Top Questions on Food Safety Answered by FoodSafetyHelpline Experts

Question. When a food product is packaged by a manufacturer of food products for another brand (Manufactured and processed by us and packed for and marketed under another brand name) , Is there a requirement to put the FSSAI number of the brand under which the product is marketed

Ans. Indian Food Labelling Regulations state that the FSSAI logo with the license number of the Brand owner has to be mentioned on the label of the food product. And for Manufacturer & Distributor/Wholesaler etc. only the License number to be mentioned on the label of the food product.

Question. A package of Masala Tea contains tea leaf/dust, cardamom, elaichi,cinnamon, …etc. Does it required to take Product Approval? OR it may be considered as proprietary food? A package of tea needs to write Nutritional information?

What is the difference between Product approval and proprietary food? Which food products required to take product approval and to be considered as proprietary food?

Ans. In our opinion, PA is not required in this case, reason, if you go by the definition of Tea; ‘Natural Flavours’ & ‘Natural Flavouring Substances’ which are acceptable for human consumption exclusively obtained by physical processes from materials of plants origin either in their natural state or after processing, may be used in packaged tea.

Yes, Nutritional Information will be required to be mentioned on the package of Tea.

To know more about the Product Approval Procedure, you may please click the following link for your better understanding: http://foodsafetyhelpline.com/food-product-approval-system/

Question. Is food safety Logo is mandatory on food package? if yes, under which provision of the FSSA Act 2006? Is Nutritional information is mandatory on food package of Supari ? if yes , under which provision of the FSSA Act 2006?

Ans. Yes, FSSAI Logo and License no. need to be declared on the Package of the food product. However, the compliance date for the same has been further extended upto July 1, 2015.

Nothing has been defined for the nutritional information on Supari but the labelling guidelines state that a warning in conspicuous bold print in a rectangular box should be given in the following manner:

Chewing of Supari is injurious to Health

Question. I have requirement of medical fitness certificate/ check list for new employe in food industry so plese me guide/ suggest or send what requirement for medical fitness as per FSSAI.

Ans. Please download the form for your reference:

http://www.fssai.gov.in/Portals/0/Pdf/MEDICAL_FITNESS_CERTIFICATE(29-02-2012).pdf

Question. We applied for PA through online procedure for our food product.

Have queries:

1) Name of the company in application & uploaded documents are different.

2) Certificate of Analysis of each ingredient is uploaded whereas Ingredient specific Certificate of the products is required.

Ans. You can write to: productapp@fssai.gov.in or can call on 011-23237418 to know about the clarifications/details.

FOOD DEPT RAID YIELDS 1.5 QUINTALS OF FAKE MILK

Several teams from the Department of Food Safety have been launching special checking drives for some days ahead of Holi. The team seized 1.5 quintal of spurious condensed milk on Tuesday, said Dehradun Food Safety officer Anoj Kumar Thapliyal. He said that the team checked a vehicle carrying around 1.5 quintal of spurious condensed milk at Hanuman Chowk on Tuesday noon. The driver and the owner fled. The owner was, however, issued notice by the team. Later, the seized stock was destroyed.

The team had also conducted checking at around eight confectioners in and around Hanuman Chowk area and they were issued notices after they were caught selling spurious condensed milk. Around 50 kg spurious condensed milk and curd were later destroyed by the team. Thapliyal said that six teams have been deployed in the district for the past few days to keep tabs on the manufacturing units of sweets and the retail shops to ensure no malpractice occurs. 

The Food Safety and Standards Act, 2006 applies to all food business undertakings- profit, non-profit, public and private- ranging from the stage of manufacture, processing, packaging, storage, to importing, selling, transporting and distribution of the items, he said.He further said that during inspection, teams are monitoring preparation techniques and are also keeping a close watch over hygiene and precautions being maintained by the manufacturers. 

The officials have been directed to take samples of milk and the by- products which remain in demand during the festive season.

