Technical perspective
FSSAI's Scheme of Testing for packaged drinking water and mineral water took effect on 1 January 2026. It follows the October 2024 omission of the mandatory BIS certification-mark requirement, but it does not remove the food business operator's duty to comply with FSSAI standards. The new scheme sets minimum testing frequencies, source-water controls, packaging checks, failure actions and record retention.
The change is especially relevant in Maharashtra, where FSSAI directed comprehensive inspection of packaged drinking water units. A unit should be ready to show more than a collection of laboratory reports: the regulator needs to be able to connect the approved source, production batch, package, result, release decision and corrective action.
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What changed—and what did not
BIS mark
The earlier mandatory certification-mark requirement was omitted in October 2024; this is not an exemption from FSSAI product standards.
Testing scheme
All relevant food business operators must follow the FSSAI scheme effective 1 January 2026.
Laboratory route
Specified source-water and periodic compliance testing must use an FSSAI-notified, NABL-accredited ISO/IEC 17025 laboratory as required by the scheme.
Records
The scheme requires records to be retained for five years and produced for inspection when requested.
Build the programme from the official product category. Packaged drinking water and natural mineral water do not share every requirement. Products marketed with added ingredients, alkaline claims or other descriptions may raise separate questions about identity, permitted ingredients and labelling. Do not assume that a water-like appearance or a high pH makes a product compliant.
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Turn the FSSAI scheme into a testing calendar
The table below summarises the minimum rhythm in the 17 December 2025 FSSAI scheme. The exact parameter lists and product-specific notes should be taken from the current official document. A risk assessment may justify more frequent internal checks; it should not be used to reduce a prescribed minimum.
| Frequency or event | Minimum scheme focus | Operational record |
|---|---|---|
| Before first use and whenever the source changes | Source water for all parameters specified under the applicable FSSAI standard | Source identity, sampling point, report and approval decision |
| Monthly | Specified microbiological parameters for the finished product | Batch/sample link, laboratory result and product-release status |
| Quarterly | Specified undesirable substances and certain packaging/carton checks | Due-date register, report and review signature |
| Every six months | Pesticide residues and all packaged drinking water parameters | Full-scope report and trend review |
| Every six months or as specified | Container and packaging conformity, including applicable migration requirements | Supplier lot, declaration, test report and change control |
The monthly microbiological set in the scheme includes coliforms, faecal streptococci and Staphylococcus aureus, sulphite-reducing anaerobes, Pseudomonas aeruginosa, aerobic microbial count, yeast and mould, Salmonella and Shigella, and Vibrio cholerae/parahaemolyticus. Confirm the method, sample quantity, transport conditions and acceptance criterion with the laboratory before collection.
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Source water, process control and packaging are one system
A compliant finished-product sample does not by itself validate a changing source or an uncontrolled filling line. Keep a source register that identifies borewell, municipal, tanker or other inputs; protect the abstraction and storage points; and treat any new source or material source change as a formal approval event. Routine plant controls should cover treatment performance, sanitation, filter and membrane maintenance, ozone or other disinfection controls where used, and environmental hygiene.
Packaging deserves the same change discipline. A new preform, cap, bottle resin, pouch film, ink, carton or supplier can alter conformity and migration evidence. Link packaging certificates and laboratory reports to the actual material grade and supplier lot. Generic food-grade statements without a material identity or intended-use condition are weak evidence.
- Maintain a master list of sources, tanks, treatment lines, filling lines and sampling points.
- Map every product and pack size to the correct specification and testing calendar.
- Record sanitation, maintenance, calibration and critical process checks against production dates.
- Use change control for source, treatment chemical, filter, package, cap and supplier changes.
- Trend results instead of reviewing each report only as pass or fail.
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Respond correctly to a microbiological failure
The FSSAI scheme requires investigation when a microbiological parameter fails and states that the affected production should not be released until conformity is established. Production and dispatch can restart only after five consecutive batches are satisfactory for the failed parameter. This makes a prewritten hold-and-release procedure essential.
| Step | Required control question | Evidence |
|---|---|---|
| Contain | Which batches, pack sizes, lines and dispatches could be affected? | Stock hold, distribution trace and decision log |
| Investigate | Was the source, process, environment, package, sampler or transport involved? | Root-cause record and targeted samples |
| Correct | What sanitation, maintenance or process action removes the cause? | Work record, verification and responsible approval |
| Verify | Have five consecutive batches met the failed microbiological requirement? | Lot-linked reports and authorised restart/release |
| Prevent recurrence | What monitoring or change control needs strengthening? | Revised procedure, training and trend review |
Retesting the same retained bottle until a satisfactory result appears is not a corrective-action system. Preserve the original evidence, investigate the process and define the regulatory disposition of held or distributed product with competent advice and the authority where required.
Build a packaged-water testing calendarArticle section
Inspection-ready file for a Maharashtra unit
- Current FSSAI licence, product categories and approved layout or operational details.
- Source-water approval reports and a change history for every source.
- Monthly, quarterly and six-monthly testing calendar with due and completion dates.
- Batch manufacturing, treatment, filling, sanitation and release records.
- Packaging specifications, conformity/migration evidence and supplier change controls.
- Out-of-specification investigations, holds, recalls where applicable and five-consecutive-batch evidence.
- Five-year retrievable archive with a clear link from each report to source or production batch.
Apply this guidance
