An Evaluation Study on the Implementation of

National Laws on Packed Food Products

Sponsored By:Ministry of Agriculture,

Department of Food Processing Industries,Government of India

AuthorBejon Misra, assisted by

P.K Dhingra, Puneet Kalra & the VOICE team

Voluntary Organisation in Voluntary Organisation in Interest of Consumer Interest of Consumer

Education (VOICE)Education (VOICE)

VOICE is a registered Non Government Organisation working since 1983 to promote, protect and educate the consumers on their rights and responsibilities through its activities focused on:

Education Comparative Testing Advocacy & Campaign Research & Development

KEY QUESTIONS

a ) To document the existing level of implementation of National Laws concerning labeling and packing of imported food products.

KEY QUESTIONS

b ) To analyze and compare with Indian made food products and similar imported food products in terms of adherence of the National Laws.

KEY KEY QUESTIONSQUESTIONS

KEY KEY QUESTIONSQUESTIONS

c) To prepare a well-documented campaign kit for the

consumer groups in India on the study to sensitize and build awareness among consumers on seeking & demanding mandatory information on all packed food products.

METHODOLOGMETHODOLOGYYStage - I

9 markets were identified

SOUTH DELHI : Lajpat Nagar,Vasant Vihar,Chanakya Puri.NORTH DELHI : Shalimar Bagh, Pitampura.

WEST DELHI : Rajouri Garden.

CENTRAL DELHI : Karol Bagh.

EAST DELHI : Faridabad, Noida.

457 samples were purchased from 9 selected markets and were scientifically collated and analyzed in terms of the information available on

the packs to see whether they confirmed to the law or not.

METHODOLOGMETHODOLOGYYStage - II

METHODOLOGMETHODOLOGYY

The final report was mailed to the leading consumer organisations to develop the future action plan on sustaining a campaign on the implementation of the national laws on food labeling and packaging.

Stage -III

SCOPE OF STUDY

Prevention of Food Adulteration Act (1954). Adulterated Food- comes within the scope of section 2(1a) of PFA Act (1954). Misbranded Food- comes within the scope of section 2(1X) of PFA Act (1954).

Prevention of Food Adulteration rules (1955) Packing and labelling of food under PFA Rules (1955).

SCOPE OF STUDY Packing and labelling of food under PFA

Rules (1955)

Variations from prescribed standard: - Standards for different food items

are laid down in Appendix B to PFA Rules (1955) and standards for foods are grouped into different groups i.e. spices, cereals and cereal products, oils and fats,

confectionery etc.

Packaged Commodity Rules (1977). Provisions applicable to imported foods Rule 33. Fruit Products Order (1955).

TYPE OF SAMPLES

(a) Confectionery:Chocolate,Candy,Toffee,Biscuit,Pastry & similar.

(b) Beverages :Juice,Carbonated,Drink, Milk, Ice Tea & similar.

(c) Meat :Fish,Ham,Pork,Prawn & similar.

(d) Value added Food Products:Pasta,Sauce,Spices & similar.

HIGHLIGHTS OF THE ANALYSIS

Product Distribution of Top 5 Countries

Thailand16%

Malaysia16% UK

25%

USA 32%

Germany11%

HIGHLIGHTS OF THE ANALYSIS

Distribution by Countries

Others56%

Top Five44%

Other Countries:Korea, Italy, Denmark, Australia, Indonesia, Switzerland, Holland, Singapore, Japan, China, France, Hong Kong, UAE etc.

MAJOR VIOLATIONS

ConfectioneryProducts

(357)

BeverageProducts

(39)

MeatProducts

(21)

ValueAdded Food

Products(40)

Total(457)

PFARules 32(1955)

276/357(77%)

39/39(100%)

20/21(95%)

38/40 (95%)

373/457(81%)

PCRRules 33(1977)

282/357(79%)

39/39(100%)

19/21(90%)

31/40(77%)

371/457(81%)

MAJOR VIOLATIONS

ConfectioneryProducts

(357)

BeverageProducts

(39)

MeatProducts

(21)

Value AddedFood

Products(40)

Total(457)

ImportersAddress

269/357(75%)

36/39(90%)

18/21(86%)

25/40(62%)

315/457(69%)

MAJOR VIOLATIONS

ConfectioneryProducts

(357)

BeverageProducts

(39)

MeatProducts

(21)

ValueAddedFood

Products(40)

