Quick answer
- Selling on marketplaces (Amazon, Flipkart, blinkit) → no e-Commerce KOB. FSSAI’s definition excludes marketplace sellers. You are licensed on your own turnover — Registration at ₹100/yr up to ₹1.5 crore.
- A catalogue website with no checkout → a storefront, not a platform. The KOB attaches to platforms used “for transaction or sales.” No payment on the site, no transaction on the site.
- Payment taken on your own website → the e-Commerce KOB applies. That is the line, and it is a clear one.
- Upgrading later doesn’t change your 14-digit number, so starting under Registration costs you nothing in reprinted labels.
Why is everyone telling small sellers to buy a Central Licence?
Because two different things are being collapsed into one, and because the people publishing the advice are usually the people selling the licence.
Search this question and you will find page after page stating that all online food sellers — including home kitchens and single-product brands — require a Central Licence regardless of turnover. Some of those pages also still quote the old ₹12 lakh and ₹20 crore thresholds, which were replaced on 1 April 2026 by ₹1.5 crore and ₹50 crore. If a page has not caught up with a change that took effect this April, treat its conclusions carefully.
The deeper error is a category error. FSSAI regulates an e-commerce food business operator — the entity that runs the platform. That is Amazon. That is Flipkart. That is a food delivery app. It is not the person selling six jars of jamun honey through someone else’s platform. Conflating the two turns a rule aimed at national marketplaces into a ₹7,500 annual charge on a founder with one SKU.
It also has a commercial logic. Most of these pages belong to compliance agencies whose business is filing applications. A Central Licence is a larger filing than a ₹100 Registration.
Annual fee for basic FSSAI Registration versus a Central Licence — a 75× difference, before you count the documentation, the inspection and the months of waiting. Knowing which one your model actually requires is worth an afternoon of reading.
FoSCoS Kind of Business Eligibility, updated 01.04.2026Does selling on Amazon or Flipkart need a Central Licence?
No. FSSAI’s own definition of an e-commerce entity is a person or company that “owns, operates, or manages a digital or electronic facility or platform for electronic commerce” — and it expressly states that this does not include a seller offering goods for sale on a marketplace e-commerce entity.
Read that plainly: the marketplace is the e-commerce FBO. You are a seller on it. Amazon holds the e-commerce licence for the platform; you hold whatever your own activity and turnover require. For a honey brand under ₹1.5 crore working with a co-packer, that is basic Registration under the Relabeller category — ₹100 a year. The full breakdown of which KOBs a honey brand needs is here.
FSSAI goes one step further in the same direction: individual sellers do not need a separate licence for a warehouse or fulfilment centre that the platform has already licensed. If you use Amazon’s fulfilment network, that facility is Amazon’s compliance obligation, not yours.
Is a website an e-commerce platform if it doesn’t take payment?
Our position, stated plainly: no. A site that displays your products without taking payment is a storefront, and a storefront is not a platform for transaction or sales.
The regulation keys on activity, not on the existence of a web page. FSSAI defines the e-commerce category around platforms used “for transaction or sales,” and it has separately confirmed that platforms which only provide listing or directory functions — showing products and pointing people onward — are not required to obtain a licence. The common thread is that display is not commerce. Commerce is the transaction.
So consider what a small Indian honey brand actually runs. A website with photographs, varietal descriptions, the sourcing story, prices, and a button that opens WhatsApp. The buyer messages. You confirm stock, quantity, delivery. They pay by UPI or bank transfer. You ship. Every element of the sale — offer, acceptance, payment — happened off the website. The website did what a printed catalogue or a shop window does: it created interest.
Calling that an e-commerce platform would mean any business with a price list on the internet is running one. That is not what the category was written for, and it is not how the definition reads.
It is also worth saying that this is not a contrivance invented to dodge a fee. Catalogue-plus-WhatsApp is the dominant way food and ingredient business gets done in India, ours included. Most B2B honey enquiries in this country arrive as a WhatsApp message about a page someone looked at. The structure came first; the licensing question came second.
Where is the line, exactly?
