Private-Label Documentation Pack: What Ships With a Sri Lankan Run
By the Silk Foods Ceylon Editorial Team
Buyer’s snapshot
- Sri Lanka’s Food (Labelling and Advertising) Regulations 2026 took effect on 1 July 2026. They put a batch number and manufacture and expiry dates on every retail pack; nutrition panels follow for most packaged food from late June 2027.
- Processed food exports grew 33.76 percent to USD 214.61 million in January to August 2026 on Export Development Board data, so more brand owners are meeting this paperwork for the first time.
- A private-label run at Silk Foods Ceylon (SFC) ships with six documents: label compliance check, nutrition panel, allergen statement, per-batch certificate of analysis, shelf-life file and, where a traditional claim is made, Ayurveda registration.
- Two tables below show who produces each document and which ones travel with the brand.
A private-label run arrives in two parts: the pallets everyone plans for, and a folder. The folder that comes with them decides whether a retail buyer’s quality team lists the product, whether a complaint can be traced to a batch, and whether the brand can change factories later without starting again.
Most first-time brand owners in Sri Lanka have never seen that folder before the first run lands. This guide lists what should be in it, who produces each document, and which items are legal requirements as against procurement habits.
What documents ship with a private-label run in Sri Lanka?
Six documents make up the pack. Two are driven by the Food (Labelling and Advertising) Regulations 2026: the label compliance check and, for most products from late June 2027, the nutrition panel. Three are evidence that buyers ask for: the allergen statement, the per-batch certificate of analysis and the shelf-life file. The sixth, Ayurveda registration, applies only to a traditional claim.
| Document | What it settles | Who produces it | When |
|---|---|---|---|
| Label compliance check | Every mandatory particular on the artwork, traced to a regulation | Manufacturer QA, signed off with the brand owner | Before print |
| Nutrition panel | Energy and eight mandatory nutrients, per 100 g and per serving | Laboratory analysis of the locked recipe | After recipe lock, before print |
| Allergen statement | Which named groups are present, and what shares the line | Manufacturer QA | At recipe lock, updated on any change |
| Certificate of analysis | One batch’s results against the agreed specification | Manufacturer, per batch | With every dispatch |
| Shelf-life file | How the expiry date was derived | R&D team, with the brand’s sign-off | Before the first commercial run |
| Ayurveda registration | The right to make a traditional claim | The applicant; the Department of Ayurveda issues | In parallel with R&D, only when claimed |
Service snapshot: Private Labelling at Silk Foods Ceylon
Service: an SFC-formulated SKU from 50 or more ready-to-go products, under the buyer’s brand
First-run MOQs: 1,500 jars (300 g glass), 1,250 bottles (200 ml), 180 capsule bottles
Lead time: 2 to 3 weeks from PO to dispatch; where a recipe is adapted first, R&D runs 3 to 4 weeks at most
Cert coverage: BRCGS- and FSSC 22000 V6-audited site, with Sri Lanka Food Act labelling support inside the engagement
The label compliance check against the Food Act
The label compliance check is a line-by-line reading of the artwork against regulation 5 of the 2026 regulations, which lists the mandatory particulars for a retail label. There is no government pre-approval queue for a plain label, so this check is the only review a compliant pack gets before it prints.
Regulation 6 sets the letter heights, from 1 mm on the nutrition panel to a 3 mm floor on the common name. The element-by-element table, with languages and sizes, is in Sri Lanka’s 2026 food labelling rules as a first-run checklist.
The check the SFC QA team hands over is a marked-up proof: each particular, the regulation it answers, the language used and the measured letter height. Under regulation 10(5), a plant-origin food containing any animal-origin ingredient must name it in bold at 1.5 mm or more, with a statement that it is of animal origin. On a vegan SKU, that is the clause an artwork studio working from an older template most often misses.
Does a Sri Lankan label need a nutrition panel yet?
Under Schedule II, a nutrition panel is mandatory now for any food carrying a nutrition or health claim, for foods made for infants, young children and pregnant mothers, and for special dietary and medical foods. For every other packaged food it becomes mandatory one year after the gazette of 26 June 2026, so from late June 2027.
The content is fixed: energy, then protein, total sugars, available carbohydrate, dietary fibre, total fat, saturated fat, trans fats and sodium, plus any nutrient the label claims. Values are given per 100 g or 100 ml and, in addition, per serving as quantified on the label.
The analysis is commissioned per SKU on the locked recipe, never on a bench sample, because a formulation change changes the numbers. SFC quotes the analysis inside the R&D phase, and the serving size has to be decided before the panel is typeset.
Schedule II exempts single-ingredient unprocessed products, spices and spice mixtures, salt, sugar, tea, coffee, vinegar and packs with a printable area of 100 sq cm or less. A blend with a sugar or fat carrier is a judgement call, and any blend carrying a nutrition claim needs the panel now.
The allergen statement: what the law requires and what buyers ask for
The 2026 regulations do not use the word allergen and do not require a separate allergen box. They require that seven groups of ingredients are always declared in the ingredient list, even when present only as processing aids. A separate allergen statement is a procurement document, asked for by organised retail and hotel buyers.
