Pan Masala explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Regulation 2.11 is a set of short standards for foods that fit no other chapter: baking powder (2.11.1), edible catechu (2.11.2), gelatin (2.11.3), silver leaf or chandi-ka-warq (2.11.4), pan masala (2.11.5), carob powder (2.11.7), dietary fibre from dextrin (2.11.8) and special dietary food with low sodium content (2.11.9). Regulation 2.11.6 is printed with its text omitted. Sweet makers, pan masala brands, bakers and gelatin users can start with FSSAI registration for food manufacturers.
This article reads the text as amended up to 20 December 2022 (FSSAI Compendium Version XXVI; later amendments to 10 July 2025 do not change regulation 2.11). Later notifications should be checked on fssai.gov.in. A compendium is a reference consolidation; the Gazette text prevails.
Silver leaf must have silver content of minimum 999/1000 fineness, a weight of silver foil of up to 2.8 gm per square metre, and must not be manufactured using any material of animal origin at any stage. Baking powder must yield not less than 10 per cent of its weight of carbon dioxide. Pan masala has two ash limits and may not contain added coal-tar colour. Low sodium foods carry a 120 mg/100 g limit and very low sodium foods 40 mg/100 g.
The standards one by one
| Clause | Product | Defining feature | Key parameters named |
|---|---|---|---|
| 2.11.1 | Baking powder | sodium bicarbonate, acid-reacting material and starch or another neutral material | carbon dioxide yield; moisture kept below 5% |
| 2.11.2 | Catechu (edible) | dried aqueous extract of the heart-wood of Acacia Catechu | loss on drying, water insoluble residue, alcohol insoluble residue, ash |
| 2.11.3 | Gelatin | purified product of partial hydrolysis of collagen from skin, connective tissue and bones of animals | moisture, total ash, sulphur dioxide, nitrogen |
| 2.11.4 | Silver leaf | food grade sheet of uniform thickness | foil weight, fineness, animal origin |
| 2.11.5 | Pan masala | food taken as such or with pan | total ash, acid insoluble ash |
| 2.11.6 | Omitted | ||
| 2.11.7 | Carob powder | powder from roasted carob pods | total ash, acid insoluble matter, tannin |
| 2.11.8 | Dietary fibre (dextrin, soluble fibre) | dextrinised starch glucose polymer | use at GMP; fibre claim thresholds |
| 2.11.9 | Special dietary food with low sodium | reduction or restriction of sodium | sodium per 100 g; label conditions |
Baking powder, catechu and gelatin
Baking powder (2.11.1) is a combination that yields carbon dioxide under baking conditions: a fine powder of sodium bicarbonate (INS 500(ii)) with a mixture of acidulants and an inert material such as starch, to keep moisture below the critical figure of 5%. The acidulants may be any one or a combination of twelve listed substances, including monocalcium phosphate, sodium aluminum phosphate, cream of tartar, tartaric acid, glucono delta lactone, calcium silicate (not more than 10%) and sodium acid pyrophosphate. The baking powder must be a white powder that flows easily and has no off odour, and when tested it must yield not less than 10 per cent of its weight of carbon dioxide.
Catechu (2.11.2) has a colour reaction with ferric ammonium sulphate, loss on drying not more than 16 per cent, water insoluble residue not more than 25 per cent, alcohol insoluble residue not more than 30 percent by weight, total ash not more than 8 per cent and ash insoluble in HCl not more than 0.5 per cent, with a higher figure of 1.5 per cent for bhatti katha.
Gelatin (2.11.3) is colourless or pale yellowish and translucent, in sheets, flakes, shreds or powder. The text bars more than 15 per cent moisture, more than 3.0 per cent total ash, more than 1000 parts per million of sulphur dioxide and less than 15 per cent nitrogen on dry weight basis. Gelatin from fish processing waste is separately standardised in our article on fish and fish products.
Silver leaf: 2.11.4
Food grade silver leaf (chandi-ka-warq) must be a sheet of uniform thickness, with no creases or folds, a weight of silver foil up to 2.8 gm/Sq meter and silver content of minimum 999/1000 fineness. It must not be manufactured using any material of animal origin at any stage, and must comply with the Contaminants, Toxins and Residues Regulations, 2011 and the labelling regulations cited in the clause. It is a regular input for sweet makers; see our overview of sweets and namkeen standards.
