There is no FSSAI order asking states to follow a "Maharashtra model". What FSSAI has issued is a festive-season enforcement letter that puts beverages on the focus list, and that is what matters for a packaged drinking water (PDW) plant.
What FSSAI ordered, and when
In a letter dated 29 September 2026, FSSAI asked the Commissioners of Food Safety of all states and union territories, and its own regional directors, to increase surveillance and enforcement during Navratri and Diwali. FSSAI made the letter public on 5 October 2026. It was marked "most important".
The letter directs Designated Officers, Food Safety Officers and Central Food Safety Officers to carry out inspections and take samples. The listed focus products are milk and milk products (including ghee, khoa and paneer), sweets, snacks and savouries (namkeen, papad, fryums), edible oil, beverages and ghee. FSSAI added that the list may vary by region.
Two operational points stand out:
- Enforcement is to focus on "identified hotspots and sensitive locations". Where available, Food Safety on Wheels vans are to be deployed at prominent marketplaces or on specific intelligence.
- All inspection, sampling and outcome data must be entered in real time on FoSCoS and FoSCoRIS.
The letter does not mention packaged water by name. But "beverages" is a wide term, and officers decide on the ground what to sample.
The Maharashtra angle: a court case, not a model
Maharashtra FDA has, on its own, asked food service businesses in the state (hotels, restaurants, caterers, sweet shops, cloud kitchens and similar outlets) to back their licence with test reports and records. Testing labs that have summarised the order say it includes water testing every six months at a NABL-accredited or FSSAI-notified lab. It applies to food service outlets in Maharashtra, not to manufacturers nationally.
Separately, on 23 October 2026 it was reported that the Maharashtra government has moved the Bombay High Court against FSSAI. Among other things, it challenges a 2023 FSSAI directive (reported as dated 12 May 2023) that stops state food safety officers from inspecting centrally licensed establishments. The matter is listed on 26 November 2026 before a bench of Chief Justice MC Tripathi and Justice Advait Sethna.
Quick reference
| Item | Date | Who it covers | Status |
|---|---|---|---|
| FSSAI festive enforcement letter | 29 Sep 2026 (made public 5 Oct) | All states/UTs; beverages among focus products | In force for Navratri-Diwali season |
| FSSAI Scheme of Testing for PDW | Order 17 Dec 2025; from 1 Jan 2026 | All PDW and mineral water units | In force |
| Maharashtra FDA records and testing order | 2026 (as summarised by labs) | Food service outlets in Maharashtra | State only |
| Maharashtra v. FSSAI petition, Bombay HC | Reported 23 Oct 2026; hearing 26 Nov 2026 | Inspection powers over central licensees | Pending |
Where a water plant may meet an inspector this season
The letter only says "hotspots and sensitive locations". In our experience, these are the places a PDW product is most likely to be checked:
- Retail and market counters in busy bazaars, where Food Safety on Wheels vans are sent. A bottle sampled from a shop is traced back to you through the FSSAI number and batch on the label.
- Distributor and stockist godowns.
- Bulk supply to events: 20-litre jars, pouches and cups supplied to pandals, melas, weddings and caterers.
- Hotels, sweet shops and restaurants that buy your jars. In Maharashtra they now need water test records and may ask you for reports.
- Your plant itself. State-licensed and registered units are inspected by state Food Safety Officers. Central licensees (turnover above Rs 50 crore) are currently inspected by Central Food Safety Officers under the 2023 directive, which is now under challenge.
What this means for water plant owners
Keep one inspection file ready at the plant, and a copy with your manager:
- Correct licence for manufacturing packaged drinking water, displayed at the premises, with the same number printed on labels. See our FSSAI licence guide.
- Scheme of Testing records: monthly microbiological test reports, source-water reports from an FSSAI-notified NABL lab, and records kept for five years.
- Batch records linking each batch to production date, test results and the distributors it went to, so you can respond quickly if a sample fails.
- Expired and rejected stock out of the way: remove expired finished goods and expired or rejected raw materials (preforms, caps, labels, treatment chemicals) from production and dispatch areas. Keep them in a separate, clearly marked "Not for use / Not for sale" area, with a register showing quantity, date and how they were disposed of.
- Hygiene on the floor: clean filling room with restricted entry, hair nets, gloves and clean uniforms for filling staff, hand-wash points working, no leaks or standing water, sealed drains, and windows and vents screened against insects. Back these up with jar washing and sanitising logs, tank cleaning records and pest control service reports.
- Medical and training records: medical fitness certificates for every food handler, renewed each year as required under Schedule 4 of the FSSAI licensing regulations, and a list of the staff authorised to handle water in the filling area. Keep the FoSTaC certificate of your trained Food Safety Supervisor on display or on file. FSSAI says Central and State licence holders should have at least one trained and certified Food Safety Supervisor for every 25 food handlers or part of that number, at each premises.
- High-risk category duties: PDW is a high-risk food category, so central licensees need their annual third-party audit on file. See our high-risk category explainer.
- If a sample is taken, note the batch number and date and keep your copy of the sampling papers. Under the Food Safety and Standards Act, an operator can appeal an adverse food analyst report within 30 days.
Plants in Uttar Pradesh should also note the state FSDA order of 14 October 2026 that makes BIS certification compulsory for PDW units there. Nationally, BIS remains voluntary. Keep your CGWA NOC and pollution board consent in the same file.
How ClearPath Compliance India can help
We review a plant's licences, test records and labels against current FSSAI requirements, set up an inspection-ready file, and help respond to notices or sample results. See our packaged drinking water plant licence service, or call us before the Diwali rush.
Sources
- Business Standard, 5 Oct 2026
- Kashmir Life, 6 Oct 2026
- The News Mill, 5 Oct 2026
- Free Press Journal, 23 Oct 2026
- Envirocare Labs summary of Maharashtra FDA order
Read this in Hindi: हिंदी में पढ़ें. General information only, not legal advice. Orders and court dates as reported on the dates stated; check the latest FSSAI and state notifications before acting. Not sponsored or endorsed by any organisation named.