FCO 1985 · Fertilisers
Conventional fertilisers work to established specifications. Nano fertilisers are newer ground, and the specification question is where projects succeed or stall.
How are fertilizers registered in India?
Fertilisers are governed by the Fertiliser (Control) Order, 1985, administered by the Controller of Fertilisers with State agriculture departments. A product must conform to a specification laid down in the relevant Schedule, and manufacture and sale require State-issued licences. Products without an existing Schedule entry require an application for inclusion of a new specification.
Two starting positions
| Existing Schedule entry | No existing entry | |
|---|---|---|
| What you must show | Conformity with the specification | That a new specification should be included |
| Data required | Analytical conformity | Chemistry, efficacy and safety data |
| Nature of the work | A compliance exercise | A project |
| Typical duration | Weeks to months | Considerably longer |
The first question for any fertiliser product is therefore which side of that line it falls on. Companies sometimes assume a new inclusion is needed when an existing entry would in fact cover the product, and occasionally the reverse. Establishing this correctly saves more time than anything else in the process.
Conventional fertilisers: conformity is the requirement
Where a Schedule entry exists, the product must meet the specification in every respect — nutrient content, permissible tolerances, moisture, particle size, and limits on contaminants including heavy metals. Conformity has to hold not just at manufacture but through the claimed shelf life and in the market, because samples are drawn from the market.
A product that performs well agronomically but sits outside specification cannot lawfully be sold. That is worth saying plainly, because the commercial instinct is to treat a marginal parameter as a technicality. Enforcement does not.
Nano fertilisers
Nano fertilisers have attracted substantial commercial interest in India, particularly nano urea and nano DAP, and the regulatory framework for them is newer than the framework for conventional products. That has two practical consequences.
First, the specification question is central. A nano formulation is characterised by particle size distribution and the behaviour that follows from it, not only by nutrient percentage. A specification that does not capture the nano characteristics does not actually control the product.
Second, efficacy evidence carries more weight. The commercial claim for a nano fertiliser is typically improved nutrient use efficiency at lower application rates. That is a claim about performance relative to a conventional product, and demonstrating it requires trial design capable of supporting the comparison across the relevant agro-climatic zones.
Companies entering this space should expect the assessment to be more searching than for a conventional product, and should plan the data programme accordingly rather than assuming a conformity-style timeline.
What compliance involves either way
- Specification position — confirm whether an existing Schedule entry fits, or an inclusion application is required
- Analytical conformity — demonstrate the product meets the specification through shelf life
- Manufacturing licence — from the State agriculture department for the producing site, supported by factory documents, laboratory facilities and quality control arrangements
- Sale and marketing licences — in each State of distribution
- Labelling — carrying the particulars required by FCO, including specification, batch, date of manufacture, expiry and manufacturer details
Imported fertilisers
Imported products face the same specification requirement as domestic ones. The additional work is usually documentary: establishing that the overseas manufacturer's specification and analysis correspond to the Indian Schedule entry, and that consignment analysis will support conformity on arrival. Where the overseas specification is expressed differently, reconciling the two before shipment avoids arguments at the point of sampling.
How JDR supports fertiliser registration
We establish the specification position first, assess conformity and identify where a formulation change is needed to achieve it, prepare and file State licensing applications, draft FCO-compliant labels, and manage Schedule inclusion applications for products without an existing entry — including nano fertilisers, where the specification and efficacy case need building together.
Frequently Asked Questions
Do fertilizers need CIBRC registration?
No. Fertilisers are regulated under the Fertiliser (Control) Order, 1985, not the Insecticides Act, 1968. CIB&RC registration applies to products with pest control claims.
What if my product does not match any Schedule entry?
You must apply for inclusion of a new specification, supported by chemistry, efficacy and safety data. This is a project rather than a filing, and should be planned and resourced as one.
Are nano fertilizers regulated differently?
They sit under the same Order, but the framework is newer and the assessment tends to be more searching. Specification has to capture the nano characteristics rather than nutrient content alone, and efficacy claims about improved nutrient use efficiency need trial design capable of supporting the comparison.
Do I need licences in every state?
Yes for sale. Manufacturing is licensed where the plant is located, and sale and marketing licences are required in each State of distribution.
What is the most common compliance failure?
Falling outside specification on a parameter at some point in shelf life, or on a market-drawn sample. Conformity has to hold through the claimed shelf life, not only at manufacture.
Reviewed: 22 September 2026 · Reflects the Insecticides Act, 1968 and Insecticides Rules, 1971 as amended, including the Insecticides Third (Amendment) Rules, 2026 (G.S.R. 597(E) dated 8 July 2026). General guidance only — confirm current requirements before acting.
Launching a fertiliser or nano fertiliser?
Send us the composition and claim. We will confirm the specification position before you commit to a data programme.
Talk to Our Regulatory Team