Pan masala: 2.11.5
Pan masala is food generally taken as such or with pan. It may contain betelnut, lime, coconut, catechu, saffron, cardamom, dry fruits, mulethi, aromatic herbs and spices, sugar, glycerine, glucose, permitted natural colours, menthol and non prohibited flavours. It may not contain added coal-tar colouring matter or any other ingredient injurious to health. The standards are total ash not more than 8.0 per cent by weight (dry basis) and ash insoluble in dilute HCl not more than 0.5 per cent by weight (dry basis). For the mandatory warning statement see our sister article on Schedule II, part 1, label declarations, and for the separate bars on tobacco and nicotine in food see our sister article on specific prohibitions.
Omitted regulation 2.11.6
The compendium prints 2.11.6 as omitted, with no text. No requirement can be read under that number.
Carob powder, dextrin fibre and low sodium foods
- Carob powder (2.11.7): powder from roasted carob pods (Ceratonia siliqua), with no husk and no artificial colouring, flavouring, extraneous matter or glazing substance. Total ash not more than 1.2 per cent, acid insoluble matter not more than 5 per cent and tannin not less than 0.1 per cent and not more than 0.15 percent.
- Dietary fibre (dextrin, soluble fibre) (2.11.8): a glucose polymer obtained by dry roasting acidified starch, with an average degree of polymerization of 12-25. It may be used at GMP in seven listed food groups, including breakfast cereals, noodles and pasta, spreads, snacks and bakery products. It must carry the label declaration of serial number (54) of sub-regulation 2.4.5 of the packaging and labelling regulations, and wheat or maize sources must be non-genetically modified. A "source of dietary fibre" claim needs not less than 3g/100g or 1.5g/100Kcal, and a "high source" claim not less than 3g/100g or 1.5g/100 kCal and not more than 6g/100g or 3g/100 kCal.
- Special dietary food with low sodium content (2.11.9): a "low sodium" food has sodium of not more than one half of that of the comparable normal product and not more than 120 mg/100 g; a "very low sodium" food, not more than 40 mg/100 g. Salt substitutes under clause (6) of 2.9.30 may be added within GMP. The label must carry the description "low sodium" or "very low sodium", the sodium content to the nearest multiple of 5 mg per 100 g and per serving, the carbohydrate, protein and fat content and energy value, the salt substitute added, total potassium where a potassium salt is used and the salt equivalent as sodium chloride. See our article on salt, seasonings and dried herbs for the salt substitute clause.
A practical example
Kesar Sweets buys silver leaf for mithai. Its purchase specification asks the supplier for a certificate of 999/1000 fineness, a foil weight within 2.8 gm/Sq meter and a statement that no animal-origin material was used at any stage. A brand selling a low sodium namkeen would first check the 120 mg/100 g ceiling and the "low sodium" description on the label.
Need help with these standards?
Our team can map your product to its clause and prepare the licence and label review through FSSAI registration for food manufacturers. The chapter on proprietary food follows in our article on regulation 2.12.
Key takeaways
- Silver leaf must be of minimum 999/1000 fineness and made without animal-origin material at any stage.
- Baking powder must yield not less than 10 per cent of its weight of carbon dioxide.
- Pan masala has ash limits and may not contain added coal-tar colour.
- Low sodium food is capped at 120 mg/100 g and very low sodium food at 40 mg/100 g.
- Regulation 2.11.6 is printed as omitted.
Read next
- Regulation 2.12: proprietary food
- Regulations 2.10.6 to 2.10.9: carbonated beverages, mineral water and packaged drinking water
- Sweets and namkeen standards
- Schedule II, part 1: mandatory label declarations
Disclaimer: Based on the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011 as consolidated in FSSAI's chapter-wise compendium (to amendment 83 of 21 October 2024) and the First Amendment Regulations, 2025, as consulted on fssai.gov.in on 2-3 October 2026. Later notifications and the Food Safety and Standards Act, 2006 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.