Compliance pressure mounts on Organic Food Business Operators in India

Food for thought: How compliant are you as an organic food manufacturer?

Can you legally call your products organic?

A 2018 report of the ASSOCHAM (Associated Chambers of Commerce and Industry of India) estimates the Indian organic foods market at ₹40,000 million, a figure that is likely to increase to ₹100,000-120,000 million by 2020 with their exports complementing this trend. The government is getting increasingly strict about science, labeling and claims by the organic producers.

India has a couple of watchdogs coming up with stringent regulations against scientifically false and misleading claims about the safety and wholesomeness of organic food. As a result, chances of your products being recalled are higher if you haven’t already acquainted yourself with the  norms set forth by the FSSAI (Food Safety and Standards Authority of India) and APEDA (Agricultural and Processed Food Products Export Development Authority).

Barring petty manufacturers with an annual turnover of less than ₹12 Lakhs per annum and/or a production capacity of non-milk and non-meat products at less than 100 kgs or 100 litres per day, all food businesses need a license from the FSSAI. Which means that a small time Organic FBO (Food Business Operator) doesn’t need to worry about doing the rounds at government offices for license and certifications. But in case you surpass aforementioned criteria, not only are you required to apply for the FSSAI license, but you’re also additionally required to comply with the Food Safety and Standards (Organic Foods) Regulations, 2017.

What’s the first step to calling your brand “Organic” ?

The 2017 regulations on safety and standards of organic foods recognize two systems of certification—

1. the Participatory Guarantee System (PGS), implemented by the Ministry of Agriculture and Farmers’ Welfare and
2. the National Programme for Organic Production (NPOP), implemented by the Ministry of Commerce and Industry.

While the NPOP is beneficial for FBOs who also want to export their products, PGS-India is a local Quality Assurance initiative which certifies farmers in a local group through a peer-appraisal process. According to their operational manual, “individual farmers or group of farmers having less than 5 members are not covered under PGS.”

Membership to either of these organisations makes you eligible to apply for the Jaivik Bharat logo which has to be printed on the label of all organic products. The compliance burden is on the manufacturer and dealer who are prohibited from selling organic products which do not carry this logo, effective from 1^st April, 2019.

Your handbook to getting it right the first time: Source: NPOP Appendix 5 – Organic Food Processing and Handling:

• Packaging
  • Ensure it is biodegradable, recyclable, reusable systems and eco-friendly
  • Shouldn’t contaminate food.
  • Should resist manipulation or any attempts of
  • Should be accredited by the certifying body
• Labelling
  • Description to state “produce of organic agriculture”
  • If you’re phasing-in into organic farming, mention the year of conversion
  • Must mention name and address of the person or company legally responsible for the production or processing of the product
  • List processing procedures
  • Declare all components of additives and processing aids
  • Additional product information shall be made available on request
  • List ingredients from wild production
  • Single ingredient products may be labelled as “Organic” when all standard requirements have been met
  • If you’re selling a Multi ingredient product and if 95% of those ingredients are of organic origin, your product may be labelled “certified organic“. If it falls short of the 95% criteria but stands above 70%, you can only use the description “made with organic ingredients” provided there is a clear statement of the proportion of the organic ingredients. Anything less than 70% will not be called ‘organic’
• All raw materials to be listed in order of their weight percentage
• The label of a certified organic product must depict the name and logo of the accredited Certification Body, accreditation number and India Organic Logo
• The accredited Certification Body shall verify the labeling requirement and approve the labels of their certified operators before the labels are used

If you are an organic food manufacturer or a participant in the organic food supply chain, we would love to hear from you about the processes you have put in place to ensure compliance on an on-going basis.