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Exporting food supplements from India

Food supplements containing botanicals leave India for the EU and the UK only with an official certificate from the Export Inspection Council or its agencies. Other supplements are exported under the general rules: an IEC, the shipping bill and a certificate of origin. DGFT issues free sale and commerce certificates that buyers abroad often ask for.

Updated · Each section links to the official source it comes from

Botanicals to the EU and UK
Official certificate from EIC or an Export Inspection Agency
Free sale certificate
DGFT regional authority, valid two years
Export promotion council
Pharmexcil lists nutraceuticals
Herbal raw materials
In APEDA's schedule
FSSAI return
Form D-1 by 31 May, including exports

Before the goods leave

The questions to answer, in the order they usually come up.

  1. 1Does the supplement contain botanicals, and is it going to the EU or the UK? Read more
  2. 2Does the buyer want a free sale certificate, and from whom? Read more
  3. 3Which council or board issues the exporter's RCMC? Read more
  4. 4Does the manufacturer's FSSAI licence and annual return cover the exports? Read more
  5. 5Is the IEC current, and which documents go with the shipment? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

Botanical supplements to the EU and UK

A condition in India's export policy for food supplements that contain botanicals.

  • Food supplements containing botanicals, exported to the European Union or the United Kingdom and intended for human or animal consumption, are allowed subject to an official certificate from the Export Inspection Council (EIC) or the Export Inspection Agencies (EIAs).
  • EIC and the EIAs are the designated competent authority for that certificate.
  • The certificate is issued on a satisfactory analytical test report from EIC or an EIC-recognised laboratory, as the EU's requirements lay down.
  • The condition appears in the export policy for Chapter 13 (vegetable saps and extracts) and Chapter 21 (miscellaneous edible preparations) of ITC(HS) 2022.

How we help: Compliant Always keeps the EIC certificate and the test report behind it with the lot, and reads them against what the EU or UK importer asks for. Ask about this

Free sale and commerce certificates

A certificate that the product is freely sold in India, which DGFT issues on application.

  • DGFT's regional authorities issue a Free Sale and Commerce Certificate for export of any item not restricted or prohibited for export, valid for two years from issue (HBP para 2.34(b)).
  • Items covered by the Drugs and Cosmetics Act, 1940 apply to the Central Drugs Standard Control Organisation (CDSCO) instead.
  • Applications use form ANF 2H with its Annexure A; the certificate is issued in the format of Annexure B.
  • DGFT describes the certificate as confirming that the product is freely sold in India, without any indication that it has been evaluated for safety and efficacy.

How we help: Compliant Always keeps the free sale certificate with the products it lists, and shows when the two years run out. Ask about this

RCMC and APEDA registration

Which council registers the exporter, and when the RCMC is needed.

  • An RCMC is needed to apply for an authorisation or any other benefit under the Foreign Trade Policy (FTP para 2.57).
  • The exporter takes the RCMC from the council for its main line of business. DGFT's list of councils gives the Pharmaceuticals Export Promotion Council (Pharmexcil) for herbal, ayurvedic and unani products and nutraceuticals.
  • Herbal and medicinal plants are in the First Schedule to the APEDA Act; their exporters register with APEDA within one month of the first export (section 12).

How we help: Compliant Always keeps the RCMC or APEDA registration with the exporter's record, dated, and shows when it falls due. Ask about this

FSSAI licence and annual return

The food licence held by the business that makes or handles the supplements.

  • 100% Export Oriented Units are licensed by FSSAI's Central Licensing Authority.
  • Every licensee files an annual return in Form D-1 by 31 May, stating the quantities manufactured, handled, imported and exported; late returns attract Rs 100 a day.

How we help: Compliant Always keeps the FSSAI licence with the products it covers, and shows a licence that lapses before the next shipment. Ask about this

IEC, origin and shipping documents

The general rules every export from India meets.

  • No export or import of goods is made without an Importer-Exporter Code (IEC) unless specifically exempted (FTP 2023, para 2.05).
  • The IEC is a 10-character code, the same as the firm's PAN, issued separately by DGFT on an online application.
  • The IEC holder updates its details online every year between April and June; an IEC not updated is de-activated.
  • Mandatory export documents are the bill of lading, airway bill or other transport receipt; the commercial invoice cum packing list; and the shipping bill or bill of export (FTP 2023, para 2.06).
  • The shipping bill is an electronic declaration in the Indian Customs EDI System, entered by the exporter or an authorised customs broker through ICEGATE or a service centre.
  • Where goods carry restrictions or need an NOC under another law, the regulator may notify additional export documents.
  • Certificates of origin for exports from India are issued only by agencies DGFT has authorised, and only through trade.gov.in (FTP para 2.62; HBP para 2.90).

How we help: Compliant Always keeps the shipping bill, invoice and certificate of origin of each shipment together, so an importer's question can be answered from the record. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ExporterThe IEC, the RCMC, the free sale certificate application and the shipping bill.Certificates kept dated, with what lapses shown before shipment.
ManufacturerThe FSSAI licence and annual return, and the product information behind a test report.Specifications and test reports kept with each lot.
Export Inspection Council or AgencyThe official certificate for botanical supplements to the EU and UK.The certificate read against what the importer asks for.
DGFT regional authorityThe Free Sale and Commerce Certificate.The certificate kept with the products it lists.

Where are the goods going?

Most of what food supplements have to meet is set where they are sold. Each guide sets out the rules on arrival, with the official source for each.

Questions businesses ask

Do food supplements need a certificate to be exported from India to the EU?
Supplements containing botanicals do. Export to the EU is allowed subject to an official certificate from the Export Inspection Council or an Export Inspection Agency, issued on a satisfactory test report from an EIC or EIC-recognised laboratory.
Does the same apply to supplements exported to the UK?
Yes. India's export policy names both the European Union and the United Kingdom for the official certificate on food supplements containing botanicals.
Who issues a free sale certificate for supplements in India?
DGFT's regional authorities issue a Free Sale and Commerce Certificate for any item not restricted or prohibited for export. For items under the Drugs and Cosmetics Act, 1940, the application goes to CDSCO (HBP para 2.34).
How long is a DGFT free sale certificate valid?
Two years from the date of issue, unless otherwise specified.
Does a free sale certificate mean India has assessed the product's safety?
No. DGFT describes it as confirming that the product is freely sold in India, without any indication that it has been evaluated for safety and efficacy or registered for use.
Which export promotion council covers nutraceuticals?
DGFT's list of councils gives the Pharmaceuticals Export Promotion Council (Pharmexcil) for nutraceuticals and for herbal, ayurvedic and unani products.
Do I need an RCMC to export supplements?
An RCMC is required to apply for an authorisation or another benefit under the Foreign Trade Policy. It is valid for five years from 1 April of the year it is issued.
Do herbal ingredients need APEDA registration?
Herbal and medicinal plants are in the First Schedule to the APEDA Act, so their exporters apply to APEDA for registration within one month of the first export.
Do supplement makers report exports to FSSAI?
Every FSSAI licensee files an annual return in Form D-1 by 31 May, which includes the quantities exported. A late return attracts a penalty of Rs 100 a day.
How does Compliant Always help with exporting from India?
Our team reads the rules for the routes you ship. Compliant Always shows which export documents apply to your product, keeps them with the shipment beside what the destination asks for, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

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