Which Regulation Applies

Finished omega-3 supplements sit under the FSSAI regulations governing health supplements, nutraceuticals, foods for special dietary use and related categories, which were consolidated in a 2022 revision of the earlier 2016 regulations. Those regulations define what a health supplement and a nutraceutical are, set the framework for permitted ingredients and their levels, and lay down labelling rules specific to the category. Fish oil as a raw material also falls under the general product standards and the contaminant, toxin and residue limits in the food product standards regulations. A marketer must read both sets: the category rules for the finished product and the commodity and contaminant rules for the oil.

Licensing

Anyone manufacturing, importing, distributing or selling omega-3 supplements in India needs an FSSAI licence or registration appropriate to their scale and activity, and manufacturers of nutraceuticals are licensed under the category that covers health supplements and nutraceuticals rather than under a general food category. The 14-digit licence number must appear on the label with the FSSAI logo. Importers additionally clear each consignment through the FSSAI import process at the port, where sampling and testing against the applicable standards can occur.

What to Specify in the Oil

ParameterWhy it mattersTypical specification line
EPA and DHA contentThe label claim is built on it; concentrates (30/20, 40/20, 60/30 and higher) are graded on itEPA and DHA as mg/g or % by GC, as triglyceride or ethyl ester form stated
Oxidation: peroxide value, anisidine value, TOTOXRancid oil fails organoleptically and is the main quality complaintPV NMT 5 meq/kg, AV NMT 20, TOTOX NMT 26 are the widely used industry ceilings
Acid value and free fatty acidsRefining qualityStated per grade
Heavy metalsMercury, lead, cadmium, arsenic limits under the contaminant regulationsBy ICP-MS, reported as numbers
Dioxins, PCBs and other organic contaminantsRequired by most buyers and by several destination marketsReported on a reference lot at minimum
AntioxidantMixed tocopherols or rosemary extract are usual; must be declaredNamed with level
Species and originSustainability and allergen declarations depend on itAnchovy, sardine, mackerel; fishing area

Internationally, the GOED voluntary monograph is the reference most buyers use for oxidation and contaminant limits, and pharmacopoeial monographs (USP, European Pharmacopoeia) set the standards for pharmaceutical-grade concentrates. An Indian marketer specifying to those limits will meet the domestic contaminant rules comfortably.

Labelling and Claims

The Exporter’s Angle

Bulk fish oil exported from India for manufacture abroad is not labelled for the Indian consumer, but the exporter still needs an FSSAI licence covering export, a batch COA against the buyer’s specification, and a health certificate where the destination asks for one. The destination’s rules govern the finished product: the EU sets contaminant limits and novel-food status for some oil forms, and the US treats fish oil supplements under its dietary supplement framework with its own labelling. SV Botanica supplies omega-3 fish oil as a bulk ingredient against specification, with EPA/DHA by GC and the oxidation and contaminant panel on the COA; see the omega-3 fish oil product page.

This guide describes the regulatory framework as understood at the date of publication; the regulations and their schedules are amended periodically and the FSSAI website is the authoritative source.