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Compliance pressure mounts on Organic Food Business Operators in India

Food businesses in India has to comply with Food Safety and Standards (FSS) Act, 2006 except petty manufacturers whose annual turnover is Rs. 12 lakhs or less and production capacity (non-milk and non-meat) is less than 100 kg or 100 l per day. Barring this category, all food businesses need a license from Food Safety and Standards Authority of India (FSSAI). Organic food businesses need to comply additionally with the Food Safety and Standards (Organic Foods) Regulations, 2017. This blog will focus on the regulatory requirements for organic food businesses with respect to packaging and labelling, to ensure that their business is not interrupted due to non-compliance.

The Jaivik Bharat logo has to be printed on the label of all organic products. The compliance burden is on the manufacturer and the dealer who is prohibited from selling organic products which does not carry this logo, effective from 1st April, 2019. In order to be eligible for tagging a product as organic and for printing this logo, the organic food business operator has to register either with National Programme for Organic Production (NPOP) or Participatory Guarantee System for India (PGS – India).


NPOP under Agricultural and Processed Food Products Export Development Authority (APEDA) accredits certification bodies to inspect and certify organic food business operators as per defined procedures. While the NPOP is beneficial for FBOs who also want to export their products, PGS-India is a local Quality Assurance initiative which prescribes organic standards and 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.”

Salient points under NPOP Appendix 5 – Organic Food Processing and Handling:

  • Packaging
    • Biodegradable, recyclable, reusable systems and eco-friendly packaging materials shall be used wherever possible
    • Material used for packaging shall not contaminate food. Certain additives for use in manufacturing of packaging films for packaging of organic food stuffs are allowed for restricted use (Annex 2)
    • The packages shall be closed in such a manner that substitution of the content cannot be achieved without manipulation or damage of the seal
    • The accredited Certification Body shall approve the packaging material for use
  • Labelling
    • When the full standards requirements are fulfilled, products shall be sold as “produce of organic agriculture” or a similar description
    • The label for conversion products shall be clearly distinguishable from the label for organic products by mentioning the year of conversion
    • The name and address of the person or company legally responsible for the production or processing of the product shall be mentioned on the label
    • Product labels should list processing procedures, which influence the product properties in a way not immediately obvious. All components of additives and processing aids shall be declared
    • Additional product information shall be made available on request
    • Ingredients or products derived from wild production shall be declared as such
    • Single ingredient products may be labelled as “Organic” when all standard requirements have been met
    • Multi ingredient products where not all ingredients, including additives, are of organic origin may be labelled in the following way (raw material weight):
      • Where a minimum of 95% of the ingredients are of certified organic origin, products may be labelled “certified organic” or similar and should carry the logo of the certification programme.
      • Where less than 95% but not less than 70% of the ingredients are of certified organic origin, products may not be called “organic“. The word “organic” may be used on the principal display in statements like “made with organic ingredients” provided there is a clear statement of the proportion of the organic ingredients. An indication that the product is covered by the certification programme should be used, close to the indication of proportion of organic ingredients.
  • Where less than 70% of the ingredients are of certified organic origin, the indication that an ingredient is organic may appear in the ingredients list. Such product may not be called “organic”.
  • For aquaculture products the use of iodized salt shall be referred on the labels.
  • All raw materials of a multi-ingredient product shall be listed on the product label in order of their weight percentage. It shall be apparent which raw materials are of organic certified origin and which are not. All additives shall be listed with their full name
  • If herbs and/or spices constitute less than 2% of the total weight of the product, they may be listed as “spices” or “herbs” without stating the percentage.
  • Organic products shall not be labelled as GE (genetic engineering) or GM (genetic modification) free in order to avoid potentially misleading claims about the end product. Any reference to genetic engineering on product labels shall be limited to the production method
  • 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 labelling requirement and approve the labels of their certified operators before the labels are used

The requirements specified above are in addition to the requirements under FSS (Packaging and Labelling) Regulations, 2011.

We would like to conclude this post by reiterating a note by APEDA in May 2018 on launching a traceability module for organic food. “Certification process shall be followed as per the provision of NPOP till the product is packed into retail packs. The last end processor (who shall be packing the produce in retail packs) shall be certified under NPOP. Final processed and packed product shall be divided into reasonable size batches. Batch and label shall be approved by the certification body and batch numbers along with QR code shall be generated from Tracenet – which shall be compulsorily printed on retail packets.”

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.

Courtesy: Aravind Ravi, Technical Documentation Manager at ManageArtworks.

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