After collecting sampling, food items are sent to Food and Drug Testing Laboratory (FDTL), Rudrapur for checking its purity, he added.

Packaging & labelling regulations for Indian ready-to-eat food segment

Introduction

India is the second-largest producer of food, and holds the potential to be the biggest on the global food and agriculture canvas, according to a survey by Corporate Catalyst India (CCI). The food industry in India comprises food production and processing firms. The food processing industry is one of the largest in India – it is ranked fifth in terms of production, consumption, export and expected growth.

Food processing overview: Indian scenario
India annually produces 205 million tonne fruit and vegetables, and is the second largest country in farm production in the world, but unfortunately the processing percentage is poor - only 4.6 per cent. In contrast, countries like the United States (65 per cent), China (23 per cent) and the Philippines (78 per cent) are far ahead of India in reducing wastage and enhancing the value addition and shelf life of farm products.

This is an alarming signal for India, as a large volume of the agricultural produce is wasted. About 35 per cent of the fruit and vegetables are wasted annually due to poor storage facilities, amounting to a revenue loss of Rs 500 billion. Also, 80 per cent of the vegetables rot due to high water content and the lack of processing facilities, resulting in a revenue loss of Rs 125 billion.

The agricultural sector is vital for any nation, and in India, it is the principal source of livelihood for more than 58 per cent of the population. I consider the food processing sector to be just an extension of the agriculture sector. The progress of each sector is dependent on the other. In developed countries, because of a developed food processing sector, a demand is created in the agriculture sector. India would follow the same path.

Indian food industry
The Indian food industry is projected to grow from $100 billion to $300 billion by 2015, according to a report by a leading industry body and Technopak. During this period, the share of processed foods, in terms of value, is expected to increase from 43 per cent to 50 per cent of the total food production.

The food processing industry is of enormous significance for India's development, as it has efficiently and effectively linked the nation’s economy, industry and agriculture. The linking of these three pillars has synergised the development process and promoted the growth of the nation to a great extent.

The food processing industry is one of the largest industries operating in India and is divided into several segments.

The ready-to eat (RTE) segment is one of the fastest-growing segments in food processing, and has huge prospects in future.

The RTE food industry can be a potential hub for the sustainable growth of new entrepreneurial opportunities; creating a flourishing opportunities, and promoting consumption of RTE foods among the masses.

• ?A strong and effective food processing sector plays a significant role in diversification of agricultural activities, improving value addition opportunities and creating surplus for the export of agro-food products
• ?The most important point in the food processing industry is that a substantial portion being based in the rural areas, it has a very high employment potential with significantly lower investment
• ?The Indian processed food industry has shown a tremendous potential for exports
• ?The fruit and vegetable farming for processing is not only employment-intensive, but also enhances the gross and net returns of the farmers
• ?Cereal processing is one of highest growth sectors to ensure nutritious foods
• ?Emerging modern bakeries ensure best employment opportunities
• ?Food processing industry generates new demand, as the farm sector for more and different agricultural outputs. The development of these industries would relax wage goods constraints to economic growth by enhancing the supply of their products

Impact of new food safety regulations on RTE business
The Food Safety and Standards Act (FSSA), 2006, was born out of the need for an integrated food law, prioritising consumer safety and harmonisation of food standards with international regulations. FSSA, 2006 is a new legislation that integrates eight different existing food laws, and is a comprehensive enactment aimed at ensuring public health and safety. The implementation of this Act will be a major transformation that ensures to bring about a paradigm shift in the food regulatory scenario of India. As per these regulations, every packaged food need to comply with packaging and labelling regulations.

