The legal definitions
Kulfi has no U.S. standard of identity. Part 135 of Title 21 of the Code of Federal Regulations covers frozen desserts, and none of its standards is for kulfi.
In our reading, a kulfi sold in the United States under the name ice cream would have to meet 21 CFR 135.110, the standard for ice cream and frozen custard, like any other ice cream. That section sets three main rules:
- At least 10% milkfat. The floor drops to 8% of the whole when bulky flavors such as chocolate, fruit or nuts are added.
- A weight of at least 4.5 pounds per gallon.
- Less than 1.4% egg yolk solids.
India has its own rules. FSSAI (the Food Safety and Standards Authority of India) standard 2.1.14 covers ice cream, kulfi, chocolate ice cream, softy ice cream, milk ice, milk lolly and dried ice cream mix. It treats kulfi as a named kind of ice cream. Under that standard, kulfi is a frozen milk product made by freezing a pasteurized mix of milk or products made from milk. It may contain incorporated air, and it must be frozen hard. The standard sets no egg yolk figure for kulfi.
Fat and solids
FSSAI’s published standard, as reproduced in its myth buster on ice cream and frozen dessert, sets three tiers. That document carries no date.
- Kulfi: total solids at least 36.0% by mass, milk fat at least 10.0%, milk protein at least 3.5%, and a weight of at least 525 g per liter.
- Medium-fat kulfi: total solids at least 30.0%, milk fat above 2.5% and under 10.0%, protein 3.5%, and at least 475 g per liter.
- Low-fat kulfi: total solids at least 26.0%, milk fat at most 2.5%, protein 3.0%, and at least 475 g per liter.
The 2024 review by Mondal and colleagues, whose first author works in the Dairy Technology Division of ICAR-National Dairy Research Institute in Karnal, describes kulfi as close to ice cream in composition. It is made from cow milk, buffalo milk or both. Cooking the milk down to half its volume concentrates its solids. That is where kulfi’s richness comes from, rather than from whipped-in air.
Air, weight and temperature
This is the one place where traditional kulfi and the regulated product part ways. The NDRI review describes kulfi as having no air. FSSAI’s standard allows incorporated air and sets a minimum weight of 525 g per liter instead. By our arithmetic, that is about 4.4 pounds per gallon. So a kulfi made to the letter of the standard can hold some air, while a traditional kulfi holds none.
For comparison, U.S. ice cream must weigh at least 4.5 pounds per gallon. By our arithmetic, at a typical mix density, that caps overrun near 104%. H. Douglas Goff of the University of Guelph gives about 100 to 120% overrun for standard ice cream and 25 to 50% for super-premium.
On temperature, FSSAI says only that kulfi must be frozen hard. The experiments in the NDRI review froze the mix in small molds at about -20 °C (-4 °F) overnight. That is a freezing temperature, not a serving one. We found no sourced serving temperature for kulfi. For ice cream, Goff gives a typical serving temperature of about -16 °C (3 °F).
How kulfi is made
The traditional method, as the 2024 review describes it:
- Sweeten the milk and heat it slowly, stirring constantly.
- Keep going until the volume is about half of what you started with.
- Flavor it. The review lists rose, mango, cardamom, saffron, strawberry and pistachio.
- Pour it into small molds and freeze it without churning.
Ice cream works differently. Goff describes it being frozen while stirred in a barrel freezer, which works air into it. It is then hardened in a blast freezer at -30 to -40 °C. Kulfi skips the stirring during freezing entirely.
The review also notes that about 0.7% of India’s milk goes into frozen desserts such as ice cream and kulfi. Our sources give no origin date or story for kulfi, so we do not give one either.
Where our sources disagree
Two figures do not line up, and we do not pick one.
- Fat: FSSAI sets at least 10.0% milk fat for kulfi. The NDRI review says kulfi contains approximately 8.53% fat. That is below FSSAI’s kulfi floor and inside its medium-fat range.
- Air: FSSAI allows incorporated air. The NDRI review describes kulfi as having none.
Both can be true at once. The regulator describes what may be sold under the name. The review describes how kulfi is traditionally made. If you buy kulfi, the label and the standard it follows tell you which kind you have.