By Navneet, Chief Regulatory Expert at Regbite
FSSAI has signalled that it intends to tighten the rules around protein supplements — particularly those making unauthorised medical or health claims, and those whose declared nutritional information does not survive testing. The trigger was a study finding that a meaningful share of products on store shelves, in gyms and on e-commerce platforms carried questionable claims or inaccurate nutrition data.
An important caveat before you act on anything below: at the time of writing this is a stated regulatory intent, not a notified regulation. There is no gazette notification you can read, no clause number to cite and no compliance deadline. Anyone telling you otherwise is selling you something.
But I have watched enough of these cycles to tell you what the notified version usually looks like — and every item below is already required or already defensible under the existing framework. So you lose nothing by fixing them now, and you gain a head start measured in months.
1. Your declared protein has to survive a lab test
The single most common finding in protein testing studies is that declared protein exceeds measured protein. Sometimes that is sloppy formulation. Sometimes it is nitrogen spiking — adding cheap non-protein nitrogen sources so a Kjeldahl test reads higher than the true protein content.
Kjeldahl measures nitrogen and infers protein. It cannot distinguish protein nitrogen from free amino acid or other added nitrogen. If your supplier's certificate of analysis uses Kjeldahl alone, you do not actually know your protein content — you know your nitrogen content.
What to do: get batch-level testing from an NABL-accredited laboratory, and ask specifically whether the method distinguishes true protein. If your contract manufacturer resists that question, you have learned something important about your supply chain.
2. Every claim needs a dossier that exists today, not one you could assemble
Under the 2022 nutraceutical framework, structure–function claims require substantiation you can produce on request. In practice, most brands I audit can describe their substantiation but cannot hand it over. During a show-cause response window, those are the same thing.
What to do: for each on-pack claim, keep one file containing the claim as worded, the evidence relied on, and who approved it. If the claim strays anywhere near treating, preventing or curing a condition, it is a drug claim and it does not belong on a food label at all — that is the boundary that turns a labelling problem into a Drugs and Cosmetics Act problem.
3. The amino acid profile is not optional decoration
If you are declaring a profile, it has to match the product. If you are declaring protein quality — PDCAAS or DIAAS — the figure needs to correspond to the blend you actually shipped, not the blend you formulated on paper before your supplier substituted a cheaper input.
What to do: reconcile your declared profile against incoming raw material CoAs every time a supplier or grade changes. Most divergence I find is not fraud. It is a formulation change that never made it back to the artwork.
4. Your marketplace listing is a label
I will keep repeating this because brands keep being surprised by it. The claims in your Amazon title, your Flipkart bullet points and your own product page are treated as label claims. A clean physical label and a non-compliant listing is still a non-compliant product.
What to do: audit listings on the same cycle as artwork. In my experience the listing is usually worse, because it is edited by whoever runs performance marketing and never goes past regulatory.
Why acting before the notification is the cheap option
When a regulation is notified, you get a transition window — typically three to six months. That window has to absorb reformulation, retesting, artwork revision, printing, existing stock and every marketplace listing you own. Brands that begin in the window rarely finish inside it.
Brands that fixed the underlying accuracy problems beforehand spend the transition window updating artwork, which is the only part that genuinely requires the final notified text.
This is the reasoning behind how we built Regbite's checks: the engine tests your label against the 64 rules in force today across FSSAI, Legal Metrology and AYUSH, and every finding cites the specific rule code it came from so you can verify it rather than take our word for it. When the protein rules are notified, they become new rules in the same engine and your portfolio is re-scored against them automatically — you do not start from a blank page.
The brands that will struggle are the ones whose declared numbers were never quite right. That is not a labelling problem you can fix with artwork.
This article discusses regulatory intent reported in 2026. No protein-specific regulation had been notified at the time of writing. This is general guidance, not legal advice.