Guidance Note on Food for Special Medical Purpose (FMP) ‘The Authority hus observed that a large number of applications are being received for approval under the Food Safety and Standards (Approval for Non-Speciied Food and Food Ingeadients) Regulations, 2017(herein after referred as NSE Regulations) which are categorised or fall under FSMP under the Food Safety and Standards (Health Supplements, Nutraceuticals, Food for Special Dietary Use, Food for ‘Special Medical Purpose, Functional Food and Novel Food) Regulations, 2016 (herein after referred as Nutraceutical Regulations). Most ofthe FSMP formulations are made ‘up of one or more purified and well characterized ingredient(s) from a botanical source, fr a synthetic molecule having pharmacological activity, and are often formulated in tablets, capsules or liquids formats, Unlike drug which Is used to prevent or treat disease,FSMP is a special dietary formulationintended for supporting nutritional needs fof person with diseases or disorders through a food route. However, due to technological limitations of size/volume of the formats(tablets, capsules), these products do nat always meet the requirements of being nutritionally complete or even nutritionally incomplete category of PSMP. 2, Toprovide further clarity of on the FSMP products the following guidelines have been laid out: |L__ PSMP isa food formulation intended to provide nutritional support to persons \who suffer from a specific disease, disorder or a medical condition, as a part of their dietary management. Hi ‘These products cre to be used under the directions of a medical practitioner, with proper indication of the disease disorder or medical condition. lik These product(s) should be administered orally or using enteral route (nas0- gastric tube feeding} It Is a common practice to have these products in food formats including powder or liquid. iv, FSMP products should be either nutritionally complete food with a standard nutrient formulation, oF nutritionally complete food with a nutrient adopted formulation, or nutritionally incomplete food with a standard formulation or a nutrient adopted formulation. Thus, the FBO applying under NSF Regulations should clearly specify the FSMP categorythe product falls nto and the disease, disorder or medical condition for which itis intended along with the scientific and technical justification, The FSMP formulation shall also full partial or complete nutritional requirement of the intended individual The FBOs formulating the FSMP should preferably provide the product in a food format to deliver he desired benefit of nutrients to the target audience. ‘vi, FSMP formulation should Include essential nutrients such as carbohydeates/ proteins fats/vitamins/minerals/amino acids and other nutrients to contribute hutritional benefts to the end-user and they can customise the formulation based on the medical condition, disease and disorder ofthe target audience.vil si 3 SMP products,ray have nutrients at levels higher than the Recommended Dally Allowance (RDA), but not exceeding the limits of vitamins and minerals as specified in Schedule Ilof the Nutraceutical Regulations. Formulation with vitamin or mineral singly or in mere combination, within RDA, or exceeding the ‘mits of RDA, shall nt be considered as FSMP. Formulations, containing vitamin or mineral singly or in mere combination up to the Tolerable Upper limit (TUL) sa drug and shall not be classified under FSMP, SMP formulatien with a single molecule/ chemical with pharmacological activity in a format like tablet, capsule and liquid shall not be accepted by the Authority a food, as such a formulation is akin toa drug Label ofthe FSMP products shal specify the statementssuch as ‘RECOMMENDED ‘TO BE USED UNDER MEDICAL ADVICE ONLY" and “For the dietary management of ___"(the specific disease, disorder or medical condition for which the product is intendad, and shown tobe effective). Ie Is the responsibility of the FBO to ensure that there are no potential Interactions amongst a combination of ingredients leading to adverse impact on stability, bloavafability, safety, and efficacySuch combinations should be Aavoldedthat otherwise can potentially be antagonistic to functional outcome of the product ‘The examples of aroducts falling under PSMP category are dietary formulations for weight reduction and intended as total replacement of complete diet: persons suffering from metabolic disorders including food protein allergy, gastrointestinal dsorders ete Examining FSMP applications under NSF Regulations: Considering the above clarifications/quidelinesthe Authority shall critically examine the products potentially falling under FSMP categories with one or more ingredients of botanicals, herbs and Ingredients of animal orgin.which may also have a drug like activity, to determine Whether these products would be best suited under food regulations or drug regulations, In cases of ambiguity, the Authority will err on the side of caution and categorise such ingredients /produets to be more akin to drug, Theit use will not be Permitted under Food Safety and Standards Regulations, as anabundant caution to protect consumers 4 Further, the following table has been developed to distinguish diferent categories of products covered under Nutraceutical Regulations:Health supplement ‘Nutraceutical bu EMP Description Health supplementsare intended to supplement the normal diet of @ person, with concentrated sources of one or more nutrients with known mutetional oF beneficial physiological fect, Health supplements may be preferred when the normal diet is not enough to meet the nutrient requirements Wutraceuticals are naturally ‘ceurring ingredients that are extracted, isolated and purified from food or non- food sources.The consumption in measuredamounts, provides physiological benefit and help maintain good health Foods for Special Dietary Uses (FSDU) are foods specialy processed or formulated "to satisiy particular dietary requirements for certain physiological or specific health conditions. Foods for Special Medical Purpose (FSMP)are