The proviso to regulation 5(2)(a)(i) names the groups: cereals containing gluten (wheat, spelt, rye, barley and oats), crustacea, eggs, fish, peanuts and soybeans, milk including lactose, and tree nuts. The list tracks section 4.2.1.4 of the Codex General Standard for the Labelling of Prepackaged Foods, CXS 1-1985, which adds sulphites at 10 mg per kg or more.
The statement SFC issues per SKU does three things the ingredient list cannot. It names which groups are in the recipe. It names which other allergens are handled in the same production block, because a cellular-manufacturing facility moves equipment between configurations and a coconut spread may follow a cashew cheese. And it describes the changeover control between them. Under the FSSC 22000 Version 6 audit, allergen declarations on a label or in accompanying documentation have to be verified and validated, so the statement is an audited document, not a courtesy letter.
What is on a per-batch certificate of analysis?
A certificate of analysis records what one batch was tested for and what it measured, against the specification agreed at the brief. It carries the batch number the pack carries under regulation 5(2)(a)(iii), so a jar on a shelf can be traced to its results. Every dispatch from a private-label run should come with one.
Codex CXS 1-1985 has required since 1985 that each container be marked, in code or in clear, to identify the producing factory and the lot. The FSSC 22000 V6 audit tests the system behind it: traceability one step up and one step down, with a traceability exercise, mass balance included, run on a named product during the audit.
A typical certificate at SFC carries the product and SKU, the batch number, the dates of manufacture and expiry, each parameter tested, its specification limit, the result, the method or laboratory, and a QA release signature. The parameters depend on the product: microbiological results for a retorted plant milk, moisture and sieve size for a spice blend, Brix and pH for a coconut jam. There is no standard panel, because one panel for a capsule and a sauce would be wrong for both.
The QA team at the Matale facility sees one failure pattern more than any other in files that arrive from elsewhere: certificates whose batch numbers match nothing on a label. A certificate for a batch the buyer cannot find on a pack is not evidence. It is paper. The fix is procedural: the batch code is assigned before the fill, printed on pack and certificate from the same record, and handed over with the dispatch note.
The shelf-life justification file
Since 1 July 2026 every packaged food in Sri Lanka has had to carry a numerical date of expiry, and selling past it is an offence under regulation 5(4). The regulations say nothing about how the date is derived. The shelf-life file defends the number, and the brand whose name is on the pack carries the liability.
The file records the study design, storage conditions, pull points and results behind the expiry date. A 12-month claim takes 12 months of real-time data to prove, so a first run usually launches on an accelerated study with real-time samples still running. The method choices are in shelf-life and accelerated stability testing for a Sri Lankan SKU. The file should name the batch the samples came from.
When is a Department of Ayurveda licence part of the pack?
Department of Ayurveda registration joins the pack only when the label makes a traditional or Ayurvedic claim. The Department’s Form A covers registration or renewal of a manufactory of Ayurveda articles, substances or drugs. Form B covers registration or renewal of Ayurveda products. A capsule sold with no claim stays on the food track.
The legal basis is the Ayurveda Act No. 31 of 1961, most recently amended by the Ayurveda (Amendment) Act No. 19 of 2023. The product registration asks for the formulation, the herb sources and the claim wording, so SFC runs the application in parallel with R&D: the claim and the herb content have to agree. The two tracks are walked through in private-label Ayurvedic capsules: Ayurveda Department and SLSI in parallel. The brand holds a copy of the manufactory registration and the product registration for the SKU. The Department publishes no fee or processing time, so confirm both at application.
Who owns each document, and what travels on a factory switch
Under private labelling the recipe belongs to the manufacturer and the brand to the brand owner. That split decides which documents can go to another factory and which start again from zero.
| Document | Belongs to | Travels on a switch? |
|---|---|---|
| Label compliance check | The brand owner; the artwork is theirs | Yes, re-checked against the new manufacturer’s details |
| Nutrition panel | The brand owner, for that recipe | Only if the recipe travels, and a private-label recipe does not |
| Allergen statement | The manufacturer; it describes its own site | No. The new site issues its own |
| Certificate of analysis | The brand holds copies for batches it bought | Historic certificates stay valid as records; new batches need new ones |
| Shelf-life file | As the agreement says | A study on one site’s batch does not prove another site’s product |
| Ayurveda registration | Form A: the manufacturer. Form B: the registered holder | Form A never travels; Form B as the registration states |
Two lines decide most disputes. The allergen statement and the shelf-life file describe a product made at one site and cannot be carried to another. Ownership under each route is covered in private label, contract manufacturing or OBM: who owns what, the records that restart on a packer change in switching co-packers in Sri Lanka: the audit chain handover, and the manufacturer’s own audit stack in contract manufacturing certifications in Sri Lanka.
Buyer’s checklist: six questions before signing
- Will the label compliance check arrive as a marked-up proof, with regulation numbers, before print?
- Who commissions the nutrition analysis, on which batch, and who pays?
- Does the allergen statement cover the whole production block, beyond the recipe itself?