Payment on your own site. Add a cart, a checkout and a payment gateway, and you are operating a platform for transaction and sales — the e-Commerce KOB applies, and on the current FoSCoS eligibility grid that sits in the Central Licence band irrespective of turnover.
That line is clear, and we would advise anyone to respect it. Running a checkout while declaring you have no e-commerce activity is not a structural argument — it is a misdeclaration, and it is the one version of this that will actually cause you trouble. The point of understanding the boundary is to choose which side of it you want to be on, deliberately, with your eyes open.
| How you sell | Does the e-Commerce KOB apply? | What you need |
|---|---|---|
| Marketplaces only — Amazon, Flipkart, blinkit | No — marketplace sellers are excluded from the e-commerce definition | Registration up to ₹1.5 Cr (₹100/yr) |
| Catalogue site, orders and payment off-site (WhatsApp, call, transfer) | No transaction occurs on the site — our reading is that it does not apply | Registration up to ₹1.5 Cr (₹100/yr) |
| Your own site with cart and payment gateway | Yes | Central Licence band (₹7,500/yr), any turnover |
| Social selling — Instagram or WhatsApp catalogue, payment by transfer | No platform of your own is being operated | Registration up to ₹1.5 Cr (₹100/yr) |
How do you make your position unarguable?
Ask, in writing, and keep the reply. FSSAI has not published a clarification dealing specifically with a brand’s own catalogue site that takes no payment. Our reading of the definitions is set out above and we think it is sound — but a reading is not a ruling, and different state officers can take different views.
The fix is free and takes an afternoon. Write to your state licensing authority or the FoSCoS helpdesk, describe your setup in specific terms — products displayed on your own website, no cart, no payment gateway, orders confirmed and paid off-platform — and ask which Kinds of Business you are required to endorse. Keep the reply with your registration papers.
A founder holding that email is in a completely different position from one relying on a blog post. If the answer comes back saying the e-Commerce KOB is required, you have learned it for the price of an email rather than a penalty notice. If it confirms your reading, you have documentation that settles the question for years. Either outcome beats guessing, and this is exactly the kind of paperwork discipline that also protects you from the credentials trap we describe in the main FSSAI guide — register the FoSCoS account yourself, and keep your own login.
What does the sensible sequence look like?
Start where the rules are simple, and add complexity when the business earns it. For most first-time honey founders that means:
- Register under your actual activities — Relabeller if a partner makes your honey, plus Retailer or Distributor as applicable. ₹100 a year, roughly a week to approve.
- Sell through marketplaces, retail, gifting and direct enquiry. Catalogue site plus WhatsApp. This is where you find out what actually sells — and it is a real business, not a rehearsal.
- Add your own checkout when the numbers justify it. When D2C margin genuinely beats marketplace commission, the E-Commerce KOB and its fee become a rational cost rather than a barrier to entry.
And the reassuring part: your 14-digit FSSAI number does not change when you upgrade. Same number on the labels, higher category on the certificate. Sequencing costs you nothing in reprinted packaging — which is worth knowing, because label reprints are one of the real costs in a honey launch.
None of this is about dodging compliance. It is about not buying a licence written for national marketplaces before you have sold your first hundred jars. The regulation has a shape; a small brand should sit where that shape actually puts it.
The short version
- Marketplace sellers are expressly excluded from FSSAI’s e-commerce definition. Selling on Amazon does not require a Central Licence.
- A catalogue website that takes no payment is a storefront. The e-Commerce KOB attaches to platforms used for transaction or sales — and FSSAI has confirmed listing-only platforms need no licence.
- Taking payment on your own site does trigger the KOB, which sits in the Central Licence band at any turnover. Respect that line — don’t run a checkout undeclared.
- FSSAI hasn’t ruled on the catalogue case specifically. Get your setup confirmed in writing by your licensing authority and keep the reply.
- ₹100 vs ₹7,500 a year, and your 14-digit number never changes when you upgrade — so start simple and add the checkout when the business justifies it.
This article sets out how we read FSSAI’s published definitions from a supplier’s seat, with links to the source documents. It is operational guidance, not legal advice, and FSSAI has not issued a clarification on the catalogue-without-payment case — confirm your own position with your licensing authority before you rely on it.