Total(457)

Lot/Batch No 179/357(50%)

36/39(92%)

39/21(62%)

25/40(62%)

279/457(61%)

MRP 228/357(63%)

27/39(69%)

13/21(62%)

27/40(67%)

295/457(64%)

Separate Declarationon Addition of Non-Permitted Chemicals

236/357(66%)

27/39(69%)

2/21(10%)

12/40(30%)

277/457(61%)

MAJOR VIOLATIONSConfectionery

Products(357)

BeverageProducts

(39)

MeatProducts

(21)

ValueAddedFood

Products(40)

Total(457)

FPO (1955) 7/357(2%)

- - - 7/457(1%)

PFA (1954) 16/357(4 %)

- - - 16/457(3%)

Adulterated 88/357(25%)

4/39(10%)

2/21(9%)

6/40(15%)

100/457(22%)

Ingredients List 14/357(4%)

1/39(2%)

- - 15/457(3%)

Best before 83/257(23%)

10/39(27%)

8/21(38%)

15/40(37%)

116/457(25%)

Non-Permitted Colour/ Agent Declaration

65/357(18%)

- 1/21(5%)

7/40(17%)

73/457(16%)

Separate Declarationon Addition ofFats/Oils

33/357(9%)

01/39(2%)

- - 34/457(7%)

Common Name 20/357(5%)

- - 2/40(5%)

22/457(5%)

ManufacturersAddress

64/357(18%)

10/39(27%)

15/21(71%)

9/40(22%)

98/457(21%)

CASE STUDY

This label of Northland Cranberry Grape juice from West Indies does not show batch number, month and year of production and best before. Also it has not declared separate declaration about the use of flavour.

CASE STUDY

This label of Licht & Roming Koffiecreamer powder from Utrecht is proprietary item which contains anti-caking agent and its use in Koffiecreamer is not permitted as per Indian law. This is classified as adulterated.

CASE STUDY

This package of Owl Kopi-O does not declare the names of ingredients.

CASE STUDY

The foreign languages on the package does not carry any English or Indian language version.

CASE STUDY

This Label of Armada Heringsfilets from Deutschland contains aroma, which needs separate declaration under the Indian Law is missing.

CASE STUDY

Other than the brand name SAVING nothing else is written in English or any Indian version.

CASE STUDY

Similarly other than the brand name PERSONAL COOKING nothing is written in English or any Indian language.

CASE STUDY

The labels of Lipton Ice Tea from Singapore is a proprietary item, which does not display the name and address of manufacturer or importer. It also does not give a separate declaration about the use of flavour.

CASE STUDY

Some more products which were collected from the markets under the scope of the study.

CASE STUDY

The label of Super Cook Milk Chocolate Chips from UK does not give information about the name and address of the manufacturer and also the month and year of manufacture.

CASE STUDY

This Label of Lyle’s Golden Syrup from England has no information on the ingredients, month & year of manufacture and best before date.

CASE STUDY

This Label of Tudor gold Hazelnut from Australia does not display the batch number and separate declaration about the use of added flavour.

COMMONALITY

There is only one commonality between our labelling regulations and labels used by foreign exporters and that is in the case of ingredient list, as laid down as per our provisions of law.

There is only one commonality between our labelling regulations and labels used by foreign exporters is in the case of ingredient’s list, as laid down under the provisions of our existing law.

RECOMMERECOMMENDATIONDATIONSS

RECOMMERECOMMENDATIONDATIONSS

• Regular Training of Custom officials,retailers, importers and other agencies dealing with packaged food products on the existing provisions of Law.

• Empowering the consumers to demand implementation of the existing laws.

• Strengthening the existing regulatory authorities.

• Proper coordination between the various concerned Central Government Ministries.• Mandatory declaration by all importers on implementation of the existing laws:.

CONCLUSION1. Empowering Common consumers with the

knowledge and effective mechanisms to protect their rights and perform their duties as responsible consumers.

2. Safety and health concerns of our citizens should be the prime objective of every government. Public health issues should always prevail over trade and commerce.

3. The study should be used as a campaign tool to sensitize retailers, importers and consumers.

CONCLUSION

4. The market should always provide an unbiased platform for all stakeholders and the regulatory mechanisms should encourage the best practices

5. Such studies should be commissioned in a regular manner to evaluate the performance of the regulators and the industry towards their consumers.

Contd..

THANKYOU