Packaging - General requirements
A utensil or container made of the following materials or metals, when used in the preparation, packaging
and storing of food, shall be deemed to render it unfit for human consumption:

• Containers which are rusty;
• Enamelled containers which have become chipped and rusty;
• Copper or brass containers which are not properly tinned, and
• Containers made of aluminium not conforming in chemical composition to IS:20 specification for cast aluminium and aluminium alloy for utensils or IS:21 specification for wrought aluminium and aluminium alloy for utensils

Containers made of plastic materials should conform to the following Indian Standards Specifications, used as appliances or receptacles for packing or storing, whether partly or wholly, food articles namely:

• IS:10146 (specification for polyethylene in contact with foodstuffs);
• IS:10142 (specification for styrene polymers in contact with foodstuffs);
• IS:10151 (specification for polyvinyl chloride [PVC], in contact with foodstuffs);
• IS:10910 (specification for polypropylene in contact with foodstuffs);
• IS:11434 (specification for ionomer resins in contact with foodstuffs);
• IS:11704 (specification for ethylene acrylic acid [EAA] copolymer);
• IS:12252 (specification for poly-alkylene terephathalates [PET]);
• IS:12247 (specification for nylon 6 polymer);
• IS:13601 (ethylene vinyl acetate [EVA]);
• IS:13576 (ethylene metha acrylic acid [EMAA]), and
• Tin and plastic containers, once used, shall not be re-used for the packaging of edible oils and fats

Provided that utensils or containers made of copper, though not properly tinned, may be used for the preparation
of sugar confectionery or essential oils, and the mere use of such utensils or containers shall not be deemed to render sugar confectionery or essential oils unfit for human consumption.

General packaging requirements for canned products

• All containers shall be securely packed and sealed;
• The exterior of the cans shall be free from major dents, rust, perforations and seam distortions, and
• Cans shall be free from leaks

Some important definitions

Label: Any tag, brand, mark, pictorial or other descriptive matter, written, printed, stencilled, marked, embossed, graphic, perforated, stamped or impressed on or attached to container, cover, lid or crown of any food package and includes a product insert.

Date of manufacture: The date on which the food becomes the product as described.

Date of packaging: The date on which the food is placed in the immediate container in which it will be ultimately sold.

Pre-packaged food: The food, which is placed in a package of any nature, in such a manner that the contents cannot be changed without tampering it, and is ready for sale to the consumer

Best before: The date which signifies the end of the period under any stated storage conditions during which the food shall remain fully marketable and shall retain any specific qualities for which tacit or express claims have been made and beyond that date, the food may still be perfectly safe to consume, though its quality may have diminished. However the food shall not be sold if at any stage the product becomes unsafe.

Principal display panel (PDP): That part of a label which is intended or likely to be displayed or presented or shown or examined by the customer under normal and customary conditions of display sale or purchase of the commodity contained in the package.

All label information shall be given on the PDP

All information required on label shall either be:

• Grouped together at one place, or
• Pre-printed information at one place and online information in another place

Wholesale package:

A package containing:

• A number of retail packages, where the first such mentioned package is intended for sale, distribution or delivery to an intermediary and is not intended for sale direct to a single consumer, or
• A commodity of food sold to an intermediary in bulk to enable such intermediary to sell, distribute or deliver such commodity of food to the consumer in smaller quantities

Multipiece package: A package containing two or more individually-packaged or labelled pieces of the same commodity of identical quantity, intended for retail either in individual pieces or packages as a whole.

Misbranded food: Food articles with false, misleading or deceptive claims, imitation, false information about origin/manufacture, added with no permitted additives, or undeclared additives.

Lot number or code number or batch number: The number either in numericals or alphabets, or in combination thereof, representing the lot number or code number or batch number, being preceded by the phrase Lot Number or Lot, or Code number or Code, or Batch No or Batch, or any distinguishing prefix by which the food can be traced in manufacture and identified in distribution.

