Paneer in the Dock, Cheese on the Pizza
FSSAI proposes to ban a use of the word "paneer" that its own rules already prohibited. At the same time it stays silent on analogue cheese, which commits the same breach of trust on restaurant menus and supermarket shelves. Integrity cannot be applied to one product and not the other.
Kuldeep Sharma, Chief Editor, DairyNews7x7
On 22 September 2026, FSSAI published a draft amendment that adds one line to the Food Safety and Standards (Prohibition and Restrictions on Sales) Regulations, 2011: "paneer made of constituents not derived from milk." The explanatory note goes further. Products already licensed or registered under the "Analogue in Dairy Context" category must stop using the word "Paneer" in their nomenclature, labelling or marketing.
The dairy fraternity will welcome it, and so do I, up to a point. But two things in this notification deserve scrutiny.
The first is what it admits: products carrying the word "paneer" were licensed under the analogue category, by FSSAI's own system. The second is what it leaves out: the word "cheese" does not appear anywhere in it.
The rule was always there
Under the Food Product Standards and Food Additives Regulations, an analogue in the dairy context is a product in which non-milk constituents replace milk constituents, in part or in whole, and which resembles a milk product in taste or function.
The same regulations say plainly that analogues are not milk products. No label, commercial document, publicity material or point-of-sale presentation may claim, imply or suggest otherwise. Where the product is meant to substitute for a milk product, dairy terms shall not be used.
The 2020 draft went further still.
It proposed barring dairy terms and even phonetically similar or spell-alike names, and requiring every such pack to carry the words "THIS IS NOT A DAIRY PRODUCT." It also proposed an exclusive milk logo that only genuine dairy products could use.
Under these rules, "analogue paneer" was a contradiction in terms, and so was "analogue cheese." The 2026 draft does not create a new prohibition. It moves an existing one from the labelling chapter to the sales-prohibition chapter, and applies it to only one of the two products.
The regulator adopted the vocabulary it was meant to police
FSSAI's own April 2025 consultation paper speaks of "Analogue of Paneer" and "Analogue of Cheese," and gives "Kadhai Paneer" and a burger made with cheese analogue as examples.
The 2026 notification talks about restricting "analogue product as paneer." When the regulator uses the phrase in its own documents, it can hardly be surprised when the market does the same.
The analogue industry did not grow in a regulatory vacuum. It grew under this very regime, through licences issued, inspections not carried out, and complaints not acted on. Dairy bodies, processors and
writers like me have asked the regulator to act on this for close to a decade.
In the meantime, states have acted on their own. Chhattisgarh, Maharashtra, Gujarat, Madhya Pradesh, Uttarakhand and Uttar Pradesh have all moved, some extending bans to cream, butter, ghee and khoya. Punjab and Telangana have each imposed one-year prohibitions, and Zomato has introduced a zero-tolerance policy that covers analogue cheese as well as analogue paneer.
Note that the platform included cheese. The states included cheese.
Only the national regulator left it out.
The cheese question FSSAI didn't ask
Analogue cheese is not a fringe product in India.
It is an established category, found in pizza toppings, burger slices, "cheesy" dips, sandwich spreads and frozen snacks. It carries the same breach of trust as analogue paneer, often at greater scale, because it moves through organised QSR chains and branded packs rather than loose slabs at a mandi.
The evidence is on record. In 2023, a Maharashtra FDA inspection at a McDonald's outlet in Ahmednagar found items such as "cheese nuggets," "cheesy dip" and "cheese burger" labelled without any mention of analogue, and the outlet's licence was suspended. The licence was restored after the chain filed a compliance report and removed "cheese" from the product names. To be fair, the company later said FSSAI had confirmed that the articles in question contained cheese and no dairy analogue. That contradiction is itself the point. A state regulator and the central regulator reached opposite conclusions about the same menu, and the only lasting change was a renamed burger. Amul, meanwhile, ran ad films taking aim at "fake cheese," with the line that real cheese is made of milk, not vegetable oil. When the country's largest dairy has to take this fight to television, the regulator has left a gap.
This year the problem became impossible to ignore.
Maharashtra FDA ordered restaurants, hotels, caterers and fast-food vendors to declare cheese analogue on menus, display boards and bills from 1 May 2026, citing a surge in consumer complaints. In the first ten days, 1,496 establishments were inspected and 320 were issued show-cause notices. FSSAI officials were reported as saying the state's model could serve as a guideline for the whole country. Gujarat then banned the production, transport and sale of analogue paneer, cheese and butter after laboratory tests found vegetable oils in place of milk.
So FSSAI officials praised a cheese-analogue enforcement model in May, and in September the regulator drafted a rule that mentions only paneer. Why?
I can think of explanations, but none of them is a defence.
Paneer is the headline product: it appears in festival raids, on television, and in the family kitchen. Cheese analogue sits inside organised supply chains, pizza brands and processed-food manufacturing, where the players are larger and better at making their case to the regulator.
Cheese analogues are also often partial substitutions, with milk solids blended with vegetable fat, which makes them harder to classify. That difficulty is a reason for clear drafting, not for silence.
The economic harm is just as real. Milk fat is the most expensive constituent in cheese, and vegetable fat costs a fraction of it. A small unit making analogue "mozzarella" or "pizza cheese" from palm oil and starch can undercut a genuine cheese plant on price every day of the year.
Across India, numerous small players are doing exactly this, and they are disrupting the economics of dairies that invested in real cheese, real whey streams and real milk procurement from farmers. When the analogue is sold under a dairy name, the dairy plant is not competing against an alternative product. It is competing against deception.
