The FSSAI’s order requires all licensed small food producers to conduct chemical or microbial testing for their products in their own labs or labs accredited by the government at least once every six months and to upload the results to an FSSAI web portal.

In a letter dated June 9, the food manufacturers’ groups asked FSSAI to lift its order, which was issued on January 13 of this year. Until now, regulatory and quality checks over food products across the country have depended mainly on random sample tests by the FSSAI’s own food safety officers.

The order requires an additional self-testing requirement for all food enterprises, and food manufacturers have raised concerns about the cost and logistics of six-month tests for small and medium-sized food manufacturing enterprises.

Food manufacturers have expressed concern about the economic and logistical burden of the six-monthly tests on small and medium food manufacturing enterprises.

The signatories include representatives of small and medium enterprises making myriad food products — including dairy products such as milk, ghee, cheese and paneer; snacks such as chikkis, chaklis, and theplas; condiments, honey, jam, papads, pickles, and sambar, and rasam powders.

“This could become an existential threat to many small food enterprises,” said the director of a honey-making enterprise in Tamil Nadu, who requested anonymity. It costs us Rs 35,000 to test each flavour, and we have nine flavours. Every six months, it’s a big cost.”

The FSSAI website says India had over 3.8 million registered food business enterprises in October 2021. Food industry executives estimate nearly three million are small enterprises. Small food enterprises are typically entities with annual turnovers below Rs 12 lakh, while those with annual turnovers between Rs 12 lakh and Rs 20 crore are classified as medium food enterprises.

Those opposing the order are also asking why the FSSAI is thrusting the responsibility for food testing on the manufacturers when it itself represents the regulatory apparatus for routine food-safety testing and has food safety officers responsible for this task.

The food producers’ letter to the FSSAI has also challenged the logic of the six-monthly testing. “The once-in-six-months rule appears to have no scientific basis,” said Kavitha Kuruganti, a representative of the Alliance for Sustainable and Holistic Agriculture, a network of farm groups.

Some products, such as snacks or condiments, might have edible life cycles lasting only days to weeks. Signatories to the letter have said it is unclear how the six-monthly testing would provide useful information on products with much shorter life cycles.

The letter has also flagged concerns about a conflict of interest — food manufacturers themselves are being asked to test their own products — and the potential for fraud under the self-testing order that some say appears to disregard the FSSAI’s testing obligations.

“Under the existing regulatory regime, food safety officers from the FSSAI are expected to pick up and test random samples,” Kuruganti said. “It is unclear what prompted the FSSAI to ask food producers to also take up this responsibility.”

The signatories include dozens of food producers from Bengal, Gujarat, Haryana, Karnataka, Kerala, Maharashtra, Punjab, Rajasthan, Tamil Nadu, Telangana, and Uttar Pradesh, among other states.

“We’re waking up late to the January order — but in recent weeks, some of the signatories received messages from the FSSAI to upload their test results,” one of the signatories said. “This letter reflects our collective concerns.”

Photo caption: A small coconut oil factory, Kozhikode, Kerala, India | Photo by Hardik Monga | unsplash

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