In-Store Repacking: Label Requirements and Lot Records

Where repacked stock loses its history

Picture the back room of a typical neighbourhood supermarket on a slow afternoon. A staffer has a sack of toor dal, a weighing scale, a heat sealer and a roll of printed stickers. An hour later there's a crate of neat store packs on the trolley, and the empty sack is already in the scrap pile.

That empty sack was the only thing that knew where the dal came from. It had the miller's name, their lot number and their best-before date. Once it's gone, your store packs carry whatever date the sticker printer was set to that morning, and nothing links them back to the source.

You won't notice anything wrong until a customer finds weevils, a supplier announces a recall, or an inspector picks up a pack and asks which bag it came from. Then you find out nobody can answer.

Why the date goes wrong

The mechanism is simple. Repacking feels like handling, not manufacturing, so staff date the packs by the day they were filled. "Packed today, best before six months from today" is the default on the label template, and nobody changes it.

But the dal didn't get any younger in your back room. If the sack already sat in the miller's godown and then in your store room for a couple of months, a best-before counted from packing day pushes the date past what the original packer promised. You've just extended shelf life on paper, and the pack is now carrying a claim you can't back up.

The other failure is mixing. When half a sack of almonds is left over, someone tops it up from a new sack and keeps packing. Now one batch of store packs holds two supplier lots with two different dates, and your label shows only one of them.

What the pack label has to carry

Once you seal loose goods into a pack for sale, you're the packer, and two sets of rules apply. The Legal Metrology (Packaged Commodities) Rules, 2011 ask for declarations on every pre-packed commodity, including:

• name and address of the packer
• common or generic name of the commodity
• net quantity in standard units
• month and year of packing
• retail sale price (MRP, inclusive of all taxes)
• consumer care contact details

The same Rules also ask packers to register with the state Legal Metrology department, so check your registration is in place before the sticker roll goes into the printer.

On the food safety side, the FSSAI Food Safety and Standards (Labelling and Display) Regulations, 2020 add their own fields. These include the name of the food, the FSSAI logo and licence number, the veg mark, a lot or batch identifier, the date of packing, and a best-before or use-by date. Exemptions apply to some single-ingredient products, so check the current text of the Regulations for your exact items. Our post on FSSAI date labelling rules for food retailers goes through the date fields in more detail.

The lot field is the one stores skip, and it's the one that makes everything else traceable.

The repacking log

The fix is one log, filled in at the bench, with one row per repacking batch. A batch is everything filled from a single source bag in one go. Columns:

• Store lot code: the code you print on each pack
• Date packed
• Product and pack size
• Supplier name and invoice reference
• Supplier lot number: copied off the sack before it's opened
• Supplier best-before: also copied off the sack
• Store best-before on the pack: must be on or before the supplier date
• Packs produced and loose weight left over
• Packed by and checked by

Two house rules make it work. First, one source lot per store lot, always. If you top up from a new sack, start a new row and change the sticker. Second, tear the supplier label off the empty sack and staple it to the log page, or photograph it into the same folder. That gives you physical proof of the source.

If you'd rather start from a sheet than a blank page, the expiry-tracking spreadsheet template has the date columns already set up, and you can add the supplier-lot columns next to them.

Dating by source lot

This is the rule that matters most. The best-before on the store pack comes from the source bag, not from the packing day. The packed-on date is the day you sealed it. The best-before is the earlier of two things: the supplier's own best-before, or your own shorter limit for that product once it's opened and repacked.

Products that pick up moisture or insects once the sack is open, like rice, dal, cashews and raisins, may deserve a store limit that's shorter than the supplier's date. That's your call, and you should write it down per product so it doesn't change with whoever is on the bench. It's never a reason to go longer than the supplier date.

A worked example: one bag of toor dal

Worked example. Say you receive a sack of toor dal on 2 June whose label reads supplier lot TD-447, best before 30 November. You set a house limit of four months from packing for opened dal. On 10 August you open the sack and fill one-kilo packs.

• Packed-on date: 10 August
• Four months from packing would be 10 December
• Supplier best-before is 30 November
• So the store best-before is 30 November, the earlier of the two

The log row reads store lot R-0810-01, supplier lot TD-447, supplier best-before 30 Nov, store best-before 30 Nov, with the pack count and leftover weight. If the miller ever calls about TD-447, you search the log, find R-0810-01, and pull exactly those packs off the shelf. Nothing else needs to come down.

Had the label been dated from packing day, those packs would carry 10 December. That's ten days past what the miller would stand behind.

Running it on paper versus a system

A bound notebook or printed sheet at the repacking bench works if one or two people do all the packing and the log never leaves the room. It handles the core job: tying store lot to supplier lot and keeping the date honest.

Where paper struggles is lookup and rotation. Finding every store lot from one supplier lot means flipping pages. Paper also won't tell you that three store lots of cashews are getting close to their date while newer packs sit in front of them on the shelf. The same discipline applies in other aisles, as the pickle, papad and spice aisle guide shows. Once store-packed SKUs run into the dozens, a searchable record that knows each lot's date starts paying for itself. The batch and lot traceability setup guide walks through how to structure lot codes so they survive that move.

Getting started at your store

Start small and make it routine:

• Print the log sheet and put it next to the sealer, with a pen tied to it.
• Rewrite the label template so the best-before field is filled in by hand from the log, not calculated automatically from today's date.
• Write down a house limit per repacked product.
• Ban topping up from a second sack without starting a new lot.
• Once a week, check one random shelf pack against the log to confirm the lot code finds its source.

If you'd like expiry tracked in a system rather than a binder once the log outgrows paper, ShelfLifePro serves supermarkets and grocery stores. You can see how it fits your back room on the supermarket page, and every plan has a 14-day free trial, no credit card required.