Selling spices online in India: ground is not whole
Spices are standardised clause by clause, and whole, ground and blended products are gated on different rows. A branded masala blend has a named standard with three declarable grades.
- Spices sit in chapter 2.9 of the 2011 Food Products Standards regulations, clauses 2.9.1 to 2.9.43, and clauses 2.9.1 to 2.9.29 also carry the microbiological requirements in table 3 of Appendix B.
- Grinding changes the test, not the rigour: whole turmeric is gated on extraneous matter and defective rhizomes, turmeric powder on acid-insoluble ash, curcuminoid content and total starch.
- A branded blend is standardised. Clause 2.9.20 sets mixed masala powder in three grades at 85.0, 40.0 and 25.0 per cent minimum spice content, and the grade you pick must be declared on the label.
- Pure is barred for compound foods under Schedule V of the 2018 Advertising and Claims Regulations, and no added colour fails because added colour was never permitted in the product to begin with.
A packaged spice brand in India is rarely a manufacturer in the ordinary sense. It buys cleaned whole spice, grinds or blends it, packs it and sells it. Each step lands the product in a different part of the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011, and the part that applies decides which lab row can fail your batch.
Your product sits in chapter 2.9, and the sub-clause is the whole argument
Spices are standardised in chapter 2.9 of the 2011 Food Products Standards regulations, titled Salt, Spices, Condiments and Related Products. It runs from clause 2.9.1 to clause 2.9.43 and names individual commodities: cardamom at 2.9.2, chillies and capsicum at 2.9.3, turmeric at 2.9.18, asafoetida at 2.9.29.
The parameters that gate a batch repeat across almost every clause: extraneous matter, moisture, total ash on dry basis, ash insoluble in dilute hydrochloric acid on dry basis, volatile oil content and insect damaged matter. Two general rules sit above that list. The note at the head of 2.9 caps the inorganic fraction of extraneous matter, meaning dust, dirt, stones and lumps of earth, at 2 per cent by weight of total extraneous matter. And clauses 2.9.1 to 2.9.29 must also meet the microbiological requirements in table 3 of Appendix B, a failure mode independent of every chemical row.
Whole, ground and blended are three different tests
Turmeric at clause 2.9.18 shows this cleanly. Whole turmeric is gated on extraneous matter at 1.0 per cent, defective rhizomes at 5.0 per cent, moisture at 12.0 per cent, insect damaged matter at 1.0 per cent and a negative test for lead chromate. Turmeric powder drops the extraneous matter and defective rhizome rows entirely and picks up others: moisture at 10.0 per cent, total ash at 9.0 per cent, acid-insoluble ash at 1.5 per cent, colouring power as curcuminoid content at not less than 2.0 per cent, and total starch at not more than 60.0 per cent.
That is not loose drafting. Once a spice is ground you cannot see a stone, so the regulation stops asking you to look and starts measuring acid-insoluble ash instead. The same logic puts a starch ceiling on the powder and none on the rhizome.
A branded blend does have a standard, and it has three tiers
Most blend brands assume they are unstandardised. They are not. Clause 2.9.19 standardises curry powder, clause 2.9.20 mixed masala, including mixed masala powder.
Mixed masala powder is specified in three grades by minimum spice content: 85.0, 40.0 and 25.0 per cent by mass. Moisture is capped at 12.0 per cent and acid-insoluble ash at 2.0 per cent across all three. Minimum volatile oil moves with the grade, at 0.4, 0.2 and 0.1 per cent volume by mass on dry basis. The clause then does something unusual: it requires the minimum percentage of spice content to be declared on the label, and the other limits then apply according to the figure you declared. You pick your grade in public.
Two more things come from the same clause. Naming a blend after a dish is expressly contemplated, because the clause permits the name of the specific product, such as chana masala or sambar masala, to be mentioned. And salt content above 5 per cent must be declared. Curry powder at 2.9.19 is tight in a different way: not less than 85.0 per cent spices by weight, moisture not more than 14.0 per cent, edible common salt not more than 5.0 per cent, acid-insoluble ash not more than 2.0 per cent, crude fibre not more than 15.0 per cent, and lead not more than 10.0 ppm.
The licence route is the repacker route
Item V of Schedule 1 to the Food Safety and Standards (Licensing and Registration of Food Businesses) Regulations, 2011 sends food processing units including relabellers and repackers with installed capacity above 2 MT per day to the Central Licensing Authority, irrespective of turnover. Grinding and packing bought spice makes you a repacker, so capacity decides your tier, not only turnover, exactly as it does for selling seafood and meat online in India. The general FSSAI licence basics for food sellers are unchanged here, and nothing in that route is spice-specific.
Pure, mill fresh and no added colour are three separate problems
Schedule V to the Food Safety and Standards (Advertising and Claims) Regulations, 2018, notified on 19 November 2018, attaches conditions to specific words. Sorting your front of pack against it before artwork goes to print is cheaper than a reprint.
- Pure. Item 3 allows it only for a single ingredient food to which nothing has been added, with unavoidable contaminants below the limits in the Contaminants, Toxins and Residues Regulations, 2011. It then states that compound foods shall not generally be described as pure, although they may be described as made with pure ingredients if every ingredient qualifies. A masala blend is a compound food, so pure is not available to it. A single spice powder can earn it.
- Mill fresh. Item 2 restricts fresh to products not processed except by washing, peeling, chilling, trimming, cutting or irradiation up to 1 kGy, and says fresh or freshly shall carry no connotation beyond the immediacy of the action described. Grinding is processing.
- No added colour. Regulation 2(1)(m) defines a non-addition claim as one about an additive whose addition is permitted in the food. Added colouring matter is not permitted in turmeric or chilli powder at all, so there is nothing whose non-addition you can claim, and regulation 6 enumerates only sugars and sodium salts.
- Single origin. Undefined. No schedule, no test, no threshold. It is still a representation caught by regulation 4(1), which requires claims to be truthful and not misleading, so purchase records have to carry it.
- Organic. A separate regime, run through NPOP and the Jaivik Bharat mark under the Food Safety and Standards (Organic Foods) Regulations, 2017. Without certification the word is not available at any volume.
Traditional is worth a line too. Item 5 fixes a generation at thirty years of substantially unchanged formulation.
Sequence it so the label follows the lab
Pull the clause that names your product, test a real production batch against its rows, decide which grade and which words the results support, then release artwork. Brands that write copy first discover the standard through a sample failure, by which point the pouches are printed. The product safety documents a marketplace audit asks for are these same reports, filed early.