The FSSAI ‘Food Safey and Standards (Packaging) Regulations, 2018’ were notified on 24 December 2018 and published as F.No. 1-95/Stds/Packaging/SP(L&CA)/FSSAI-2017. They come into force on the date of publication and were uploaded on the web on 1 January 2019. The Food Safety and Standards Authority of India under the Ministry of Health and Family Welfare, expects ‘Food Business Operators’ to comply with the new regulations by 1 July 2019. It can be downloaded from –https://www.fssai.gov.in/home/fss-legislation/notifications/gazette-notification.html.
We met with the chief executive officer of FSSAI, Pawan Agarwal who reiterated, “The primary objective of packaging is to protect the food contents from microbiological, chemical, physical and atmospheric contamination and preserve the food and thereby protect consumer’s health.” On this premise, the regulations provide a detailed list of packaging materials that may be used for the packaging of specific categories of food products and also prescribe specific requirements/ restrictions in their regard. These regulations shall replace all prior provisions under the existing Food Safety and Standards (Packaging and Labelling) Regulations, 2011, that are specific to packaging requirements and require full compliance of FBOs in the country by 1 July 2019.
According to the FSSAI press release, “These regulations address all [health] concerns that came out of the two studies conducted by FSSAI recently through the Indian Institute of Packaging (IIP), Mumbai and the National Test House (NTH), Kolkata.”
The two studies had indicated that the packaging material used by the organized sector is largely safe but there are concerns about the use of packaging material by the unorganized or informal sector. There are more serious concerns about safety of loose packaging material. “Thus, these regulations prohibit packaging material made of recycled plastics including carry bags for packaging, storing, carrying or dispensing articles of food.”
Agarwal pointed that in the current regulations that supersede those issued in 2011, the regulations for food safety have been bifurcated and refined to separately address the packaging segment and the labelling and display segments respectively. He said, “The new packaging regulations would raise the bar of food safety in India to the next level. He admitted that there would be difficulties in implementation of these regulations particularly as far as they relate to the loose packaging materials and to the unorganised sector” and encouraged us to solicit industry feedback from both the food business industry and the packaging and label industry in a responsible manner. This is a project that Ipp Services, Training and Research (IppStar) www.ippstar.org plans to execute in coming weeks.
At this point, it seems that the new regulations are quite comprehensive in their definitions and in that they take into account all packaging materials and indicated the Indian Standards (IS) relevant to each. The ink migration standards have also been specified as well the migration levels. There are of course a few problem areas that come to mind in a first reading of the regulations but these are first of all in the nature of questions that may have quick answers. Moreover. the FSSAI is open to discussion and clarification from what we can gather in our meeting with Pawan Agarwal. His team is also not unaware of the issues concerning the use of plastics and waste collection and recycling.
The lead time that has been given before the regulations come into force is six months. Food and packaging businesses together have to comply with these regulations by 1 July, 2019 although the onus in the regulations is on “food business.” Aggarwal added that “stakeholder’s consultation and mass awareness building amongst consumers and food businesses would precede implementation of the new packaging regulations.”
‘We urge all food and food packaging businesses to download the new regulations and engage with our research team as try to develop responsible and informed feedback and a discussion on the new regulations. Perhaps in mid-February we can have a one-day meeting conference bringing together food and packaging businesses and concerned experts and individuals in the Delhi NCR.
Naresh Khanna firstname.lastname@example.org