Administrative & Applicant Documents

Getting the Foundation Right Before a Single Technical Page Is Written

By Dr. Ashwini Kumar

Founder & CEO, CE Group of Companies  |  Forbes Business Council Member

Regulatory Affairs Expert | Clinical Trials Advisor | Medtech & Food Regulatory Consultant

Why Administrative Documents Sink More Applications Than Science Does

There is a widely held assumption in the Food regulatory world that NSF applications fail because of inadequate toxicology data or weak safety evidence. In practice, a significant proportion of applications are returned, delayed, or rejected at the very first scrutiny stage — before the Scientific Panel even sees the science — because of administrative errors.

A missing board resolution. An expired FSSAI license. An IEC that belongs to the importer but was not included. A Form I filed via email after the June 2026 e-PAAS deadline. These are not complex scientific failures. They are process failures — and they cost the same ₹50,000 application fee and the same timeline as any other rejection.

This article covers Section A of the NSF dossier: the administrative and applicant documents that form the legal and institutional foundation of your application. Get this right before a single technical page is written.

The e-PAAS Transition — The Most Important Administrative Change of 2026

From 1 June 2026, FSSAI’s e-PAAS (Electronic Product and Claim Approval Application System) portal is the only accepted submission channel for NSF applications. FSSAI will reject all applications submitted via email, physical courier, or any offline method from this date.

For foreign Businesses and their Indian regulatory partners, the e-PAAS transition has two practical implications. First, your organisation must be registered on e-PAAS before the application can be filed — this registration is a separate step from the FoSCoS license portal. Second, your entire dossier must be structured and formatted for digital upload, with clearly bookmarked PDF sections corresponding to each part of the application form.

 

e-PAAS Portal: epaas.fssai.gov.in — Register your organisation and authorised signatory before beginning dossier preparation. Portal registration can take 3–5 working days.

 

The Section A Document Checklist

The table below covers every administrative document required for an NSF application, with applicability and expert notes for each:

 

#	Document	Applies To	Expert Note
A1	Completed Form I (ingredient) via e-PAAS portal	All applicants	e-PAAS mandatory from 1 June 2026. Paper / email submissions rejected outright.
A2	Online payment of ₹50,000 on ePAAS portal	All applicants	Non-refundable.
A3	Valid FSSAI Central License or Import License	All applicants	Must be current at filing date. Expired license = automatic rejection at scrutiny stage.
A4	Certificate of Incorporation / Company Registration Certificate	All applicants	Notarised and apostilled if issued by a foreign authority. Translated to English if in another language.
A5	Authorised Signatory declaration / Board Resolution / Power of Attorney	All applicants	Must name the specific individual signing the application. Board resolution required for company applicants.
A6	Import Export Code (IEC) — issued by DGFT	Importers only	Mandatory prerequisite for all import-category NSF applications. Apply via DGFT portal if not yet obtained.
A7	India Authorised Agent / Importer appointment letter	Foreign Businesses	FSSAI requires a named India-based regulatory contact. This entity is jointly accountable for post-approval compliance.

Table 1

The Three Documents Foreign Businesses Most Frequently Get Wrong

A4 — Certificate of Incorporation

For Indian applicants this is a routine MCA document. For foreign Businesses it is often the most administratively complex document in the set. FSSAI requires the document to be notarised in the country of origin and apostilled under the Hague Convention (or attested by the Indian Embassy / High Commission for non-Hague countries). If the certificate is not in English, a certified English translation must accompany it. Many foreign OEM applications are returned because the certificate is provided as a simple PDF copy without notarisation.

A5 — Authorised Signatory and Board Resolution

The authorised signatory declaration must name a specific individual — not a job title, not a department. The same individual must be the one who signs the application form on e-PAAS. Where the applicant is a company, a board resolution explicitly authorising that individual to sign FSSAI applications on behalf of the company must be submitted. A generic power of attorney without specific reference to FSSAI applications is sometimes rejected at scrutiny.

A7 — India Authorised Agent for Foreign Businesses

This is the document that most foreign businesses leave to the last moment — often because the commercial decision about who the India importer or agent will be has not been finalised. FSSAI requires this appointment to be in place at the time of filing. The appointment letter must identify the agent by company name, address, and FSSAI license number, and must explicitly state that they are authorised to act as the Indian regulatory representative for the applicant’s NSF application.

Selecting your India agent is not just a commercial decision. It is a regulatory one. The agent’s FSSAI compliance track record, their familiarity with the e-PAAS portal, and their ability to respond to FSSAI queries in a timely manner directly affect your application timeline. IBH (Innovation Bridge Healthcare) provides authorised agent services for foreign Businesses as part of our India market entry platform.

Administrative Checklist — Before You Hit Submit

• e-PAAS organisation registration complete and authorised signatory verified
• Form I fully completed on e-PAAS
• Online payment of ₹50,000 on ePAAS portal.FSSAI Central / Import License valid and current
• Certificate of Incorporation notarised, apostilled, translated (foreign Businesses)
• Board resolution naming authorised signatory prepared and signed
• IEC obtained and copy included (importers)
• India authorised agent appointed and appointment letter signed

 

How CliniExperts Can Help

CliniExperts and Innovation Bridge Healthcare (IBH) provide end-to-end NSF dossier preparation and FSSAI e-PAAS filing support. Whether you need a pre-filing gap analysis, full dossier build, or Scientific Panel query management — our regulatory team is here.

Connect: www.cliniexperts.com  |  innovationbridgehealthcare.com  |  Forbes Business Council Member | contact@cliniexperts.com