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The pharmacy
We won't name it. Not because we want to protect the outlet — the practices we found are worth scrutinising — but because the point of this piece is not to single out one pharmacy. It could be any of several dozen we've walked into in Bengaluru, Mumbai, or Delhi over the past eighteen months. This one happened to have a drawer.
The location is near a gym-dense residential neighbourhood in south Bengaluru. White tiled interior, a refrigerator humming in the corner for probiotics and eye drops, a glass cabinet behind the counter holding branded OTC medicines, and a freestanding shelf unit near the entrance stocked with supplements. The supplement section is roughly three shelves high, roughly 180cm wide. It faces the door. It is the first thing you see when you walk in. Everything on those three shelves is on our standard survey list. We have been here three times before. The shelf looked familiar.
The bottom drawer — a pull-out tray beneath the bottom shelf, the kind used to store overflow stock — was partly open. Not our business. Then the buyer noticed a label on a tub in the drawer: a product we'd scored. A different batch from the one on the shelf above. She photographed both, asked the counter staff if the drawer stock was for sale. It was.
The standard shelf — what looked normal
The three visible shelves held 34 products across nine brands. By our standard audit criteria — FSSAI licence number visible, net weight in grams stated, active ingredient per serving clearly declared — 29 of 34 passed. That's an 83% compliance rate, which is roughly in line with what our four-city survey from April found for general health retail chains: adequate for a market that was largely unregulated five years ago, not adequate for one that sells products with direct health implications.
What the standard shelf showed us: two domestic whey proteins, a creatine monohydrate from a brand we've reviewed, three multivitamin products, a vitamin D3 sachet brand we've flagged before, two omega-3 capsule products (one with EPA/DHA, one without — both marketed as "omega-3"), and an assortment of single-nutrient capsules. Nothing unusual. A photo essay of that shelf would tell you nothing we haven't already published.
↑ Field photographs on file. Not published to avoid identifying the outlet. Available on request for verified journalists and researchers.
The bottom drawer
The drawer held nine products. Of the nine, three were identical to products visible on the shelf above — overflow stock, presumably. The remaining six were not on the visible shelf at all. They were being stored in the drawer and offered for sale when a customer asked for them by name, or when the facing shelf unit ran low.
The six expired products
FSSAI Food Safety and Standards (Labelling and Display) Regulations, 2020, Regulation 3(1)(e), requires that food products bear a "best before or use by" date and prohibits the sale of products past that date. 1 Selling expired food products is an offence under Section 26(2)(ii) of the Food Safety and Standards Act, 2006. 2 None of this is obscure law. All six products in the drawer were being offered for sale at their full printed MRP.
We reported the expired products to the counter staff. The response was that these were "old stock" being kept for "reference." When pressed on why they were visible in the pull-out drawer with pricing stickers, the pharmacist on duty said he would have them removed. We don't know if he did. We didn't return.
The two grey-market import boxes
Both were products from US supplement brands — one a creatine monohydrate, one a multivitamin. Both had labels in English only, with no Hindi ingredient list. Neither had an Indian importer's name, address, or FSSAI import licence number. Both had US-format nutrition facts panels. One had a California Proposition 65 warning on the side panel — a US state-level labelling requirement that has no relevance to Indian regulation and indicates the product had not been prepared for the Indian market.
What Indian law requires for imported supplements
FSSAI Food Safety and Standards (Import) Regulations, 2017, Regulation 4, requires that any food product imported for sale in India must be imported by a licensed FSSAI importer and carry that importer's name, address, and FSSAI licence number on the label. Products arriving through informal channels — grey market imports, parallel imports from the US or Singapore, or bulk decanting and local repacking — do not meet this requirement. Their sale is a violation of Regulation 4 regardless of product quality. 3
The import question matters beyond legality. Products that bypass the formal import channel also bypass whatever customs and import inspection exists. For supplements, that inspection is minimal — but it is the only checkpoint for batch-level issues including contamination, adulteration, or mis-labelling that might have been caught by the exporting country's regulatory process. Grey-market products sidestep it entirely.
