Centre for Health Equity, Advanced Study Institute of Asia (ASIA) | August 2026

The Centre for Health Equity (CHE), Advanced Study Institute of Asia (ASIA) has released a briefing note, “Analogue Paneer in India: A Food-Systems Threat to Health Equity,” examining concerns around dairy analogues sold or served as paneer, with a focus on consumer protection, food safety, nomenclature, testing, enforcement and health equity.

The briefing note begins with an important distinction. The concern is not with the lawful manufacture or sale of dairy analogues as such. Rather, the concern arises when products that are not recognised as milk or milk products are represented, supplied or served as conventional paneer without clear and adequate disclosure. This can prevent consumers from making informed choices about the identity, composition and nutritional characteristics of the food they purchase or consume.

What are dairy analogues?

FSSAI defines a dairy analogue as a product in which constituents not derived from milk replace some or all milk constituents, while the final product resembles a milk product in its sensory or functional characteristics. FSSAI also explicitly states that dairy analogues are not considered milk, milk products or composite milk products.

The January 2026 FSSAI Food Safety and Standards Digest describes analogue paneer as being made using ingredients including vegetable oils and fats, starches, milk solids, plant proteins, stabilisers, emulsifiers and artificial flavours, followed by curdling with common acidulants. The resulting product can mimic the appearance and texture of paneer while having a different nutritional profile.

This leads to a central question examined in the briefing note: if FSSAI does not recognise the product as paneer or as a milk product, should “paneer” remain part of its name?

FSSAI’s April 2025 Consultation Paper acknowledged the nomenclature issue and suggested terms such as “Non-dairy” or “Analogue” before the dairy term, while noting that the terminology was suggestive and subject to consultation. The briefing note therefore asks whether such qualifiers provide sufficient clarity or whether a distinct nomenclature may be necessary to reduce consumer confusion.

The scale and enforcement challenge

The briefing note notes that there is no reliable publicly available, standalone figure for the size of the analogue-paneer trade. Available testing and enforcement findings provide indications of the problem, but the figures should not be interpreted as representing the size of the analogue-paneer industry.

In Maharashtra, 109 of 308 paneer and dairy-analogue samples tested between April 2025 and March 2026 were reported as non-compliant, including 79 classified as sub-standard and 30 as unsafe. The briefing note also records state-level action in Maharashtra, Chhattisgarh and Gujarat. At the same time, the available evidence on analogue-specific testing and enforcement remains uneven across States and Union Territories. The briefing note highlights the layered nature of enforcement: State Food Safety Officers undertake field sampling, laboratories conduct confirmatory analysis, and FSSAI establishes standards and test methods and coordinates national surveys. Differences in staffing, laboratory capacity and technical capability can affect the ability to identify violations consistently.

Why this is a health-equity issue

The report frames analogue paneer not only as a food-regulation issue but also as a question of health equity and informed consumer choice.

Consumers cannot reasonably be expected to determine through ordinary observation whether a product described as paneer contains milk-derived constituents. Where composition is not disclosed and enforcement is inconsistent, consumers with fewer opportunities to access information may be less able to avoid products they would not knowingly purchase.

The briefing note also emphasises the need for caution around health claims. It does not establish that analogue paneer itself causes cardiovascular disease, nor does it assume that all analogue products have harmful levels of trans fat, saturated fat or sodium, or lower protein than conventional paneer. Such differences depend on the formulation and require comparative testing.

The immediate concern, therefore, is also one of transparency and informed choice: consumers should be able to know what they are buying or being served and understand its composition and nutritional characteristics.

The report concludes that the issue illustrates a broader problem in food safety: a cheaper, lawful substitute can become a consumer-protection concern when it is presented as conventional paneer without adequate disclosure. The priority should be to ensure that consumers can know what they are buying, regardless of where they live or where they eat.

Representation to the National Human Rights Commission

Building on the findings of the briefing note, ASIA’s Centre for Health Equity submitted a representation dated 11 August 2026 to Shri Priyank Kanoongo, Member, National Human Rights Commission (NHRC), concerning consumer protection, food safety and regulatory enforcement relating to dairy analogues sold or served as paneer in India.

The representation clarifies that ASIA’s concern is not with the lawful manufacture or sale of dairy analogues. It concerns situations where such products are represented, supplied or served as conventional paneer without clear and adequate disclosure, particularly in the Hotel, Restaurant and Catering (HoReCa) sector, where consumers may have limited visibility into the ingredients or composition of food served to them.

The representation highlights the existing FSSAI framework, including the April 2026 West Region public notice concerning cheese analogues in food-service establishments. It also points to recent State-level actions and the uneven availability of publicly accessible, state-wise information on analogue-focused testing and enforcement.

From a health-equity and consumer-rights perspective, the representation asks whether consumers across India are equally able to understand what they are purchasing or being served when naming, disclosure and enforcement practices differ by State, establishment or point of purchase.

What ASIA has requested

ASIA has requested that the Commission, within its mandate, consider seeking information from FSSAI and concerned State/UT authorities on:

• implementation of requirements relating to the naming, labelling and disclosure of dairy analogues;
• state-wise surveillance and enforcement, including samples tested, non-compliance, inspections and action taken;
• compliance within restaurants, caterers, institutional kitchens and, where applicable, digital food-ordering platforms;
• laboratory and enforcement capacity across States and Union Territories; and
• consumer information and awareness measures to help consumers distinguish between milk-derived paneer and dairy analogues.

The representation further requests that, where considered appropriate, the Commission seek a status report from FSSAI and the concerned State/UT authorities on implementation and enforcement of the applicable regulatory framework, including measures to ensure consistent disclosure, nomenclature and consumer awareness across the country.

The briefing note, “Analogue Paneer in India: A Food-Systems Threat to Health Equity,” was enclosed with the representation as supporting analysis of the regulatory framework, available testing and enforcement evidence, consumer-information concerns and differences in implementation.

Read the briefing note: Analogue Paneer in India: A Food-Systems Threat to Health Equity

Read the representation: Representation regarding consumer protection, food safety and regulatory enforcement concerning dairy analogues sold or served as paneer in India

Media Coverage Report