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EXTRAORDINARY

Published by Authority

CHANDIGARH, WEDNESDAY, SEPTEMBER 2, 2026 (BHADRA 11, 1948 SAKA)

FOOD AND DRUGS ADMINISTRATION, PUNJAB

Near Civil Hospital, Kharar Distt SAS Nagar (140301)

The 20th August, 2026

No. Food(Pb)/2026/1406.-

Prohibition Order

Subject—Prohibition, in the interest of public health, of the manufacture, storage, distribution

(including transport) and sale of Analogue / Non-Dairy Paneer (Analogue in Dairy Context) which is

marketed in the name of paneer, throughout the State of Punjab for a period of one year under

Section 30(2)(a) of the Food Safety and Standards Act, 2006; and directions regarding the standards,

packaging and labelling of Paneer / Chhana under Regulation 2.1.16.

WHEREAS, Section 18(1) of the Food Safety and Standards Act, 2006 (hereinafter referred to as

"the Act") sets out the general principles to be followed in the administration thereof, including-

(a) the achievement of an appropriate level of protection of human life and health and the protection

of consumers' interests, including fair practices in all kinds of food trade;

(b) risk management taking into account the results of risk assessment;

assessment of available information, the possibility of harmful effects on health is identified

though scientific uncertainty may persist; and

(d) the requirement that such measures be proportionate and no more restrictive of trade than is

required to achieve the appropriate level of health protection;

AND WHEREAS, Section 30(2)(a) of the Act empowers the Commissioner of Food Safety of the

State, in the interest of public health and for reasons to be recorded in writing, by notification in the Official

3846 PUNJAB GOVT. GAZ. (EXTRA), SEPTEMBER 2, 2026 (BHDR 11, 1948 SAKA)

Gazette, to prohibit the manufacture, storage, distribution or sale of any article of food in the whole of the

State or any area thereof for such period not exceeding one year as may be specified, where there exist

reasonable grounds for believing that such article of food is likely to be unsafe or injurious to health;

AND WHEREAS, it has come to the notice of the Department that products described as "Analogue

Paneer", "Non-Dairy Paneer", "Vegan Paneer", "Synthetic Paneer", "Plant-based Paneer", or by any other

similar description are being manufactured, stored, transported, distributed and sold while being

represented, displayed or marketed as "Paneer", thereby creating confusion among consumers and

facilitating misbranding and deceptive trade practices. During the period 01st April 2025 to 31st March

2026, samples of paneer / dairy analogue drawn from across the State were sent for analysis to notified

Food Laboratory, of which 512 samples stood analysed as on date, and of the analysed samples 215 samples -

being 42% of the analysed samples were reported to be non-conforming, namely 156 sub-standard and 59

unsafe; and on analysis of the extracted fat a significant proportion thereof showed a Butyro-refractometer

(BR) reading outside the limits prescribed for milk fat, indicating the addition or substitution of vegetable

(foreign) fat not naturally present in milk, rendering the article of food unsafe and misbranded under the

provisions of the Act;

AND WHEREAS, the manufacture and sale of such analogue /non-dairy paneer, and the sale

thereof as, or in the guise of, genuine paneer, deceives the consumer as to the nature and substance of the

food, and contravenes the labelling requirements applicable to dairy analogues - including the declarations

prescribed under Regulation 2.1.1(5)(b) as to the non-milk constituents used and the milk constituents

replaced as also the Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011;

AND WHEREAS, paneer is a standardised food under Regulation 2.1.16 of the Food Safety and

Standards (Food Products Standards and Food Additives) Regulations, 2011, defined as the product

obtained from milk (of any variant), with or without added milk solids, by precipitation with permitted

acidulants (lactic acid, citric acid, malic acid, vinegar, glucono delta lactone or sour whey) and heating;

milk fat is an essential constituent of paneer, and the substitution or addition of vegetable oil, vegetable fat

or any non-milk fat is not permitted; and accordingly a product resembling paneer in which milk fat or milk

solids are replaced wholly or partly by non-milk constituents is, in law, an "analogue in dairy context"

governed by Regulations 2.1.1(3)(f) and 2.1.1(5)(b), which is not paneer and cannot be named, sold or

served as "Paneer", dairy terms not being available to a product intended to substitute a milk product, and

which is required to declare, in close proximity to the name of the product, the substitution of milk

constituents by non-milk constituents for example, "Contains Vegetable Fat" and "Contains no milk fat" -

in the manner prescribed under Regulation 2.1.1(5)(b); and any analogue /non-dairy product offered, sold

or served as paneer is misbranded, and where prepared from non-dairy- ingredients or otherwise non-

conforming, is unsafe within the meaning of the Act;

PUNJAB GOVT. GAZ. (EXTRA), SEPTEMBER 2, 2026 (BHDR 11, 1948 SAKA)

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AND WHEREAS, the Standard for Chhana and Paneer under Regulation 2.1.16, as amended by

the Food Safety and Standards (Food Products Standards and Food Additives) Fifth Amendment

Regulations, 2019, prescribes three categories of paneer according to milk-fat content namely Paneer

(regular/full-fat), Medium Fat Paneer and Low Fat Paneer together with their compositional standards and

packaging-and-labelling requirements; and in terms of the said Standard, Low Fat and Medium Fat

Paneer/Chhana shall be sold in sealed packages only and shall bear the prescribed label declarations,

whereas regular (full-fat) Paneer may be sold loose subject to the Act and the Regulations; and no product

not conforming to the said Standard in particular no analogue / non-dairy paneer - may be named, sold or

served as "Paneer";

AND WHEREAS, the Hon'ble Supreme Court of India, in Swami Achyutanand Tirth &Ors. v.