The counter staff, when asked where the boxes came from, said they were purchased from "a supplier in the city." That supplier's name was not available. The products were priced at roughly 35–40% below the Amazon.in MRP for the same items when purchased through legitimate import channels — the spread that typically signals grey-market sourcing.
The unmarked white jar
This is the one that stays with you.
It was a plain white HDPE container, roughly 500g capacity by volume, with a printed adhesive label that said: "Creatine Monohydrate" in a bold font, followed by "Net Wt. 500g" and a price handwritten in marker: ₹420. No brand name. No FSSAI licence number. No manufacturing date. No best-before date. No batch code. No ingredient list. No allergen declaration. No address. Nothing that would tell you who made it, when, from what, or where.
"There is no labelling violation more complete than a product that provides no information at all. This jar was in compliance with exactly none of the requirements that exist to protect the person buying it."
We did not purchase it. We photographed it, photographed its label, and asked the pharmacist about its provenance. He said it came from "a gym supplier" and that "many customers prefer it because it's pure." He used the word "pure" sincerely. We are confident he believed it.
Creatine monohydrate is chemically simple but not immune to adulteration. The most common adulterant in unregulated markets — documented in multiple analyses of grey-market sports nutrition from Southeast Asia and South Asia — is creatinine, the metabolic byproduct of creatine, which is visually indistinguishable from creatine monohydrate, cheaper to produce in unregulated settings, and pharmacologically inert at typical supplementation doses. 4 There is no method available to the consumer, and no information on this jar, that would allow anyone to determine whether what they were paying ₹420 for was creatine or its useless metabolite.
What shelf surveys don't capture
Our four-city shelf survey, published two weeks after this visit, checked 24 products across four retail locations. Every product on our survey list was photographed, every label was audited, every FSSAI number was verified. The methodology is sound. The findings are real. And they are a photograph of the visible shelf — the facing units, the products the store wants you to see, the stock that's been recently rotated and is within its shelf life.
What they don't capture: the drawer. The back room. The supplier's tote bag that arrived last Tuesday. The products a customer can get "if you ask." Structured shelf surveys are sampling exercises, and the sample they take is the best-case sample — the curated front-of-shelf presentation that the retailer has reason to maintain correctly. The overflow, the old stock, the informal supplier relationship — these exist in every retail environment, and they are not visible to anyone who walks in with a clipboard and a pre-specified list of SKUs.
We are not concluding from one pharmacy that the Indian supplement retail market is broadly dangerous. That would be a different kind of methodological error. What we are concluding is narrower: that the floor of the Indian retail supplement market — the worst of what is available, not the average — is considerably lower than structured surveys imply. A buyer who reaches past the facing shelf and into what's available "if you ask" is in a different risk environment than the one our audit numbers describe.
The pharmacist was not malicious. He was, by every indication, a reasonably careful person running a busy retail operation who had accumulated stock he hadn't fully rotated, sourced some products from informal channels because the margin was better, and stocked an unlabelled product because his gym customers asked for it and he trusted the supplier. None of these are exceptional behaviours. They are ordinary retail behaviours in a sector where the regulatory floor is low, enforcement is sparse, and the customer who knows to ask what's in the jar before paying for it is rare.
The buyer paid for the omega-3, which was in date. She left everything else in the drawer.
References
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[1]
Food Safety and Standards (Labelling and Display) Regulations, 2020. Regulation 3(1)(e) — Mandatory declaration of best before or use by date. Food Safety and Standards Authority of India. fssai.gov.in
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[2]
Food Safety and Standards Act, 2006. Section 26(2)(ii) — Prohibition on manufacture, distribution, or sale of misbranded, sub-standard, or unsafe food. Ministry of Law and Justice, Government of India.
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[3]
Food Safety and Standards (Import) Regulations, 2017. Regulation 4 — Conditions for import of food articles. Food Safety and Standards Authority of India. fssai.gov.in
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[4]
Mathews NM (2018). Prohibited contaminants in dietary supplements. Sports Health, 10(1):19–30. Review of adulteration patterns in sports nutrition products, including creatinine substitution in grey-market creatine. doi:10.1177/1941738117727736
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