When FSSAI removed the compulsory BIS mark for packaged drinking water (PDW) and mineral water in October 2024, many plant owners read it as "less paperwork". In practice, the testing burden moved, it did not disappear. FSSAI's Scheme of Testing, issued by order dated 17 December 2025 (File No. RCD-15001/19/2025-Regulatory-FSSAI), has applied to all PDW and mineral water manufacturers since 1 January 2026.
This guide turns the order into a simple calendar for running plants.
Who the scheme applies to
The order covers every food business operator making packaged drinking water (other than packaged natural mineral water) and mineral water. It sits alongside FSSAI's order of 29 November 2024 placing these products in the High-Risk Food Categories, which brings pre-licence inspection, annual risk-based inspection and, for central licensees, an annual third-party audit. Your testing records are what inspectors and auditors will ask to see.
All testing must be done at an FSSAI-notified, NABL-accredited laboratory (ISO/IEC 17025). Results from a lab that is accredited but not FSSAI-notified may not be accepted, so check the lab's status before signing a contract.
The testing calendar at a glance
| What is tested | Frequency | Notes |
|---|---|---|
| Source (raw) water, all parameters | Before use, and again on any change of source | Production from a new source starts only after all results comply |
| Finished product, microbiological parameters | Once a month | Coliform, faecal streptococci, S. aureus, Pseudomonas aeruginosa, yeast and mould, Salmonella, Shigella, Vibrio species and others; mineral water also E. coli |
| Finished product, listed chemical parameters | Once every three months | For PDW, includes nitrate, nitrite, iron, manganese, copper, zinc, aluminium, calcium, magnesium, barium, antimony, borates and others |
| Pesticide residues | Once every six months | Individual and total |
| Full specification (all parameters) | Once every six months | Against FSS regulation 2.10.8 (PDW) or 2.10.7 (mineral water) |
| Packaging material (jars, bottles, closures, pouches) | Mostly once every six months | Retest all parameters if the supplier changes |
Source: FSSAI order dated 17 December 2025. Always read the full order for the complete parameter lists and forms.
What happens if a sample fails
The order sets out clear steps:
- Microbiological failure: recheck stock and release only after conformity is confirmed, investigate the cause, take corrective action, and resume only after five consecutive batches give satisfactory results.
- Chemical failure: test that parameter monthly until three consecutive batches comply.
- Repeated non-compliance in consecutive six-monthly reports attracts a risk-based inspection by FSSAI.
- Radioactive residues in source water: the source must be abandoned, the water recalled and the Food Authority informed immediately.
Rejected product must be recorded and kept physically separate from conforming stock until disposal.
Records you must keep
The order prescribes formats (Forms 1 to 6) for monthly tests, lab testing, source water and packaging material tests. Records of microbiological non-compliance and corrective action must be kept for at least five years. Also keep batch records and purchase invoices and test certificates for any minerals added during remineralisation, which must be food or pharma grade.
What this means for water plant owners
- Put the calendar on the wall. Twelve microbiological reports, four chemical reports and two full-specification reports a year is the minimum rhythm for each product type.
- Book an FSSAI-notified lab on a fixed date each month so a busy month does not create a gap in your records.
- Treat a source change as a new start. A new borewell, a tanker supply or a municipal connection needs full testing before use, and borewells may also need a CGWA NOC.
- Link testing to your licence file. Inspectors under the high-risk regime will compare test reports with your FSSAI licence, production records and pollution board consent.
- Check state rules too. Uttar Pradesh now requires BIS certification for PDW units in the state, on top of this scheme.
How ClearPath Compliance India can help
We help packaged drinking water plants set up a testing calendar, prepare the prescribed record formats, shortlist FSSAI-notified NABL labs, and get ready for risk-based inspections and third-party audits. For new projects, see our complete approval checklist for a packaged drinking water plant. Share your current test reports and licences with us, and we will point out any gaps before your next inspection.
Need help with this for your plant? ClearPath handles BIS certification (IS 14543) for packaged drinking water end to end. Send us your plant details for a free requirement check.
This article is general information only, not legal advice. Rules are as notified or reported on the dates stated above (FSSAI order dated 17 December 2025); check current FSSAI, BIS and state notifications before acting. Brand names, where mentioned on this site, are trademarks of their respective owners and are used for identification only. ClearPath Compliance India is an independent consultancy; this article is not sponsored or endorsed by any brand or company.