A regulator that makes paneer the villain while effectively granting amnesty to cheese is not protecting integrity. It is picking a scapegoat.
Analogues are not the enemy. Deception is.
This point gets lost in the "fake paneer" headlines, so I will make it plainly.
An analogue made from edible vegetable fat, milk solids or plant protein, produced hygienically from permitted ingredients, is not a poison. Even the Maharashtra FDA stated that these analogue products are not harmful, only that consumers must be told.
The Codex General Standard for the Use of Dairy Terms does not ban such products. It protects dairy names. Around the world, analogue cheese, non-dairy creamers, fat spreads and filled milks are established industries serving price-sensitive markets, with clear labelling lines drawn by regulators.
I will grant the other side its strongest argument. Much of what is seized in raids is not a well-made analogue at all but outright adulteration, and palm oil and hydrogenated fat raise real nutritional questions. But that is food safety, and it is already covered elsewhere in the Act. The specific harm of an honestly made analogue sold under a dairy name is not to the body. It is to trust, and that harm is identical whether the product is called paneer or cheese.
The 2025 paper was the better plan, and it treated both products equally
The April 2025 consultation paper deserves more credit than it received. It went after the points in the chain where deception happens, and it covered all analogues, not only paneer.
It proposed that analogues be sold only in packed, labelled form, never loose, with a minimum pack size of 500 g. It proposed barring petty FBOs on basic registration from manufacturing any dairy analogue (paneer, cream, milk or cheese), leaving production to state- and central-licensed operators. It asked restaurants to declare "Non-dairy" or "Analogue" on menus, and its own examples were Kadhai Paneer and a cheese burger. And it asked that analogues used as ingredients be declared by their true nature, with their own ingredients listed in brackets.
That was an even-handed, supply-chain approach. Nearly eighteen months later, we have no published outcome. Instead we have a one-line prohibition covering one product.
Two further problems in the draft
First, the drafting is loose. "Paneer made of constituents not derived from milk" may not capture partial substitution, which the analogue definition clearly covers.
A manufacturer will argue that part of its product is derived from milk. Second, the draft takes the name away without deciding what the product should be called. The first question in the 2025 consultation paper, on nomenclature, remains unanswered. Without a mandatory generic name, the market will invent euphemisms and we will be back here in five years.
A ban without a plan
Here is the question the notification never answers: what will change on the ground the day after this rule is notified?
Using "paneer" or "cheese" for an analogue is already prohibited today. The dairy-terms clause in the product standards has been in force for years, and misbranding already carries penalties under the Food Safety and Standards Act.
The problem was never the absence of a rule. It was the absence of anyone checking. Moving the prohibition from the labelling chapter to the sales-prohibition chapter changes the legal instrument, not the inspector, the laboratory or the restaurant kitchen.
The draft is silent on every practical question that matters:
- No licence audit. FSSAI admits that products carrying "paneer" were licensed under the analogue category. How many are there? Will those licences be reviewed through FoSCoS, and who will check that the labels actually change?
- No compliance timeline. Existing licensees are told to "discontinue" the term. By when? What happens to the stock already in the market? Is there any penalty for missing the deadline?
- No testing protocol. An inspector at a dhaba needs a quick, notified method to tell milk paneer from a vegetable-fat block, such as fatty acid profile, β-sitosterol or starch screening, with clear limits for partial substitution. None is referenced in the draft.
- No mechanism for restaurants. Most of the deception happens once the product leaves the pack and ends up in a gravy or on a pizza. The draft says nothing about menus, bills or restaurant purchase records. That is exactly the gap the 2025 paper tried to close, and the one Maharashtra had to close on its own.
- No surveillance plan and no role for the states. There is no national sampling drive, no reporting target, and no coordination with the states that have already issued their own bans.
- No route for consumers. There is no dedicated complaint channel and no public list of licensed analogue manufacturers against which a buyer or a restaurant could verify a supplier.
- A prohibition is only as strong as its first inspection. Without these elements, the 2026 amendment risks being what the earlier rules became: correct on paper, ignored in the market, and brought out after the next viral raid.
- What FSSAI should do
Start by applying one rule to every analogue.
Extend the prohibition to cheese, cream, butter, ghee, khoya and every other dairy term, as the existing regulations already require in principle. A rule that covers paneer but not cheese isn't a rule about integrity. It's a rule about whichever product is in the headlines.
Next, finalise the 2025 package for all analogues together. That means packed-only sale with no loose slabs, and manufacturing restricted to state- and central-licensed operators. Restaurants should declare analogue use on menus and bills, on the Maharashtra model that FSSAI officials were reported to have praised.
Any analogue used as an ingredient should be named for what it is, with its own ingredients listed in brackets.
Then fix the drafting. Make it clear that the prohibition covers partial substitution, not only products with no milk at all. Prescribe standard generic names for each analogue category, so that the market does not fill the vacuum with new euphemisms. And revive the exclusive dairy logo proposed in 2020, so that genuine milk products can be recognised at a glance.
Finally, and above all, publish the enforcement plan with the same weight as the rule itself:
- a FoSCoS audit of every existing analogue licence;
- a firm relabelling deadline, with penalties for missing it;
- notified rapid-test methods for paneer and cheese;
- a national sampling drive run jointly with the states;
- a public register of licensed analogue manufacturers that any buyer, restaurant or consumer can check.
India is the world's largest milk producer. Its consumers trust that paneer and cheese are made from milk, and its farmers depend on that trust. FSSAI does not need another one-product ban to protect it. It needs to enforce the ones it already has, on every analogue, in every market, starting on the first day.
Without that plan, this notification is not regulation. It is a press release.
