSSAI conducts audits of factories and collect samples to send for microbial, as well as other contaminant analysis, and tests using BIS laboratories or other accredited partners. During these audits, the factories are assessed on compliance with hygiene and safety standards defined in IS 11968:2019.
- Test and Verification of Standards: Laboratories authorized by FSSAI test pet food through nutrient profiling, screening for contaminants, as well evidence that microbial limits were not exceeded, consistent with IS 11968:2019.
- Recall and Complaints Handling: FSSAI facilitates the recall of pet food products that are either unsafe, and/or potentially non-compliant with regulation. FSSAI also handles consumer complaints related to safety and contaminations in pet food.
- Awareness and Capacity Building: FSSAI develops guidelines in consultation with stakeholders, and then usual issues guides related, for example, to the emerging standards for pet food. [3]
Table 2 below highlights the relationship between IS 11968:2019 key provisions and FSSAI enforcement actions.
IS 11968:2019 Provision | FSSAI Enforcement Focus | Outcome Benefits |
Nutritional Adequacy | Labeling accuracy and nutrient testing | Ensures truthful consumer information |
Microbiological Safety | Hygiene inspections and pathogen testing | Minimizes risk of pet and public health |
Chemical Contaminant Limits | Screening for heavy metals, pesticides | Protects animal and human health |
Labeling & Packaging | Verification under legal metrology and FSSAI | Prevents consumer deception |
Traceability and Recall Protocol | Documentation audits and consumer protection law | Enables effective product recall |
Industry Impact and Growing Compliance Trends
The rise in consumer awareness of pet health has prompted manufacturers to voluntarily adhere to IS 11968:2019, and sometimes FSSAI’s food safety standards as well, to enhance market acceptance and brand value. Leading companies often engage certified food research laboratories specializing in animal food product development, pet food formulation, and pet food product innovation services to ensure scientific rigor and regulatory adherence, fostering consumer trust and market competitiveness.
Simultaneously, FSSAI is bringing clarity to pet food regulations with efforts such as consulting stakeholders, exploring possibilities of modifying present food safety statutes to include potential future amendments to food safety standards for pet foods that incorporate either IS 11968:2019 or similar standards. [4]
Outlook for Pet Food Regulation in India
With dedicated pet food safety regulations that are based on best practices internationally, FSSAI is fortifying its role as a regulator. Very soon we will start to see the mandatory IM 11968:2019 be used as a norm, along with an accountable licensing framework, robust surveillance framework and a more uniform regulation. Regulatory changes will likely include:
- A formal definition of pet food under the FSSAI Act
- Mandatory compliance to the BIS nutritional and safety standards
- Stricter penalties for n to compliance and mislabeling
- Encouragement for third-party certification and quality assurance programs
This will lead to higher quality and safer pet food products and make India’s pet food industry consistent with expectations globally. [5]
Conclusion
Though IS 11968:2019 is currently voluntary, FSSAI’s role in enforcing applicable food safety principles indirectly advances pet food safety in India. Through hygiene controls, contaminant monitoring, labeling verification, and licensing, FSSAI has laid a crucial foundation for safe and quality pet food development. Collaboration with expert facilities like Food Research Lab, which provides cutting-edge testing and innovation services, further supports manufacturers in ensuring compliance with IS 11968:2019 and accelerating animal food product development. As clarity and regulations evolve, FSSAI’s collaboration with BIS and industry players will be vital to mainstream compliance, protecting companion animal health and strengthening consumer confidence in the Indian pet food market.
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