foods Intended for exclusive or Partial feeding of people With limited orimpaired capacity to digest, absorb, metabolize ordinary food stuff and whose nutritional requlrements cannot be met by normal foods, These foods shall be used only under medical supervision. Such foods can either supplement or replace the diet entirely to provide patients with the essential mutrientsthat they eed to survive and recover ‘Age group “Applicable for 5 years and above Applicable for 2 years and above ‘Applicable for 2 years and above ‘Applicable for 2 years and above ‘Target population Healthy individuals Healthy individuals ‘Specific Physiological Conditions:For individuals like sports persons, pregnant and lactating women, aging Population etc Specific Health Conditions-Underwelght, ‘obesity, hypertension "and Persons with specifi disease, disorder or medical conditions with limited corimpaired capacity to digest, absorb, metabolize ordinary food stuff and ‘whose dietary management cannot be achieved only by modification of the normal‘ellactisease population ete iat, by food Tor specifi nutritional use, ora combination of them, Purpose/Intended | To boost theoverall health |For Supplementation of | Customised as per the target] Customised as per the target use and energy in Healthy | botanicals, herbs and audience to meet the | audience(diagnosed with individuals ‘and | nutrients to support health | particular dietary different disease condition) forSupplementation of | functions. requirements to provide nutritional nutrients such as proteins, supports. vitamins, minerals ete. in Iemay bea other group of people. 41) Nutritionally Complete Formulation 2) Nutritionally Incomplete formulation Direction ofuse | Tobe taken orally Tobe taken orally To be taken orallyor|To be taken orally or throughtube feeding through tube feeding with mandatory ‘medical supervision Duration ofuse | Daly intake as given in the | Daly Intake as given in the | Daly intake as given in the | Shall be used for the specific label ofthe pack label ofthe pack label of the pack orfor the | duration as advised by specific duration as advised | doctor or clinical dietician _by doctor or clinical dietician Format/Matrix | Capsules, — tablets, pills | Granules, powder | Granules;capsules, tablets, | Food format. At present, the sachets; jelly or gel, semi- solids andother similar forms of liquids and tablet.capsule, liquid, ely or gel, semi-solids and other formats pills, Jel, semi-solid and ‘other similar forms, sachets of powder, or any other ‘most common dosage forms are powder and liquid as other formats are not powders or other form similar forms of liqulds and | suitable to deliver the powders required dietary nutrients, Does the product to | No No be taken under medical advise May or may notbe Based on the product formulation as declared by the FBO in the label, Yes (strictly under medical advice)1s claim regarding health function is allowed? ves Yes Yes No. Can the labelling, presentation and advertisement mention that this product has the property of| preventing, treating or curing a human disease, or refer to such properties. No Ne No Level of nutrients allowed Tess than one RDA Tes than one RDA May go beyond one RDA but have’ to comply with Schedule Ill of the Nutraceuticalregulations ‘May go beyond one RDA but have to comply with Schedule Il of the Nutraceutical regulations Formulations containingmere combination of vitamins and ‘minerals in tablets, capsules, syrup formats No No No No Formulations made fon Single vitamin and mineral No No Formulations made on Single bioactive based products in tablet, capsule or No Maybe Wo WeTigi Can the formulation | No No No No contain hormones or steroids or psychotropic ingredients Examples Protein Formulation made out of [Meal replacement products | Nutritionally complete supplements.vitamin and ‘mineral formulationswith food components intended for general population. plant or botanical extracts or other ingredients specified under Schedule VI ofthe regulations intended for slimming/weight ‘management/weight control products, sport supplements, specifically designed dietary formulation for pregnant and lactating women, geriatric population, celiac disease, ete food with standard nutrient formulation Food specially prepared for ‘weight reduction and Intended as total replacement of complete diet, People suffering or recovering from serious illness such as patients recovering from stroke or severe food allergies, for patients with trauma, Infection and surgery, | ‘enteral formulas for | gastroenterological | conditions Nutritionally complete food with nutrient adopted formulation Special dietary formulas for persons suffering from chronic metabolic disorders including food proteinallergy, fatty acid metabolism, gastrointestinal disorders, kidney disease, McT (Medium — Chain ‘Triloerides) containing formulas for malabsorption conditions, patients with inflammatory bowel disease ete. Nutritionally incomplete food with standard formulation or a nutrient adopted formulation For persons suffering from ‘acute metabolic disorders, ‘gastrointestinal disorders, kidney disease,protein substitute for metabolic conditions ete. Ingredient Schedules applicable TH W, only enaymes listed inv Vil, VI ULI, VL, Vil Vil(Primarily products based on schedule vy) TUL IV, ViVi, vit 1.1, I, enzymes listed in WI vi, vit ‘Additive Schedules applicable Vi, VE, and VF (only for tablets/capsules/syrups) VA, VE, and VF (only for tablets/capsules/syrups) VB, VE, and VF (only for tablets capsules/syrups) VG, VD (weight reduction products), VE, VF (only for ‘Tablets/capsules/ syrups) Note: The definition and the requirements ofthe FSMPand other categoriesincluding the labeling can be referred from Nutraceutical Regulations which is available on FSSAI website wwwfssai gov in. Link for accessing the same is hitps://fssi.gov.in/ems/food-safery- ‘and-standands-regulations.php, Frequently Asked Questions (FAQs) on the said regulations is also available at FSSAI website and link foraccessing’s the sames_https://ssaigov.in/cms/standardsfaa php