- Shweta Verma
September 25, 2026
Food for Special Medical Purpose (FSMP) – Compliance Checklist
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Food for Special Medical Purpose (FSMP) – Compliance Checklist
|
S. No. |
Compliance Requirement |
Key Requirement / Action Point |
|
1 |
Permitted Product Category |
Ensure the product qualifies as Food for Special Medical Purpose (FSMP) and is specially prepared for particular dietary/medical requirements. |
|
2 |
Weight-Reduction Products |
FSMP may include food specially prepared for weight reduction intended as total replacement of the normal diet. |
|
3 |
Enteral Feeding |
FSMP may be formulated for oral feeding through enteral tubes. |
|
4 |
Parenteral Use Prohibited |
FSMP shall not be intended or used for parenteral administration. |
|
5 |
Nutritionally Complete Food |
May be nutritionally complete and, when used according to the manufacturer's instructions, may constitute the sole source of nourishment. |
|
6 |
Nutritionally Incomplete Food |
May be formulated for a specific disease, disorder or medical condition but shall not be suitable as the sole source of nourishment. |
|
7 |
Classification – Standard Formulation |
Nutritionally complete food with a standard nutrient formulation may constitute the sole source of nourishment when used as instructed. |
|
8 |
Classification – Disease-Specific Formulation |
Nutritionally complete food with a nutrient-adapted formulation specific to a disease, disorder or medical condition may constitute the sole source of nourishment when used as instructed. |
|
9 |
Classification – Incomplete Formulation |
Nutritionally incomplete food may have a standard or disease-specific nutrient-adapted formulation and shall not be used as the sole source of nourishment. |
|
10 |
Partial Replacement / Supplement |
Products falling under disease-specific complete or incomplete categories may be used as a partial replacement or supplement to the person's diet. |
|
11 |
Permitted Nutrients / Ingredients |
Use only ingredients/nutrients specified in Schedule I, II, III, IV, VII or VIII, and enzymes specified in Schedule VI, subject to applicable requirements. |
|
12 |
Modification of Nutrients |
Modifications to specified nutrients may be made where necessary for the intended use of the product. |
|
13 |
New Nutrient Approval |
For a nutrient having no history of use in India or lacking evidence of nutritional/physiological benefit, the FBO may apply to the Food Authority for approval, with scientific justification. |
|
14 |
Approved Nutrient List |
Use new nutrients only after they are approved/specifically permitted by the Food Authority following scientific evaluation. |
|
15 |
Very Low Energy Diet – Energy |
For FSMP intended as total diet replacement for weight reduction, the prepared product shall provide 450–800 kcal/day as the only source of energy. |
|
16 |
Very Low Energy Diet – Protein |
Recommended daily intake shall contain at least 50 g protein with a Protein Digestibility Corrected Amino Acid Score (PDCAAS) of 1. |
|
17 |
Essential Amino Acids |
Essential amino acids may be added only to the extent necessary to improve protein quality. |
|
18 |
Form of Amino Acids |
Only L-forms of essential amino acids shall be used, except methionine for which the DL-form is permitted. |
|
19 |
Linoleic Acid |
Very low energy diet shall provide at least 3 g linoleic acid/day. |
|
20 |
α-Linolenic Acid |
Very low energy diet shall provide at least 0.5 g α-linolenic acid/day. |
|
21 |
Fatty Acid Ratio |
Ratio of α-linoleic acid and linolenic acid shall be maintained between 1:5 and 1:15, as prescribed. |
|
22 |
Available Carbohydrates |
Very low energy diet shall provide at least 50 g available carbohydrates/day. |
|
23 |
Dietary Fibre |
FSMP formulated as a very low energy diet shall contain adequate dietary fibre. |
|
24 |
Vitamins & Minerals |
Nutrients may be added above the recommended daily allowance, but vitamin and mineral levels shall not exceed Schedule III limits. |
|
25 |
Product Name on Label |
The words “FOOD FOR SPECIAL MEDICAL PURPOSE” shall appear immediately proximate to the product's name/brand name. |
|
26 |
Medical Advice Warning |
Label shall prominently display “RECOMMENDED TO BE USED UNDER MEDICAL ADVICE ONLY” in bold letters and separately from other information. |
|
27 |
Disease / Condition Statement |
Label shall state “For the dietary management of ________”, specifying the relevant disease, disorder or medical condition. |
|
28 |
Scientific Substantiation |
Disease/condition-related statement must be supported by appropriate scientific, clinical or epidemiological data and is subject to Food Authority approval. |
|
29 |
Nutritionally Complete Declaration |
Where applicable, label shall state “NUTRITIONALLY COMPLETE”. |
|
30 |
Rationale for Use |
Label shall explain the rationale for use by the target consumer group and the relevant properties/characteristics of the product. |
|
31 |
Age Group |
Where formulated for a specific age group, the applicable age-group statement shall be provided. |
|
32 |
Modified Nutrients Declaration |
Specify nutrients that have been reduced, deleted, increased or otherwise modified compared with normal requirements, along with the rationale. |
|
33 |
RDA Information |
Where appropriate, express nutrient quantities as percentages of recommended daily allowances. |
|
34 |
Technical Information |
Provide information on osmolality/osmolarity, Renal Solute Load, Potential Renal Solute Load or acid-base balance, wherever applicable. |
|
35 |
Preparation & Feeding Instructions |
Provide appropriate instructions for preparation, feeding and use of the product. |
|
36 |
Storage Instructions |
Provide instructions regarding storage after opening the container. |
|
37 |
Parenteral Warning |
Label shall carry a warning that the product is not for parenteral use. |
|
38 |
Child Safety Statement |
Label shall state that the product is required to be stored out of reach of children. |
|
39 |
Permitted Additives |
Use only additives permitted under Schedule VC, VD, VE or VF. |
|
40 |
Advertising Restriction |
FSMP shall not be advertised for use by the general public. |
Author Bio
Shweta Verma
CS Trainee View Full Profile


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