Last reviewed: 25 September 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. It matters twice over now: under FSSAI's risk-based approach to inspection, your hygiene and audit record influences 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.
Which part of Schedule 4 applies to you
| Part | Applies to | Character |
|---|---|---|
| Part I | Basic Registration FBOs (up to ₹1.5 crore turnover) | General hygiene and sanitary practices — proportionate but real |
| Part II | State/Central licensees — manufacturing, processing, packing, storage, distribution | The full GMP/GHP framework: premises, layout, water, equipment, personnel, records |
| Part III | Milk and milk products units | Sector-specific additions |
| Part IV | Slaughter houses and meat processing | Sector-specific additions |
| Part V | Catering 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. The threshold was raised by the Food Safety and Standards (Licensing and Registration of Food Businesses) Amendment Regulations, 2026, notified on 10 March 2026 and applicable from 1 April 2026 under FSSAI's implementation order of 13 March 2026. 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. FSSAI's risk-based approach to inspection completes the loop: a satisfactory third-party audit is an input that can reduce routine inspection frequency. 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.
What non-compliance can cost
| Provision (FSS Act, 2006) | Default | Maximum penalty |
|---|---|---|
| Section 32 | Improvement notice not complied with | Licence can be suspended and, after a hearing, cancelled |
| Section 55 | Failure to comply with the Food Safety Officer's directions, including an improvement notice | Up to ₹2 lakh |
| Section 56 | Manufacturing or processing food under unhygienic or unsanitary conditions | Up to ₹1 lakh |
Food importers and foreign brands
Importers of food need a Central licence whatever their turnover, and each consignment passes FSSAI import clearance before it reaches the Schedule 4 premises. Foreign F&B brands setting up an Indian entity usually face the licence, import clearance and the entity's own accounting and FEMA reporting at the same time; we support that set-up through our foreign subsidiary accounting and FEMA compliance 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: under FSSAI's risk-based approach to inspection, satisfactory audits can reduce routine inspection frequency.
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.
We run a Schedule 4 gap review — documents, testing, training, display — and set up the registers and calendars that keep the file inspection-ready.
FSSAI Registration & Compliance FSSAI Annual Return (Form D-1) Talk to usThis article is general information as on 25 September 2026, based on Schedule 4 of the Licensing and Registration Regulations (as amended in 2026), licence conditions, the Food Safety and Standards Act, 2006 and the Food Safety Auditing Regulations, 2018. Category-specific conditions vary; confirm the current position for your category or take advice before acting.