Quarterly Expired-Stock Report: What Manufacturers Owe FSSAI

The filing most licensed manufacturers quietly ignore

The FSSAI advisory of 16 December 2024 made one thing very clear: licensed manufacturers, repackers, relabellers and importers must file a quarterly report of expired and rejected stock — by batch, with disposal action — through the FoSCoS portal. Not annually. Not when convenient. Every quarter.

Yet walk into most mid-size repacking units and you'll find a shelf of tattered registers, a WhatsApp group where the supervisor announces "that batch is done," and zero structured record of what happened next. When an inspector arrives — and after Reuters reported in September 2026 that Maharashtra alone saw 3,000+ raids since May, inspectors are arriving — that shelf of registers is not going to save you.

This post is for the compliance manager, the factory owner and the quality head: what the 16 December 2024 advisory asks for, what the underlying stock record needs to look like, and where the FoSCoS upload fits in.

Who this rule actually applies to

Let's be precise, because this is where a lot of operators get confused.

The quarterly expired-stock report under the FSSAI advisory (16 Dec 2024) binds licensed manufacturers, repackers, relabellers and importers. If you hold an FSSAI manufacturing or repacking licence, this is your obligation.

Retailers and supermarkets are in a different position. The FSS (Licensing) Regulations 2011, Schedule 4 stock-rotation rules bind manufacturers — and the January 2026 draft amendment expressly excludes retailers from the stock-rotation requirement. That does not mean retailers can sell expired stock; inspectors seize it and publish the results. But the quarterly FoSCoS filing is not a retailer obligation.

If you run a repacking unit that also operates a wholesale front, you are a manufacturer for this purpose. File accordingly.

What the quarterly report must contain

The 16 December 2024 advisory asks for expired and rejected stock by batch, with the disposal action taken. A record that stands up when an inspector reads it alongside your stock count carries, for each batch:

• Batch/lot number — every expired or rejected batch listed separately
• Product name and SKU
• Manufacture date and expiry date
• Quantity received into the batch and quantity remaining at expiry
• Reason for rejection — expired, contaminated, temperature excursion, pest damage, recall, or other
• Disposal action taken — destruction, return to supplier, or donation (with recipient)
• Date of disposal
• Evidence of disposal — destruction certificate, supplier return acknowledgement, or donation receipt

Picture a repacker handling 40 SKUs across three production lines. In a given quarter, maybe six batches expire unsold and two are rejected mid-run for quality. That's eight rows in the report. If your damage log is current, pulling those eight rows takes minutes. If it isn't, you're reconstructing from memory and WhatsApp messages the night before the deadline.

The record you need before you can file

The FoSCoS upload is the last step, not the first. The work is in maintaining the underlying batch record throughout the quarter. Here's what that record needs to capture, in real time:

At receipt:

• Supplier name, invoice number, lot/batch code
• Manufacture date, expiry date, best-before date
• Quantity and pack size

Under the FSS (Food Recall Procedure) Regulations 2017, reg 6(1), these distribution records must be kept for one year past the expiry date of the batch. That's not a suggestion.

During storage:

• Segregation of rejected or recalled stock from saleable stock — physically separate, clearly labelled
• Temperature logs for cold-chain items, with excursion notes
• Any damage events: contamination, pest, temperature break, water ingress

At disposal:

• Reason (expired, contaminated, recalled, rejected)
• Action taken
• Date
• Supporting document (destruction cert, return note, donation receipt)
• Photo evidence where possible

Without this running log, the quarterly report becomes a guessing exercise. And a guessed report is worse than no report — it creates a paper trail that contradicts your physical stock count.

The FoSCoS upload: honest about what it is

FoSCoS is the Food Safety Compliance System — the FSSAI portal where licensed businesses file returns, update licences and submit reports.

Here is the honest part: the FoSCoS upload itself is manual. You log in to FoSCoS and enter or upload your batch data yourself. No software — including ours — does that upload for you. What software can do is maintain the underlying batch record so that when you sit down to file, the data is already structured and accurate.

If you're exporting a clean batch-level damage log — batch number, dates, reason, action, quantity — the manual upload takes an hour, not a day.

What happens when you don't file — or file wrong

The Reuters report from September 2026 described a Navi Mumbai warehouse caught relabelling expired stock of major FMCG brands with fake expiry dates for export. Roughly US$80,000 of stock was seized. That is the extreme end. But the enforcement direction is clear: FSSAI tests over 100,000 samples a year, roughly 1 in 5 come back unsafe, substandard or mislabelled, and about 8,000 food business licences have been cancelled in three years.

For a manufacturer or repacker, a missing or inconsistent quarterly report is a direct compliance gap — not a technicality. Under the FSS Act 2006, section 59, selling unsafe food carries penalties up to six months and Rs 1 lakh where no injury results, and up to life imprisonment where death results.

More practically: if a recall happens and you cannot produce the batch distribution record within 24 hours (as required by FSS (Food Recall Procedure) Regulations 2017, reg 6(3)), the quarterly report becomes the inspector's first question. If it's missing, you've already lost the argument.

For a broader look at what inspectors actually check when they walk in, see what FSSAI inspectors look for at food businesses.

Building the habit: a practical quarterly rhythm

The filing deadline follows the quarter end. Most businesses scramble in the last week. The operators who don't scramble run a simple monthly sweep instead:

• Month 1 and 2: damage log updated in real time; any expired or rejected batch recorded on the day it's identified, with reason and action
• Month 3, week 1: pull all damage log entries for the quarter; cross-check against physical stock count
• Month 3, week 2: verify disposal evidence is attached to each entry
• Month 3, week 3: format the export for FoSCoS and do the manual upload

That's it. The quarterly report is not a separate exercise — it's the output of a running record.

For the traceability framework that underlies all of this — how batch records connect receipt to dispatch to recall — the batch and lot traceability setup guide covers the full structure.

What a nightly sweep and damage log actually do for you

One practical tool: a nightly automated sweep that marks expired batches, writes a costed wastage record, and logs the reason and action. The disposal record writes itself — each expired batch gets a timestamped entry with quantity, cost, and reason. At quarter end, you filter by date range and export.

That export is the raw material for your FoSCoS filing. You still do the upload. But you're not reconstructing from memory.

ShelfLifePro's damage log and nightly sweep work this way across its food verticals. If you want to see the batch record in action before committing, a 14-day free trial, no credit card required is available.

For operators who want to start building the paper trail before any software decision, the distributor expiry claim register — built for tracking expiry credits and returns by batch — is a practical starting point for structuring batch-level disposal records.

The short version

If you hold an FSSAI manufacturing or repacking licence:

• File a quarterly expired and rejected stock report through FoSCoS — by batch, with disposal action
• Keep the underlying distribution records for one year past each batch's expiry date
• Segregate rejected stock physically and document it on the day, not at quarter end
• The FoSCoS upload is manual — no software does it for you, but a clean damage log makes it fast
• A missing or inconsistent report is a direct compliance gap, not a paperwork formality

The crackdown is not slowing down. The operators who come through it cleanly are the ones whose records were already in order.