FSSAI Registration vs State vs Central Licence: A Rice Miller's View

What each tier actually involves

Registration is designed to be light: basic applicant and business details, no mandatory pre-registration inspection for most categories, and a fast turnaround. It suits home-based food businesses, small eateries, tiffin services and small packaged-food resellers.

State Licence applies to mid-sized food businesses. It involves a more detailed application, including plans for food safety management, and is issued by the state-level FSSAI licensing authority rather than through the lighter registration process.

Central Licence applies to the largest food businesses by turnover, and separately to categories the regulation treats as needing central oversight whatever their size. Importers and exporters of food, for instance, need a Central Licence even if their turnover would otherwise place them in the Registration or State tier, because cross-border food safety oversight is handled centrally.

Perpetual validity, the other big 2026 change

Alongside the turnover reform, FSSAI registrations and licences issued under the current framework carry perpetual validity. They do not expire and do not need periodic renewal filing, a significant change from the earlier system of fixed-term licences that had to be renewed again and again. That removes one recurring task. It does not remove the obligation to hold the correct tier for your current turnover, or your ongoing food-safety and labelling responsibilities.

The check I'd run once a year

Perpetual validity took away the one date that used to force the question. Under the old system, a renewal made you look at your tier every few years whether you wanted to or not. Now nothing prompts you, so the prompt has to come from your own calendar.

In a business like ours, the natural moment is when the CA finalises the annual accounts, because that is when the year's turnover stops being an estimate. I would check the tier every year once the annual accounts are finalised: take the turnover, hold it against the bands above, and decide before the new year's trading starts rather than after an inspector does the sum for you.

A seasonal business needs the check more than most. A mill's turnover moves with the crop and with prices, and one strong season can carry a business that sat comfortably under ₹1.5 crore past it. And if your business sells things that are not food alongside things that are, as a mill with an input counter does, do not guess how the turnover is counted for the tier: read the FoSCoS eligibility criteria for your kind of business, and ask your CA if it is still unclear.

What to do if your turnover has changed

Because the tier is turnover-based and turnover changes from year to year, this is not a one-time decision:

• If your turnover grows past your current tier's ceiling, upgrade (Registration to State Licence, or State to Central Licence) before continuing to operate at the higher volume, not after.
• If you registered before April 2026 under the old, lower bands and your turnover has stayed under ₹1.5 crore, you may now hold more than is currently required. FSSAI has said existing food businesses will be given time to migrate to the revised bands on FoSCoS, with no migration fee and no change in licence number.
• If you import or export food, you need a Central Licence regardless of turnover. This exception to the turnover tiers is easy to miss if you are watching only the revenue bands.

Four ways businesses land in the wrong tier

• Relying on outdated turnover figures. The March 2026 reform is recent enough that a lot of existing content, including some professional advisory material, still cites the old ₹12 lakh registration ceiling.
• Assuming a very small food business is exempt. There is no exemption by size, only a lighter tier; even a home baker selling occasionally needs at least basic Registration.
• Not tracking turnover against the tier ceiling. Perpetual validity removed the renewal reminder that used to prompt a review, so tier upgrades are now easier to miss.
• Overlooking the Central Licence requirement for import or export. It applies regardless of turnover and is a separate trigger from the revenue bands.

Your tier check

• Work out your current annual food-business turnover and match it against the bands: up to ₹1.5 crore (Registration), ₹1.5 crore-₹50 crore (State Licence), above ₹50 crore (Central Licence).
• If you import or export food, confirm you hold a Central Licence regardless of your turnover figure.
• If you registered before April 2026, check whether your current tier still matches your current turnover under the revised bands.
• Apply or upgrade through foscos.fssai.gov.in, the official FoSCoS portal, and avoid third-party sites that claim to speed the process up for a fee.
• Put the yearly tier check in your compliance calendar, next to the date your accounts are finalised.

FSSAI is one line of a longer list for any food processor; the manufacturing checklist shows the rest, and the registrations map shows who issues what. The tier itself takes five minutes to check. The mistake is not checking it.