The NHRC Just Called Out FSSAI Over Reused Cooking Oil

The samosa you pick up at the corner shop, the vada pav from the station stall, the pakoras at your favourite dhaba, the fried chicken at the fast food counter — all of these are prepared in oil. And in a significant proportion of Indian food service establishments, that oil is not fresh. It may have been used dozens of times, reheated to high temperatures repeatedly over days, and allowed to degrade into a substance that bears little chemical resemblance to the clean vegetable oil it started as. In October 2025, this situation attracted the attention of India's National Human Rights Commission (NHRC), which issued a formal notice to FSSAI demanding state-wise data on oil reuse practices and action taken against violators.

The NHRC notice followed a complaint from a Bhopal-based NGO alleging that FSSAI's Repurpose Used Cooking Oil (RUCO) campaign — intended to collect degraded used cooking oil for conversion to biodiesel rather than continued food use — had fundamentally failed to curb reuse of degraded oil, particularly among small and unorganised food businesses. The NGO's complaint argued that the widespread health consequences of consuming food fried in repeatedly degraded oil constituted a human rights concern — not just a food safety regulation issue.

This article explains what happens to cooking oil when it is repeatedly heated, what FSSAI's TPC standard means and how it is supposed to be enforced, what the KFC case in India revealed about the limits of corporate compliance, and what you can do to assess the oil quality in food you buy outside the home.

Fresh vegetable oil is predominantly composed of triglycerides — molecules made of a glycerol backbone linked to three fatty acid chains. When oil is heated to frying temperatures (typically 160–200°C), these molecules begin to break down through a series of chemical reactions: hydrolysis (breaking bonds in the presence of moisture from food), oxidation (reaction with atmospheric oxygen), and polymerisation (fatty acid chains linking to form larger, more complex molecules). These processes are the same whether the oil is groundnut, sunflower, palm, or refined vegetable oil.

The products of these reactions — called Total Polar Compounds (TPCs), named for their chemical polarity relative to the original non-polar triglycerides — include free fatty acids, diglycerides, monoglycerides, oxidised fatty acids, cyclic and polymeric compounds, and aldehydes. Some of these compounds, when consumed, have been linked in animal studies and epidemiological research to cardiovascular disease, atherosclerosis, liver disease, inflammation, Alzheimer's disease, and certain cancers. Acrolein, one of the breakdown products of overheated oil, is a known irritant and potential carcinogen. Trans fatty acids, another product of industrial partial hydrogenation but also formed in small amounts during repeated high-temperature heating of unsaturated oils, are associated with increased cardiovascular risk.

FSSAI's rule is specific: cooking oil becomes legally unfit for continued food use when its Total Polar Compounds (TPC) exceed 25%. This is the regulatory threshold beyond which oil used in a food business violates India's food safety standards. FSSAI also recommends, in its guidance documents, that cooking oil should ideally be heated only once and should not be reheated more than three times under any circumstances.

In 2023, KFC India became the subject of regulatory and legal discussion around cooking oil reuse — illustrating how even large branded food service chains, subject to far more corporate oversight than individual street vendors, face practical challenges with oil management. Legal analysis published on ArogyaLegal.com examined whether cooking oil could lawfully be reused in India and concluded that Indian law does not categorically prohibit reuse — it prohibits continued use once TPC levels exceed 25%. The question of whether a specific restaurant's oil has crossed that threshold requires testing, not observation.

For a large branded fast-food chain, TPC testing is feasible: they can use test strips or handheld TPC meters and have the corporate infrastructure and training to implement systematic oil-change protocols. For a street vendor or a small dhaba frying in the same kadhai all day — replacing oil whose cost represents a significant proportion of daily operating expenses — systematic TPC monitoring is, practically speaking, not happening. This is the fundamental enforcement gap: the rule exists, the threshold is defined, but the inspection capacity and incentive structure do not currently translate the rule into consistent practice at the unorganised segment of India's food service industry.

