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Wrong FSSAI Licence, Sealed Plant: Why a Trading Licence Does Not Cover Packaged Drinking Water

Water units in Pulwama and Nayagaon Mandwa Basti were sealed in 2026 because their FSSAI licences covered trade or distribution, not water packing. Here is how to check that your licence matches your plant.

Empty clear plastic water bottles with blue caps, without labels
Photo: engin akyurt / Unsplash

On 27 September 2026, the Jammu and Kashmir Food and Drug Administration sealed a packaged drinking water unit at the Industrial Growth Centre, Lassipora, in Pulwama district. The reason was not dirty water or a failed test. It was the licence. Officials said the FSSAI licence number printed on the bottles had been issued for wholesale and retail trade in fruits and vegetables. It did not cover making or packing drinking water.

It is not the only case this year. On 24 July 2026, a joint team of Revenue, Food Safety and Police officials sealed two water packaging plants at Nayagaon Mandwa Basti. As reported by The Hitavada, the two units held only distribution licences, not a licence to operate a water filtration and packing unit.

Both cases point to the same gap: having "an FSSAI licence" is not the same as having the right one.

What officials did in Pulwama

According to reports published on 27 September 2026 by Kashmir Despatch and Dynamite News, the inspection followed a complaint. The food safety team:

  • took two samples of packaged drinking water for analysis;
  • sealed the premises and suspended operations;
  • served a show cause notice on the person in charge, with three days to reply; and
  • started proceedings before the competent court under the Food Safety and Standards Act, 2006.

Officials cited Section 31 of the Act, which says no one may start or carry on a food business without a licence or registration, and Section 63, which deals with doing business without a licence. After the Jan Vishwas (Amendment of Provisions) Act, 2023, Section 63 provides a penalty of up to Rs 10 lakh. The reports did not carry a response from the unit, and no lab results had been published.

A licence covers specific activities, products and premises

An FSSAI licence is not a general permit. The licence certificate on FoSCoS, FSSAI's online licensing system, lists the kind of business (for example manufacturing, trade or distribution), the food products covered, and the premises address. A trading licence lets you buy and sell food. It does not let you treat, fill or pack water.

For packaged drinking water and mineral water, the bar is higher. Since FSSAI's order of 29 November 2024, both are in the "High-Risk Food Categories". A new manufacturing licence needs a pre-licence inspection, every unit faces a risk-based inspection each year, and Central licensees need an annual third-party audit. A plant running on the wrong licence has skipped all of that, which is why officials treat it seriously.

Licence on paper versus activity on the floor

What you actually doWhat your FSSAI licence must showReported case
Treat, fill and seal bottles or 20-litre jarsManufacturing licence with packaged drinking water as a product, at the plant address (State or Central based on turnover)Pulwama, 27 Sep 2026: licence on bottles was for fruit and vegetable trade
Only buy and resell sealed water made by someone elseTrade, distribution or retail licence/registration is enoughNayagaon Mandwa Basti, 24 Jul 2026: units with only distribution licences found operating packing plants
Sell under your own brand, made by a contract packerBrand owner's licence; the packer's own manufacturing licence; both numbers on the label when they differFSS (Labelling and Display) Regulations, 2020
Add mineral water, a new line or new premisesModified licence, or a separate licence for a new address, before production startsGeneral licensing practice

What this means for water plant owners

Take ten minutes this week and check your licence against your plant:

  • Kind of business. Download the licence copy from FoSCoS. It should show manufacturing, not only trade or distribution.
  • Products. Packaged drinking water must be listed. If you also make mineral water, that must be listed too.
  • Address. The premises address must be the plant where bottling happens, not your office or godown.
  • Label. The number on your bottles and jars should be the licence that covers this activity. Under the Labelling and Display Regulations, 2020, the brand owner's licence number goes on the label, and the manufacturer's or packer's number too when they are different.
  • Turnover. From 1 April 2026, a State licence covers turnover from Rs 1.5 crore to Rs 50 crore; above Rs 50 crore you need a Central licence. If you have crossed a limit, apply to upgrade.
  • State rules. In Uttar Pradesh, the FSDA order of 14 October 2026 requires BIS certification before a new unit gets its licence, and by 31 March 2027 for existing units. Nationally, BIS remains voluntary.

If anything does not match, apply for modification or a fresh licence before you continue production. Fixing the paperwork after a sealing order is slower and costlier than fixing it now. See our packaged drinking water plant licence checklist and FSSAI licence guide, and remember that the plant also needs a groundwater NOC and Pollution Control Board consent. For the high-risk rules, read our explainer.

How ClearPath Compliance India can help

We check existing FSSAI licences against what a plant actually does, file modifications, upgrades and new manufacturing licences, prepare plants for the pre-licence inspection, and handle the groundwater NOC, CTE/CTO, factory licence and fire NOC. Send us a copy of your licence and your plant details, call +91 92521 92607, or message us on WhatsApp.

General information only, not legal advice. Rules and enforcement actions are as reported on the dates stated; the proceedings described are pending and no finding of guilt has been made. Units are described only to explain the reported cases. Any brand names are trademarks of their owners, used for identification only; this article is not sponsored or endorsed by any brand.

Sources: Kashmir Despatch, 27 September 2026; Dynamite News, 27 September 2026; The Hitavada, 24 July 2026; FSS (Labelling and Display) Regulations, 2020, as summarised by Taxguru; Section 63 after the Jan Vishwas Act, 2023, as summarised by myFSSAI.

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