#e4mXplains:  Why FSSAI wants analogue products to stop calling themselves Paneer

Paneer is one of the few words in Indian food that needs no introduction, no explanation and, until now, very little proof. That trust is exactly what the Food Safety and Standards Authority of India (FSSAI) is trying to protect with a draft amendment notified on September 22 and published in the Gazette of India on September 23. The proposal seeks to restrict the manufacture and sale of analogue products as paneer, so that consumers are not misled about what they are actually buying.

For brands, restaurants and the agencies that write their packs and menus, it is worth understanding how the regulator got here and where it may go next.

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What exactly has FSSAI proposed?

The draft amends the Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011, and will be called the Prohibition and Restrictions on Sales Amendment Regulations, 2026 if it is finalised. It inserts a specific entry covering paneer made of constituents not derived from milk. Products already licensed or registered under the Analogue in Dairy Context category would have to stop using the word paneer in their nomenclature, labelling or marketing. The regulator has invited objections and suggestions from stakeholders, and the draft will be considered only after 60 days from the date the Gazette copies are made available to the public. In other words, this is a proposal, not yet a final nationwide ban.

What is an analogue in the dairy context?

FSSAI's own FAQs on dairy analogues define it as a product in which constituents not derived from milk take the place, in part or in whole, of any milk constituent, while the final product resembles a milk product in look, taste or function. The usual substitutions are vegetable oil or fat for milk fat, and vegetable protein for milk protein. The rule applies to products already listed and standardised as milk products or composite milk products, which means an analogue is essentially a lookalike of something that has a recognised dairy identity.

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The FAQs are equally clear on what an analogue is not. Skimmed or toned milk, lactose-free milk and fortified milk are modified dairy products, not analogues, because nothing is being substituted with a non-milk ingredient. Fruit-based shrikhand and flavoured fermented milks are also outside the net. So are products made entirely from non-dairy ingredients with a traditional name, such as coconut milk and peanut butter, and foods where dairy is only a characterising ingredient, such as milk chocolate, cream biscuits and cheesecake. The FAQs also close off one route completely: nothing can be blended with ghee or butter to create an analogue, since such admixtures are already prohibited.

Is Analogue Paneer already restricted?

Partly, and that is the interesting bit. Under the existing framework, analogues are not recognised as dairy products, and dairy terms such as milk, cream, cheese, butter and dahi are reserved for products made from milk. By that logic, an analogue is not supposed to use dairy terminology in its name, and it cannot carry the mandatory Milk logo that standardised dairy products use. Those that have no standardised identity must carry the word Analogue on the label along with the food category number under which they are licensed, such as 1.6.5 for a cheese analogue. Where milk fat or protein is only partly replaced, the pack must declare Contains followed by the constituent and its source. Where it is fully replaced, an additional Contains no declaration is required. These products are licensed under General Manufacturing and not as proprietary foods.

So why is a fresh amendment needed? The draft names paneer specifically and brings it into the restrictions on sales, which removes any room for interpretation. Cheese analogue products sold as paneer were the grey zone, and FSSAI's West Region had already issued a public notice in April 2026 stating that this practice violates food safety and labelling requirements.

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Why is this happening now?

States have been moving ahead of the Centre. Maharashtra's Food and Drug Administration prohibited analogue or non-dairy paneer in July 2026, Karnataka imposed a one-year ban in August, and Gujarat and Chhattisgarh have also acted. FSSAI chief Rajit Punhani has said that eight states have already banned it and that a countrywide ban would be considered once states give feedback and a consensus emerges. His reasoning is that paneer is a major source of food and protein in India, and consumers should get what they expect when they order it.

Price is the other driver. Earlier market reports put real paneer at around ₹450 a kg, against ₹200 to ₹250 for analogue, nearly half. Those are older figures, but the gap explains why the substitute turned up in restaurant kitchens and street food. The category is large enough to be worth protecting: IMARC Group valued India's paneer market at ₹731.4 billion in 2025 and projects a 12.34% CAGR through 2034. Industry estimates also place the packaged paneer market at roughly ₹12,000 crore, against a ₹30,000 crore loose and unorganised segment that could shift towards branded players if enforcement tightens.

What changes for brands, restaurants and agencies?

For dairy brands, the draft strengthens a territory they have long occupied in communication: real milk, purity and sourcing. Expect agencies to revisit pack language, on-pack callouts and campaign narratives, while being careful not to cross from a legitimate milk-based claim into disparagement of analogues.

For analogue makers, the challenge is creative as much as regulatory. They will need a new product name that is honest on the label, appealing on the plate and distinct from a word they can no longer use. Restaurants, hotels and caterers face a parallel exercise, since menu copy, delivery-app listings and outdoor communication that lean on the word paneer may need a second look, and some may face higher input costs if they move back to milk-based paneer.

What happens next?

The 60-day consultation window is the key milestone. Stakeholders from dairy cooperatives to restaurant associations and analogue manufacturers can submit objections and suggestions, and FSSAI will weigh these before deciding whether to notify the amendment as final. If it does, the Indian food industry will have a clear rule on one of its most familiar words: if it is called paneer, it has to be made from milk.