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 FIFI has 127 members who are importing food products worth $2.1 billion, representing 1200 brands from 72 countries. One of its stated objectives is to educate and address the issues relating to the laws and regulations including FSSAI and encourage fair trade practices. It also believes that FSSAI should play a pivotal role to ensure that all food products are safe for human consumption but expects that the decisions are based on scientific analysis and study of international practices.
Amit Lohani, Director of Forum for Food Industry (FIFI) made a lucid Presentation interspersed with humour to reduce any pain inflicted on any of the delegates present. Through slides he showed the ambiguity resulting in the rejection of various shipments of such basic products as olives and  mayonnaise (which incidentally, is not allowed to be imported in this category but comes to India as a sauce). Such as the example of Lindt chocolate being rejected for vague reasons when it is much sought after in dozens of countries and ostensibly has high standards of quality and has moved out of India rather than succumb to the flimsy grounds of rejection.
It is truly ironical that India is the biggest beef exporter of 1.5 million metric tons of beef – ahead of Australia, USA and Argentina and yet there are quibbles from various groups protesting about its consumption in India, he exclaimed. Curiously, corned beef is allowed as a product category and he showed the documents listing it as such.
Ridiculous High Sampling Costs
One of the main reasons for the recent hike in import costs has been thanks to the sampling costs which may appear innocuous at Rs. 3371 per sample submitted for testing (including the service tax) for each sample in the shipment but in reality they can be totally out of proportion-even more than 50%, as he explained in the hypothetical example of the import of cookies from the same manufacturer from a country, but in different shapes and sizes and flavours.
For the sake of explanation, his slide included cookies from 2 batches in 10 different shapes (round, square, triangular etc) in 4 different pack sizes, by weight in 2 different flavours, that would be treated as 160 samples by FSSAI (2*10*4*2). At Rs. 3371 each as sampling cost, that would mean a mean Rs. 539,328 ($8990). If the cost of one container-load is Rs.10,00,000 (one million), the sampling cost alone is around 54% of the cost of cookies!! It would seemingly provide several jobs for FSSAI and possibly cookies for many testers!!
Arbitrary
The World Health Organisation and the Food and Agricultural Organisation of the UN formed Codex International Food Standards over 50 years ago; these are the most widely used globally as benchmark standards. It seems strange that FSSAI has only 377 categories whereas Codex has 4000 standards, said Lohani. But what appeared more shocking was that not a single standard seems to have been added since FSSAI came into existence in 2008. Lohani wondered how many labs were added during the six years since the FSSAI came into being. Scientific labs of international standards are very important to validate the authenticity of the products tested. He also rued the fact that the Product Approval was being given based on company names or brands, thus giving benefits to a few giants. Surprisingly, the Food Safety Standards do not have any provision for Product Approvals.
Labelling Requirements
One of the biggest issues raised has been the labelling requirements, starting with its own logo of FSSAI that needs to be in 4-colour printing, making it an expensive exercise from the overseas producers’ point of view. FSSAI requires scientific names of the products to be mentioned on the labels. For instance, rice packaging needs to display ‘Oriza Sativa’- the mostly unknown scientific name even though many people are aware of the name Asafoetida for ‘hing’- a common ingredient for Indian dishes. Canola oil which is being increasingly added as a cooking medium must now have the name ‘Rapeseed oil with low Erucic acid’.
FIFI seems to have done a study for actual sampling costs incurred for 2012-2014 and it was presented to the audience. It varied from a little over 5% in 2012-2013 to 7% in 2013-2014. Most wine importers agree that the sampling cost for wines is also within these limits though it has made import of fine wines very difficult as the cost of the bottle taken for sampling is very high- making this cost go up to 20-25 % if 6 bottles were to be imported.
 The presentation was part of the First F & B Conclave organised by the BW Hotelier group at Hotel La Meridien and attended by various F & B personnel including chefs, managers and kitchen equipment suppliers who are the end users of many of the products mentioned by Lohani end of the sticks with escalated costs and delay in receiving the products. They were surprised to know that 80% of the imported food ingredients they are buying from the vendors are not Product Approved. But the shocking fact is that according to the Notification issued a couple of weeks ago by FSSAI, the end user is legally liable to ensure that the product they are using is FSSAI compliant ingredients to ensure their customers get safe food products only.
Like the wine importers, Lohani concluded that FIFI also recognises that the safety standards are for the benefit of the consumers but wondered why the members of the Authority look at all importers with distrust, causing a resentment among most importers who are honest. They would like to have the advisories be given a 6-12 month window before implementing. He concluded his Presentation with the remark that there was no representation by the food industry with FSSAI, a representation that wine importers have also made.
For 60 years since independence, there have been no well-defined laws to regulate the industry and suddenly the whole industry is sought to be changed overnight – a laudable goal but most delegates were left wondering whether this was plausible, with the limitations and constraints highlighted by FIFI. The food and wine industry have suffered at the hands of the arbitrary handling of the issue by FSSAI. One hopes that this is a transitional period and the government and the Authority realise that a pragmatic and scientific approach would go a long way in making the food healthy for us all. We as consumers appreciate the efforts and objectives of providing us safe food and wine but let it not become the case of the baby being thrown out with the bathwater.
Subhash Arora
The article is written based on the Presentation made at the Conference and authenticity of figures has not been checked by us. It is assumed that FIFI has validated the facts- editor |