Union of India & Ors., Writ Petition (Civil) No. 159 of 2012, decided on 5th August 2016 [(2016) 9 SCC 699],

taking note of the large-scale adulteration of milk and milk products including the use of refined / vegetable

oil as a substitute for milk fat - directed the Union of India and the State Governments to implement the

Food Safety and Standards Act, 2006 in a more effective manner, and in particular directed that the State

Food Safety Authorities identify high-risk areas and high-risk times (such as festival seasons) and intensify

sampling therein, that adequate NABL-accredited testing infrastructure and mobile food-testing facilities

be ensured, that State-level and District-level committees be constituted to review the work of curbing

adulteration, and that the general public be informed of the nature of the risk to health in terms of Section

18(1)(f) of the Act; and the said directions cast a continuing obligation upon this authority to take effective

preventive measures against the adulteration of milk and milk products;

AND WHEREAS, notwithstanding sustained enforcement, surveillance and sampling carried out

over a period of one year and the awareness and labelling measures already in force, the incidence of non-

conforming paneer and of the substitution of genuine paneer by vegetable-fat analogue has shown no

appreciable improvement, the proportion of non-conforming samples remaining persistently high at 42%

of the samples analysed, thereby demonstrating that enforcement through routine sampling and the existing

labelling framework has, by itself, proved insufficient to arrest the said practice and to protect public health;

AND WHEREAS, upon consideration of the material placed before me including inspection

reports, seizure proceedings, laboratory findings, the use of non-food-grade ingredients, the systematic

substitution of genuine paneer by analogue /non-dairy paneer in manufacture and in the food-service sector,

the absence of any prescribed quality standards for analogue paneer and the consequent infeasibility of

field-level enforcement, and the considered opinion of the 48^thCentral Advisory Committee Minutes - I am

satisfied that analogue /non-dairy paneer, as a class, being non-standardized, nutritionally non-beneficial,

organoleptically indistinguishable from genuine paneer and inherently prone to deliberate adulteration and

3848 PUNJAB GOVT. GAZ. (EXTRA), SEPTEMBER 2, 2026 (BHDR 11, 1948 SAKA)

to being passed off as genuine paneer, presents a risk to human health and to the interests of consumers;

and that this Order is directed at non-standardized dairy analogues, for which no quality parameters stand

prescribed by the Food Authority, and does not extend to standardized products such as frozen dessert,

processed cheese and mixed fat spread, for which standards stand duly notified - the said distinction being

that drawn by the Central Advisory Committee itself; and that, in the interest of public health, a prohibition

of the said article of food throughout the State for a period not exceeding one year, in exercise of the powers

under Section 30(2)(a) of the Act, is necessary and proportionate;

NOW, THEREFORE, in exercise of the powers conferred under Section 30(2)(a) read with

Sections 18 and 29 of the Food Safety and Standards Act, 2006, and all other powers enabling me in this

behalf, I, Kanwal Preet Brar, I.A.S., Commissioner, Food and Drugs Administration, Punjab, hereby issue

this Order, which shall have immediate effect and be binding upon all Food Business Operators engaged in

the manufacture, storage, distribution (including transport) and sale of paneer and analogue / non-dairy

paneer throughout the State of Punjab, as follows:

Definitions: For the purpose of this Order, "analogue/non-dairy paneer" shall mean any

product resembling paneer in which milk fat or milk solids are replaced wholly or partly by

vegetable oil, vegetable fat or other non-milk-derived constituents.

ii.

Prohibition of Analogue/Non-Dairy Paneer: The manufacture, processing, preparation,

packing, storage, distribution (including transportation), wholesale sale, retail sale, offering or

exposing for sale, and sale by any means whatsoever, within the State of Punjab, of analogue /

non-dairy paneer (by whatever name called or described), is hereby prohibited throughout the

State of Punjab for a period of one year from the date of publication of this Order in the Official

Gazette.

iii.

Food Service Establishments (Hotels, Restaurants, Caterers): No hotel, restaurant, caterer,

eatery, cloud kitchen or other food service establishment shall use, prepare, serve, store, stock,

sell or keep analogue / non-dairy paneer in any dish, preparation or article of food whatsoever;

and the use or service of analogue / non-dairy paneer, including in the guise of genuine paneer,

being misleading to consumers and an unfair trade practice within the meaning of Section 24

of the Act, and a contravention of the responsibilities cast upon Food Business Operators under

Section 26 of the Act, is hereby prohibited.

iv.

Paneer - Labelling Compliance: Every Food Business Operator manufacturing, packing,

storing, distributing or selling paneer/chhana shall ensure that every package thereof bears all

the declarations prescribed under the Food Safety and Standards (Labelling and Display)

Regulations, 2020, failing which the article shall be liable to be dealt with as misbranded under

Section 52 of the Act.

PUNJAB GOVT. GAZ. (EXTRA), SEPTEMBER 2, 2026 (BHDR 11, 1948 SAKA)

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Penalties and Consequences: Any contravention of this Order shall be punishable under the

applicable penal provisions of the Food Safety and Standards Act, 2006 including Sections 50,

51, 52 and 59, and shall render the offending article liable to seizure and destruction in

accordance with law.

vi.

Commencement, Duration and Representations: This Order shall come into force on the

date of its issuance and shall remain in force for a period of one year from that date, unless

earlier rescinded, modified or extended in accordance with law.

This Order is issued in the interest of protecting public health and ensuring the availability of safe food to

consumers of the State of Punjab.

Sd/-

KANWAL PREET BRAR, I.A.S.

Commissioner,

Food & Drugs Administration, Punjab.

3818/9-2026/Pb. Govt. Press, S.A.S. Nagar