Introduction
In the Indian culinary landscape, for a substantial segment of the population, particularly those adhering to vegetarian diets, paneer serves not merely as a delicacy but as a vital source of protein and essential nutrients, effectively stepping in where non-vegetarian options might otherwise feature. From rich curries to flavourful stir-fries, delectable snacks and desserts, Indians consume paneer in different forms. However, recent concerns regarding proliferation of ‘fake’ paneer in the market have created doubts and apprehensions in the minds of Indian consumers.
A recent food safety investigation conducted in Noida and Greater Noida revealed alarming levels of adulteration in paneer, wherein 83% of paneer samples failed quality standards and 40% were stated to be unsafe due to presence of harmful chemicals and unidentified substances.[1] The Ahmedabad Municipal Corporation seized 1500 kgs of fake paneer being sold at multiple eateries.[2] Similarly, the Food and Drug Control Administration in Pune raided a factory and seized 1400 kgs of adulterated paneer where glycerol monostearate powder and skimmed milk powder was being used to prepare the same.[3] Recently, a number of high-end hotels have been in the limelight over allegations of serving fake paneer as real paneer in their menu.[4] Such food safety drives across various states uncover the widespread presence of fake paneer, raising serious questions about consumer safety and fair trade practices.
What is fake paneer?
Fake paneer, which is also referred to as ‘analogue paneer’ is basically designed to resemble traditional dairy paneer in appearance, texture, and even taste, but without using actual milk in full. Instead of fresh milk, fake paneer is usually produced using cheap vegetable oils, starch, emulsifiers, etc., as the ingredients, which helps create the firm, white cubes that one associates with real paneer, but the nutrition profile is far from similar.[5] Analogue paneer is usually sold at a lower price point as compared to real paneer.
What is interesting to note is that selling analogue paneer is not illegal in India, as long as its labelling is in compliance with the concerned food safety and standards regulations and does not seek to mislead the consumer into believing that the product is real paneer or a ‘dairy product’.
The Food Safety and Standards Authority of India (FSSAI), the apex regulatory body responsible for ensuring the safety and quality of food in the country, riddled with the alarming cases of fake paneer in the market, in an attempt to clearly define and regulate the market of dairy analogues, has released a consultation paper dated April 16, 2025, titled “Consultation Paper On Compliance With The Provisions Of ‘Analogue In Dairy Context’’ (FSSAI’s Consultation Paper)[6], inviting comments and suggestions from stakeholders. Against this backdrop, this blog post seeks to delve into the existing regulatory landscape governing dairy products and dairy analogues, particularly analogue paneer, and analyse the proposals outlined in FSSAI’s Consultation Paper.
Regulating dairy products and analogue dairy products – Analysing the contours of definitions, exclusions, and prohibitions
The Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011(FSS Additives Regulations), which inter alia provide for the general standards to be adhered for milk and milk products,make it clear that the usage of ‘dairy terms’ which could include names, designations, symbols etc. suggestive of the product being milk or milk product, can only be used for such products which are directly or indirectly milk or milk products.[7] In simple terms, if a food product is not made using milk or a milk product, such a product cannot be termed as a dairy product.
For clarity, products like cheese, chhana, paneer, cream, etc., have been listed as some of the milk products in the FSS Additives Regulations. The said list therefore inherently restricts the term “paneer” to a product derived solely from milk or as a milk product. Additionally, a look at the standards provided in the FSS Additives Regulations to be followed for paneer[8], include a specific definition of paneer[9], its essential raw materials, required composition of paneer, permitted food additives, etc. Therefore, composition of paneer as a dairy food product, is required to be in compliance with the set standards under the FSS Additives Regulations.
Analogues are not dairy products
The FSS Additives Regulations make it clear that food products which are analogues of dairy products (called as ‘analogues in the dairy context’[10]), are not to be understood as milk or milk products, and therefore, cannot be described using a dairy term. In this context, fake paneer which is basically analogue of paneer, made using ingredients like milk powder, vegetable oil, etc., that replace the actual milk constituent, is not a milk product or a dairy product, and therefore cannot be sold under a dairy term which can potentially mislead the consumers into believing that they are consuming real paneer which is a milk product. therefore
Describing and Labelling Dairy Products – Analogues not to be disguised as dairy products
FSS Additives Regulations provide for a detailed manner of labelling and describing milk and milk products in order to avoid issues of misleading and deceptive claims that can impact the health of consumers. The said regulations essentially lay down the contours of such labelling and description, along with providing clear guidance on which products would not be labelled as milk or milk products.
The FSS Additives Regulations[11] state that no food product should be presented in a manner that leads to a false impression regarding the true nature of the product – dairy terms intended for milk and milk product should not be used otherwise to describe products which are neither directly nor indirectly milk or milk products. In this context, the said regulations categorically state that ‘Analogues in the dairy context’ are not considered milk, milk products, and therefore cannot be labelled or described using dairy terms which signify the product being a milk or milk product. Further, no label, commercial document, publicity material or any form of point of sale presentation is permitted to be used for such products, which would claim, imply or suggests that the product is milk, a milk product or a composite milk product, or which refers to one or more of these products. [12] In case a product contains milk or a milk product as an ingredient which however is not an essential part in terms of characterisation of the concerned product, dairy terms are permitted to be used only in the list of ingredients of such product.
