Discussion between CA Shivprasad Sakhare and Clients on FSSAI Annual Returns

Clients:

Good morning, Mr. Sakhare. We're here to understand more about the FSSAI annual returns and the upcoming deadlines. Could you guide us through the requirements and due dates?

CA Shivprasad Sakhare:

Good morning, everyone. Absolutely, I'll explain everything you need to know about the FSSAI annual returns. Let's start with the basics. The Food Safety and Standards Authority of India (FSSAI) mandates that Food Business Operators (FBOs) must file annual and half-yearly returns. This ensures compliance with the Food Safety and Standards (FSS) Act, 2006.

Client 1:

Who exactly needs to file these returns?

CA Shivprasad Sakhare:

Every FBO with a business turnover of more than Rs. 12 lakhs must file these returns. This includes entities involved in importing, selling, manufacturing, exporting, storing, distributing, handling, or transporting any type of food product. Specifically, those involved in the manufacturing and distribution of milk have additional requirements.

Client 2:

Are there any exemptions?

CA Shivprasad Sakhare:

Yes, certain entities are exempted from filing the FSSAI annual return. These include fast-food joints, restaurants, grocery stores, and canteens.

Client 3:

What types of returns are we required to file?

CA Shivprasad Sakhare:

There are two main types of returns:

1. FSSAI Form D1 (Annual Return): This must be filed by all food importers, manufacturers, packers, labellers, re-labellers, and re-packers. The due date for filing Form D1 is on or before 31 May of every financial year.

2. FSSAI Form D2 (Half-Yearly Return): This is specifically for FBOs involved in the business of manufacturing or importing milk or milk products. Form D2 needs to be filed for two periods: from 1 April to 30 September (due by 31 October) and from 1 October to 31 March (due by 30 April).

Client 4:

What information needs to be included in these returns?

CA Shivprasad Sakhare:

For Form D1, you need to include:

- FBO name and address

- FSSAI license number

- Statement showing quantities of food products handled, manufactured, exported, and imported in tonnes, with specific details about the products, packaging, and values.

For Form D2, details required include:

- FBO name and address

- FSSAI license number

- Details of milk procurement, purchase, reconstitution, sales, and stock positions, including specifics on the types and quantities of milk and milk products.

Client 5:

How do we file these returns?

CA Shivprasad Sakhare:

You can file these returns either online or offline. For online submission, log into the FoSCoS portal, fill out the respective form, and submit it. The online submission has been effective since the financial year 2020-21. For offline filing, you need to download the relevant form from the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011, fill it out, and send it via registered post or email to the concerned food licensing authority.

Client 6:

What happens if we miss the filing deadline?

CA Shivprasad Sakhare:

If you do not file the returns within the prescribed due date, a fine of Rs. 100 will be imposed for each day the default continues, starting from the next day after the due date.

Client 7:

That sounds serious. Can you summarize the immediate steps we should take?

CA Shivprasad Sakhare:

Certainly. First, ensure all your business details and FSSAI license information are up to date. Then, gather all the necessary data for the forms. If you haven't already, register on the FoSCoS portal for online filing. Make sure to file Form D1 by 31 May 2024 to avoid penalties. If you deal with milk or milk products, keep in mind the deadlines for Form D2 as well.

Client 1:

Thank you, Mr. Sakhare. This has been very helpful. We'll get started on this right away.

CA Shivprasad Sakhare:

You're welcome. Feel free to reach out if you have any more questions or need further assistance.