- Does every dispatch carry a certificate of analysis whose batch number matches the pack?
- Which study backs the expiry date, and which batch did the samples come from?
- If the label carries a traditional claim, who holds the Form B registration?
A brand that cannot answer the fourth should not sign. The stages behind these documents are in from brief to first commercial run: how a test batch actually works.
Frequently asked questions
What documents should come with a private-label run in Sri Lanka?
Six: a label compliance check against regulation 5 of the 2026 labelling regulations, a nutrition panel from laboratory analysis, an allergen statement covering the production block, a certificate of analysis for every batch, a shelf-life file, and Ayurveda registration where a traditional claim is made.
Is a certificate of analysis required by law in Sri Lanka?
The 2026 regulations require a batch number on the pack under regulation 5(2)(a)(iii) but do not require a certificate to be handed to the brand owner. The certificate is how a manufacturer evidences the traceability the FSSC 22000 V6 audit tests, and organised retail buyers ask for it as a listing condition.
When does the nutrition panel become mandatory in Sri Lanka?
Schedule II makes a panel mandatory now for claim-bearing foods, infant and pregnant-mother foods, and special dietary and medical foods. For all other packaged food it applies one year after the gazette of 26 June 2026, so from late June 2027, with spices, salt, sugar and tea exempt.
Does Silk Foods Ceylon provide the documentation pack on a private-label run?
Yes. A private-label run from the Matale facility ships with the label compliance check, the allergen statement, a certificate of analysis per batch and the shelf-life file, with nutrition analysis quoted per SKU and Ayurveda registration supported where a claim is made. First runs start at 1,500 jars or 180 capsule bottles.
How Silk Foods Ceylon can help
For brands commissioning a first private-label run, Silk Foods Ceylon (SFC) offers a catalogue of 50 or more ready-to-go products labelled under the buyer’s brand at the Matale facility. First-run MOQs are 1,500 jars for spreads (300 g glass), 1,250 bottles for beverages (200 ml) and 180 bottles for capsules, with 2 to 3 weeks from PO to dispatch; where a recipe is adapted first, R&D runs 3 to 4 weeks at most. The site is BRCGS- and FSSC 22000 V6-audited, and the label check, allergen statement, per-batch certificates and shelf-life file sit inside a standard engagement.
To brief a project, email b2b@esilkroute.com.lk or call +94 76 441 0389 / +94 76 918 5744.
Sources
Government of Sri Lanka, Food (Labelling and Advertising) Regulations 2026, Gazette Extraordinary No. 2494/47 of 26 June 2026, under section 32 of the Food Act No. 26 of 1980, in operation from 1 July 2026: regulations 5(2)(a), 5(4), 6 and 10(5), and Schedule II. Retrieved 4 October 2026. https://eohfs.health.gov.lk/food/images/2494-47_E.pdf
FAO/WHO Codex Alimentarius, General Standard for the Labelling of Prepackaged Foods, CXS 1-1985, adopted 1985, amended through 2010: sections 4.2.1.4 and 4.6. Retrieved 4 October 2026. https://www.fao.org/input/download/standards/32/CXS_001e.pdf
FSSC 22000, Annex 2, CB Audit Report Requirements, Version 6, April 2023: traceability system (one up, one down; mass balance; traceability exercise during the audit) and allergen management and declaration verification. Retrieved 4 October 2026. https://www.fssc.com/wp-content/uploads/2023/03/Annex-2_CB-Audit-Report-Requirements-FSSC-22000-_Version-6.pdf
Department of Ayurveda, Ministry of Health, Sri Lanka, Application forms: Form A (manufactory registration or renewal) and Form B (registration or renewal of Ayurveda products). Retrieved 4 October 2026. https://ayurveda.gov.lk/application-forms/
Parliament of Sri Lanka, Ayurveda (Amendment) Act, No. 19 of 2023, amending the Ayurveda Act No. 31 of 1961. Retrieved 4 October 2026. https://www.parliament.lk/uploads/acts/gbills/english/6301.pdf
Newswire.lk, Sri Lanka export earnings surpass US$ 12 billion mark, 23 September 2026, reporting Export Development Board data: processed food exports up 33.76 percent to USD 214.61 million in January to August 2026. Retrieved 4 October 2026. https://www.newswire.lk/2026/09/23/sri-lanka-export-earnings-surpass-us-12-billion-mark/
Silk Foods Ceylon, internal capability data for the Matale facility: first-run MOQs of 1,500 jars, 1,250 bottles and 180 capsule bottles; 2 to 3 weeks from PO to dispatch; R&D 3 to 4 weeks maximum; the documentation pack as issued by the QA and R&D teams.
Written by the Silk Foods Ceylon Team. Silk Foods Ceylon (Pvt) Ltd. is a BRCGS- and FSSC 22000 V6-audited contract manufacturer in Matale, Sri Lanka, offering contract manufacturing, private labelling, co-packing, and in-house R&D for local Sri Lankan brand owners, FMCG companies, hotel and restaurant groups, and distributors. To brief a project: b2b@esilkroute.com.lk, +94 76 441 0389, or +94 76 918 5744.