The NHRC's October 2025 notice was significant not just because of its source — a human rights body treating food oil reuse as a rights issue — but because of the specific allegation it accepted for examination: that FSSAI's RUCO campaign had failed to prevent degraded oil from re-entering the food supply. The RUCO (Repurpose Used Cooking Oil) initiative was designed to create a collection ecosystem for used cooking oil — with food businesses surrendering degraded oil to registered collectors who would convert it to biodiesel, thereby removing it from food use. The NGO complaint alleged that in practice, degraded oil collected through informal channels was being diverted back into food production rather than to biodiesel, and that FSSAI had insufficient data and inspection capacity to prevent this.

The NHRC requested state-wise data on the scale of cooking oil reuse, enforcement actions taken, and the RUCO program's actual performance from FSSAI — signalling that the commission took the complaint seriously enough to require an official response. As of the most recent reporting, the NHRC's examination of this matter was ongoing. The notice itself served as public acknowledgement at the highest non-judicial oversight level that cooking oil reuse is a systemic problem, not an individual bad-actor situation.

India's street food economy is enormous — the sector is estimated to involve crores of vendors and provide daily meals to hundreds of millions of people. It is also the segment furthest from systematic TPC monitoring. A street vendor frying puri or bhature in a large kadhai over a wood or gas flame, from early morning until the day's supply runs out, is making an economic calculation about oil replacement that has nothing to do with TPC levels. Oil is expensive. Customers don't test the oil. Inspectors rarely visit. And fresh oil fries differently from repeatedly used oil — it actually produces a less crispy, paler product than oil that has been heated a few times, which means experienced street food cooks have empirical incentives to use oil that has been heated at least a few times, even if not to the point of degradation.

The tell-tale visual signs of severely degraded oil — dark brown or black colour, thick viscosity, strong persistent smell, excessive foaming — are visible even to untrained eyes. But oil that is significantly degraded but has not yet reached the extreme end of these visual indicators may still exceed the 25% TPC limit while looking only slightly darker than fresh oil. The only definitive test is a TPC meter, which street vendors do not own and inspectors do not routinely bring.

From a health perspective, the risk from occasionally consuming food fried in somewhat degraded oil is not the same as the risk from daily consumption as the basis of a diet. Someone who eats street-fried food daily — as many urban Indians do, for financial and convenience reasons — faces meaningfully higher cumulative exposure to TPC-derived toxins than someone who enjoys street food as an occasional treat. The correlation between high street-food consumption and cardiovascular disease risk in Indian urban populations is well-documented in epidemiological research, though causality is difficult to establish given multiple confounding factors.

Separate from the cooking oil reuse issue (though related), FSSAI has implemented a 2% maximum limit on trans fatty acids in all food products as of 2022 — down from a previous 5% limit. Trans fats, which form primarily during industrial partial hydrogenation of vegetable oils (vanaspati, dalda) but also in smaller amounts during repeated high-temperature heating of unsaturated oils, are associated with increased LDL (bad) cholesterol, decreased HDL (good) cholesterol, and elevated cardiovascular disease risk. The WHO's goal is global elimination of industrially produced trans fats by 2023 — a deadline India has approached through the 2% limit, though complete elimination remains a longer-term objective.

For consumers, the 2% trans fat limit means that products containing partially hydrogenated vegetable oil (commonly used in bakery, snacks, and packaged foods) should not exceed 2g of trans fat per 100g of product. Checking the nutrition label for "Trans Fat" under the fat section, and looking for "partially hydrogenated" in the ingredient list, are the relevant checks for packaged foods. For cooked food at restaurants or street stalls, there is no practical way to test for trans fat content as a consumer — the cooking oil management practices of the establishment are the proximate determinant.

Visual check: fresh or recently changed oil should be pale yellow to light golden. Oil that is dark brown, opaque, thick, or produces heavy foam when food is added has likely been used far beyond safe limits. This is visible without any equipment — trust the visual signal.

Smell check: degraded oil has a persistent strong rancid or fishy smell even when not actively frying. Fresh oil at frying temperature has a clean, neutral odour. If the smell near a frying station makes you uncomfortable, that is useful information.

