- Shweta Verma
September 26, 2026
Sampling of Imported Food – Compliance Checklist
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Sampling of Imported Food – Compliance Checklist
|
Sr. No. |
Compliance Requirement |
Responsibility |
Timeline / Condition |
|
1 |
Ensure compliance with applicable Labelling and Packaging Regulations, 2011 and verify that the imported food has a valid shelf life. |
Authorised Officer / Representative |
At sampling |
|
2 |
Draw two parts of the food sample for each description/measure, except aseptic sealed packages. |
Authorised Officer / Representative |
At sampling |
|
3 |
Forward the prescribed quantity of sample to the Food Analyst as specified under the Laboratory and Sample Analysis Regulations, 2011. |
Authorised Officer |
After collection |
|
4 |
Seal the collected samples appropriately. |
Authorised Officer |
At sampling |
|
5 |
For aseptic/hygroscopic sealed bulk containers, obtain two representative sealed samples from the same batch along with the manufacturer's declaration confirming that they correspond to the bulk container. |
Food Importer / Manufacturer |
At import clearance |
|
6 |
If representative sealed samples and manufacturer's undertaking are not provided, the Authorised Officer may break open the seal and collect a sample for laboratory analysis. |
Authorised Officer |
Where required |
|
7 |
Where the representative sealed samples appear doubtful, the Authorised Officer may collect a sample directly from the sealed container. |
Authorised Officer |
Where required |
|
8 |
For food having shelf life of less than 7 days, declare the shelf life in Form-13 and permit sampling/provisional NOC procedure. |
Importer / Applicant |
At import clearance |
|
9 |
For <7-day shelf-life products, the Authorised Officer may issue a provisional NOC to Customs without waiting for the laboratory report; final NOC is communicated after receipt of the analysis report if the product conforms. |
Authorised Officer |
As applicable |
|
10 |
In case of non-conforming sample, immediately inform the Importer/Custom Broker to initiate recall and submit the required compliance report under the Food Recall Procedure Regulations, 2017. |
Authorised Officer / Importer / Custom Broker |
Immediately upon non-conformance |
|
11 |
Maintain vigilance at all import points regarding products manufactured by the same company or similar products imported by the same importer/Custom Broker. |
Food Authority |
Following non-conformance |
|
12 |
Label each sealed sample with the sample code number, date/place of collection, quantity, food name/category, preservative details (if any), signatures of importer/CHA and sender with official seal. |
Authorised Officer |
At sampling |
|
13 |
Forward one sealed and labelled sample to the Food Analyst/notified laboratory for analysis. |
Authorised Officer |
After sampling |
|
14 |
Store the remaining sample parts under appropriate conditions. |
Authorised Officer / Representative |
Until disposal/return |
|
15 |
If the sample is found safe/conforming, return the remaining sample to the Food Importer. |
Authorised Officer |
After satisfactory analysis |
|
16 |
If the sample is found unsafe/non-conforming, the Importer may request that the second sample be sent to the Referral Laboratory for analysis. |
Importer / Authorised Officer |
On request |
|
17 |
Returned rejected export consignments entering India as the country of origin are subject to these regulations; packaging/labelling may follow the country of export, and rejection documents must be submitted. |
Importer |
At re-import |
|
18 |
The Food Analyst/notified laboratory must analyse the sample against the parameters prescribed under the Act and applicable regulations. |
Food Analyst / Laboratory |
As applicable |
|
19 |
The Food Analyst must forward the signed analysis report within 5 days to the Authorised Officer, stating whether the product is conforming or non-conforming. |
Food Analyst |
Within 5 days |
|
20 |
Proprietary foods must be tested, wherever applicable, against prescribed general safety requirements for contaminants, toxins, residues and microorganisms, depending on the nature of the product. |
Food Analyst / Laboratory |
During analysis |
|
21 |
Submit the Certificate of Analysis (COA) provided by the importer along with the sample. |
Importer / Authorised Officer |
With sample |
|
22 |
The COA should be referred while conducting the requisite quality-parameter tests. |
Food Analyst / Laboratory |
During analysis |
|
23 |
If the laboratory cannot complete testing within the prescribed period, the Food Analyst must provide written reasons to the Authorised Officer. |
Food Analyst / Laboratory |
Where applicable |
|
24 |
The final analysis report must be duly signed by the Food Analyst and forwarded to the Authorised Officer. |
Food Analyst |
After analysis |
Author Bio
Shweta Verma
CS Trainee View Full Profile


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