Further, in order to avoid confusion and deception, the FSS Additives Regulations[13] state that the labels of ‘analogues in the dairy context’ should specifically state the ingredients that have been used in place of milk in the product, in this format – “Contains …..”. Additionally, the milk constituent which is being replaced should also be mentioned in this format – “Contains no milk….”. In addition to FSS Additives Regulations, the Food Safety and Standards (Labelling & Display) Regulations, 2020[14] also prohibit the labelling, description, presentation etc., of a pre-packaged food product which leads to an erroneous or misleading impression of the product.
In a nutshell, while misleading and deceptive labelling/marketing of a food product, in this instance, of dairy products is prohibited, the proliferation of analogue paneer and the scepticism around the same colours a different picture – one may suggest that while labelling of dairy products is well defined and clear, labelling of dairy analogues needs to be more informative and easier to understand for the consumer. In this context, FSSAI’s Consultation Paper seeks to bridge this gap.
Decoding the FSSAI Consultation Paper: A Step Towards Clarity?
The FSSAI’s Consultation Paper signifies a proactive approach towards addressing the regulatory gaps in the framework for the standardization and labelling of analogue dairy products, aiming to protect consumer interests and ensure fair trade practices. The paper emphasizes the importance of clear and transparent labelling. Usage of phrases like ‘non-dairy’ or ‘analogue’ to be used as prefix to the dairy terminology is being contemplated. Such mention is also proposed to be incorporated in the ingredient list in case an analogue of dairy product is used as an ingredient, along with the constituents of such analogue product. Therefore, if an analogue of cheese is used as an ingredient of a product, the same shall be mentioned in the ingredient list as ‘analogue of cheese’. Further, in case of restaurants and hotels, such place should clearly mention the exact nature of the food item being served. For instance, if analogue paneer is being used to made ‘kadhai paneer’, the menu card should mention the same.
To curtail the easy sale of analogue of dairy products in the market, the FSSAI Consultation Paper states that analogue of dairy products should only be sold in a packed condition not less than 500 grams with proper labelling describing the true nature of the product following the labelling requirements set in the FSS Additives Regulations. Another interesting proposal set forth by the said consultation paper is the restrictions on the grant of FSSAI registration for food business operators manufacturing dairy analogues. The paper states that the category of ‘Analogue in dairy context’ may only be given State and Central Licenses in order to ensure greater scrutiny and better compliance on the end of the food business operators.
Conclusion: Navigating the Future of Analogue Dairy Products
The controversy surrounding fake paneer underscores a critical need for a robust and adaptive regulatory framework that can keep pace with the evolving food landscape of analogue dairy products. The widespread adulteration not only deceives consumers but also poses potential health risks due to the use of unpermitted and potentially harmful substances. The FSSAI’s efforts in addressing this issue through proactive surveillance and the formulation of specific regulations for dairy analogues are commendable and timely. The potential benefits of the proposals set forth in the FSSAI Consultation Paper are manifold. Firstly, clear regulatory standards would provide manufacturers with much-needed clarity. Secondly, standardized labelling would empower consumers to make informed choices based on accurate information about the product’s composition and nutritional value. This would be particularly beneficial for individuals with dietary restrictions or preferences.
However, the proposals also warrant careful consideration of potential challenges. For instance, there is a risk that overly stringent regulations could stifle innovation and limit the availability of affordable dairy alternatives. Moreover, ensuring effective enforcement of these regulations across the vast and diverse Indian food market will be a significant undertaking. The active engagement of stakeholders in this consultation process is vital to ensure that the final regulations are balanced, practical, and effective in addressing the challenges posed by analogue paneer and other analogue dairy products.
[1] Paneer Adulteration News: 702 food samples revealed paneer as the most adulterated product | – The Times of India
[2] Dairy to scary: Fake paneer flooding markets; 1.5k kg seized in six months | Ahmedabad News – The Times of India
[3] 1,400 kg of adulterated paneer seized from factory in Pune
[4] Gauri Khan’s Torii restaurant reacts after YouTuber finds ‘fake paneer’ — ‘As dish contains soy-based ingredients…’ | Mint
[5] How harmful is fake paneer served in popular Indian restaurants
[6]https://fssai.gov.in/upload/uploadfiles/files/Consultation%20Paper%20for%20inviting%20comments(1).pdf
[7] Regulation 2.1.1 (1) (c) defines ‘dairy terms’ as ‘names, designations, symbols, pictorial or other devices which refer to or are suggestive, directly or indirectly, of milk or milk products’; Regulation 2.1.1 (1) (e) defines ‘milk’ as ‘the normal mammary secretion derived from complete milking of healthy milch animal, without either addition thereto or extraction therefrom, unless otherwise provided in these regulations and it shall be free from colostzrum’; and Regulation 2.1.1(1)(f) defines ‘milk product’ as ‘product obtained by processing of milk, which may contain food additives and other ingredients functionally necessary for the milk product as permitted in these regulations…’.
[8] Regulation 2.1.16, FSS Additives Regulations
[9] Paneer has been defined as ‘product obtained from any variant of milk**, with or without added milk solids, by precipitation with permitted acidulants and heating’.
[10] Regulation 2.1.1 (1)(aa) defines ‘analogues in the dairy context’ as ‘products in which constituents not derived from milk take the place, in part or in whole, of any milk constituent(s) and the final product resembles, organoleptically and/or functionally, milk or milk product or composite milk product as defined in these regulations’
[11] Regulation 2.1.1.(2)
[12] Regulation 2.1.1 (3)(f)
[13] Regulation 2.1.1(5) (b)
[14] Sub-regulation 4(3)