Smoke signal: oil that smokes excessively at normal frying temperature has degraded significantly — its smoke point drops as TPC levels rise. Excessive smoke at a frying station means the oil should have been replaced long ago.

Ask, when appropriate: at a restaurant (less so at a street stall), asking about oil change frequency is reasonable and legitimate. A restaurant that changes oil daily or every other day for a high-volume frying operation is likely within safe TPC limits. One that claims to change oil "weekly" for a busy operation is almost certainly exceeding the 25% TPC threshold routinely.

Be aware of where reuse risk is highest: samosa, bhature, puri, pakora, and similar deep-fried items require high oil volumes and long frying times — the economics strongly incentivise extended oil use. Tawa-cooked items (roti, dosa, paratha with a small amount of oil) involve much lower total oil volumes and shorter heat exposure, and carry lower risk from this specific issue.

India's cooking oil reuse enforcement landscape has a significant disparity: large branded restaurant chains (McDonald's, KFC, Domino's, and their Indian counterparts) face far more scrutiny and accountability for oil management than small dhabas, street stalls, or informal caterers — partly because they are visible targets for consumer complaints and regulatory attention, partly because the KFC case and similar instances have made oil management a reputational issue for branded chains that unbranded operations don't face.

This enforcement disparity creates a counterintuitive situation where a consumer eating fried food at a large branded chain may actually face lower TPC-related risk than one eating the same food from a local dhaba — not because the chain's food is inherently safer, but because the chain has stronger corporate incentives (legal liability, brand reputation, franchise standards) to manage oil change protocols systematically. The traditional and informal food sector, which is where the majority of Indians eat fried food regularly, is the highest-risk environment precisely because it is the lowest-scrutiny one.

This dynamic also affects the geographic distribution of risk: urban consumers who eat primarily at branded establishments have lower oil-reuse exposure than peri-urban and rural consumers who rely primarily on informal food service for fried food. The public health burden of cooking oil reuse falls most heavily on populations that already face multiple health disadvantages — compounding existing inequities in nutrition and food safety outcomes.

FSSAI's RUCO (Repurpose Used Cooking Oil) initiative offers a meaningful alternative to both continued food use and improper disposal of degraded cooking oil: collection and conversion to biodiesel. Used cooking oil has genuine value as a biodiesel feedstock — it can be processed into biodiesel fuel that is cleaner-burning than fossil diesel and addresses both a disposal challenge and an energy security need. FSSAI has registered collection agencies under RUCO and created a framework for food businesses to surrender used oil to these agencies rather than reusing it or disposing of it improperly.

The RUCO programme represents a genuinely good idea that has struggled with implementation at the informal-sector scale. For a large hotel or restaurant chain, formalised used oil collection is manageable within existing procurement and vendor management systems. For a street vendor who uses five litres of oil a day and earns a living on thin margins, the concept of formalised oil collection requires a level of documentation and coordination that is not realistic without significant support infrastructure. The NHRC complaint in 2025 specifically cited RUCO's failure to adequately reach this informal sector — the part of the market where the problem is most concentrated.

Search trends for India show strong interest in "is reused cooking oil safe," "how many times can you use cooking oil for frying," "effects of reheated oil on health," "TPC cooking oil india," "RUCO program india," and "trans fat india ban." There is also significant search interest in "which oil is best for deep frying india" — reflecting a consumer base that is increasingly aware that oil selection matters for health but may not be equally aware that oil management (how many times it is used and at what temperatures) matters just as much as oil type.

India's cooking oil reuse problem is not primarily a story about individual bad actors. It is a story about incentive structures: oil is expensive, inspection capacity is limited, and there is no efficient mechanism for the 1.5 crore small food businesses in India to test TPC levels routinely. The NHRC notice, the RUCO campaign, and the 25% TPC rule all represent genuine regulatory intent. What they do not yet represent is reliable enforcement at the scale of the problem. As a consumer, the practical tools available to you — visual assessment of oil colour and smoke, awareness of which dish types carry the highest reuse risk, and personal threshold for accepting that risk — are, for now, more reliable guides than any assumption that restaurant or street-vendor oil has been recently changed.