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FSSAI Schedule 4 Explained: GMP, GHP and Hygiene Audits 2026
FSSAI Safety Norms · Schedule 4

Last reviewed: 12 August 2026. Every FSSAI registration and licence carries an annexure most operators never read: Schedule 4 of the Licensing and Registration Regulations — the Good Manufacturing Practices (GMP) and Good Hygiene Practices (GHP) that inspectors walk in with as a checklist. Since April 2026 it matters twice over: the risk-based inspection framework uses your hygiene and audit record to decide how often you get inspected at all. This guide maps which part of Schedule 4 applies to you, the conditions that generate documents (the ones inspectors actually ask for), and how audits now buy you breathing room.

Quick answer
What Schedule 4 isThe hygiene and safety conditions embedded in every registration/licence — premises, water, equipment, people, records.
Which part binds youPart I: registration-band FBOs · Part II: licensed manufacturing/processing · Parts III–V: milk, meat, catering.
The paper it generatesTest reports (six-monthly for manufacturers), water potability, medical fitness certificates, pest-control and sanitation records, FoSTaC certificates.
Why it pays nowAudit and hygiene outcomes feed the 2026 risk-based inspection framework — a clean file means fewer inspections.

Which part of Schedule 4 applies to you

PartApplies toCharacter
Part IBasic Registration FBOs (up to ₹1.5 crore turnover)General hygiene and sanitary practices — proportionate but real
Part IIState/Central licensees — manufacturing, processing, packing, storage, distributionThe full GMP/GHP framework: premises, layout, water, equipment, personnel, records
Part IIIMilk and milk products unitsSector-specific additions
Part IVSlaughter houses and meat processingSector-specific additions
Part VCatering and food service (restaurants, canteens, caterers, cloud kitchens)Service-side hygiene: receiving, storage, cooking, holding, serving

Note what Part I means in 2026: the businesses that moved from licence to registration under the ₹1.5-crore threshold did not move out of hygiene law — they moved from Part II to Part I. Inspectors can and do visit registration-band units.

The conditions that generate documents

  • Product testing — at least once every six months for manufacturers, at an accredited/notified lab, covering the relevant chemical and microbiological parameters. Keep the reports; they are the first ask in an inspection and a direct input into your risk score.
  • Water: potable-quality water for processing, with periodic test reports on file.
  • People: annual medical fitness certificates for food handlers; FoSTaC-certified supervisors at one per 25 handlers; hygiene wear and practices on the floor.
  • Premises and pests: layout that separates raw from cooked, pest-control contracts and service records, cleaning/sanitation SOPs with logs.
  • Display: the licence/registration certificate and the Food Safety Display Boards (FSDBs) for your category, visible at the premises.
  • Traceability: batch/lot records and supplier invoices that let you trace back and, if ever needed, recall forward.

Third-party audits — from burden to strategy

Under the Food Safety Auditing Regulations, 2018, FSSAI recognises private auditing agencies, and audits are mandated for licensed manufacturers in high-risk categories (milk, meat, fish, egg products, foods for infant nutrition and similar), while remaining a strong voluntary signal for everyone else. The 2026 risk-based framework completed the loop: a satisfactory third-party audit demonstrably reduces routine inspection frequency, because audit outcomes are an explicit input into who gets inspected. For a multi-unit business, an annual audit cycle is now the most economical way to keep inspectors focused elsewhere — and the audit report doubles as buyer-audit and tender documentation. The voluntary Hygiene Rating Scheme does the same job customer-side for food service.

A 30-minute self-inspection, before someone else does it

  • Licence/registration and FSDBs on the wall, current annual fee paid?
  • Last two six-monthly product test reports and the latest water report on file?
  • Medical fitness certificates — all handlers, within twelve months?
  • FoSTaC certificates — enough supervisors for today's headcount, none expired?
  • Pest-control service records and sanitation logs current?
  • FoSCoS reflecting today's products, layout and responsible persons?

Anything failing that list is precisely what an improvement notice would cite — the subject of our guide to FSSAI notices, penalties and appeals.

Frequently asked questions

What is Schedule 4 of the FSSAI regulations?

The schedule of Good Manufacturing Practices and Good Hygiene Practices attached to every FSSAI registration and licence under the Licensing and Registration Regulations. Part I applies to registration-band FBOs, Part II to licensed manufacturing and processing, and Parts III–V add sector-specific conditions for milk, meat and catering.

Does Schedule 4 apply to a small business with only Basic Registration?

Yes — Part I applies below the ₹1.5-crore registration threshold. The conditions are lighter than the licence-grade Part II, but hygiene, safe water, pest control and basic records are still enforceable, and registration-band premises are still inspected.

How often must a food manufacturer test products?

At least once every six months at an accredited or notified laboratory, covering the relevant chemical and microbiological parameters for the product — more often where risk assessment or history demands. Keep the reports; they are standard inspection asks and feed the risk-based inspection score.

Are third-party FSSAI audits mandatory?

For licensed manufacturers in high-risk categories — such as milk, meat, fish, egg products and foods for infant nutrition — periodic third-party audits under the 2018 Auditing Regulations are mandated. For others they are voluntary but valuable: satisfactory audits reduce routine inspection frequency under the 2026 risk-based framework.

What is a Food Safety Display Board (FSDB)?

The category-specific board FSSAI requires FBOs to display at the premises alongside the licence — food-safety practices for the business type in the local language, with the FSSAI licence number. Inspectors treat a missing FSDB as an easy first finding.

How does a CA firm help with hygiene compliance?

The gaps are usually record-side, which is our terrain: we build the testing and training calendars, set up SOPs and registers that produce evidence as a by-product of daily work, coordinate recognised labs and audit agencies, and assemble the compliance file that inspections, buyer audits and bank appraisals all draw on.

Would your premises pass a walk-in today?

We run a Schedule 4 gap review — documents, testing, training, display — and set up the registers and calendars that keep the file inspection-ready.

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This article is general information as on 12 August 2026, based on Schedule 4 of the Licensing and Registration Regulations (as amended in 2026), licence conditions and the Food Safety Auditing Regulations, 2018. Category-specific conditions vary; confirm the current position for your category or take advice before acting.

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