Use-by date or recommended last consumption date or expiry date: The date which signifies the end of the estimated period under any stated storage conditions, after which the food probably would not have the quality and safety attributes normally expected by the consumers and the food shall not be sold

Manner of declaration

General conditions

• Any pictorial device/graphic matter on label shall not be in conflict with the regulations
• Declarations shall be legible, conspicuous, plain, bold and in contrast of the background colour

Height of numerical in the declaration

Serial number	Net quantity	Minimum height of numeral
1	Up to 50g/ml	1mm
2	Above 50g/ml up to 200g/ml	2mm
3	Above 200g/ml up to 1kg/l	4mm
4	Above 1kg/l	6mm

Labelling general requirements

General requirements

Every pre-packaged food shall carry a label containing information as required hereunder, unless otherwise
provided, namely:

• The particulars of declaration required under these regulations to be specified on the label shall be in
• English or Hindi in Devnagri script:
• Provided that nothing herein contained shall prevent the use of any other language in addition to the
• language required under this regulation.
• Pre-packaged food shall not be described or presented on any label or in any labelling manner that is false,
• misleading or deceptive or is likely to create an erroneous impression regarding its character in any respect;
• Label in pre-packaged foods shall be applied in such a manner that they will not become separated from the container;
• Contents on the label shall be clear, prominent, indelible and readily legible by the consumer under normal
• conditions of purchase and use;
• Where the container is covered by a wrapper, the wrapper shall carry the necessary information or the label
• on the container shall be readily legible through the outer wrapper and not obscured by it, and
• License number shall be displayed on principal display panel along with FSSAI logo

Labelling of pre-packaged foods

In addition to the general labelling requirements specified above, every package of food shall carry the following information on the label, namely:

Name of the food

• List of ingredients in descending order;
• Nutritional information;
• Declaration regarding vegetarian or non-vegetarian;
• Declaration regarding food additives;
• Name and complete address of manufacturer or packer;
• Net content by weight or volume;
• Date of manufacturing/packing;
• Lot number/batch identification;
• Best-before date;
• Instruction for use, and
• Importer details and country of origin for imported products

Nutritional requirements

• Nutritional information is the declaration of the nutritional composition of the food
• Should always be stated in numerical terms
• Must be declared per 100g or 100ml or per serving of the food on the label
• This declaration should compulsorily comprise of the following information:

Energy value in kcal;
Protein, fat and carbohydrate along with sugar quantity in g, and
Amount of any other nutrient for which a nutrition / health claim is made

• The amount of vitamins and minerals in metric units
• For nutrition declaration made per serving, the amount in g or ml should be mentioned for reference beside the serving measure

Nutritional information not necessary in case of raw agricultural foods, drinking water, single ingredients and bulk foods

When a claim is made on the amount or type of fatty acid or the amount of cholesterol, the amount of   saturated fatty acids, mono-unsaturated fatty acids and poly-unsaturated fatty acids in g and cholesterol in mg should be declared. Along with this, the amount of trans-fatty acids in g should also be stated.

The wholesale package of a food must carry the following declarations: 

• Name of the food, including the trade name or description of the food;
• The vegetarian logo, consisting of a green colour-filled circle within a square with a green outline. This logo must appear close to the brand name;
• Net quantity of the contents;
• Name of the manufacturer and complete address of the manufacturing premises;
• The name and complete address of the packer, where the manufacturer is not the packer;
• Every manufacturer’s and packer’s address must carry the valid licence number, with the prefix Lic No;
• The manufacturer’s licence number should be mentioned in the FSSAI logo;
• For products manufactured at company plants, the licence number would be that of the company’s manufacturing unit, and
• A distinctive batch number with the prefix Lot/Batch/Code No
• Height of the letter for all the declarations must be minimum 1mm.

Exemptions on labelling

Where the surface area of the package is not more than 100sq cm, the label of such product shall be exempted from the requirements of the list of ingredients, lot or batch number, nutritional information and instructions for use, but this information shall be given on the wholesale package or multi-piece packages, as the case may be;

The date of manufacture or best-before or expiry date may not be required to be mentioned on the package having surface area of less than 30sq cm, but this information shall be given on the wholesale or multi-piece packages, as the case may be;
. Exemption given to refilling bottles;
. If the shelf life is of product is not more than seven days, manufacturing date may not be required, but use-by date is to be given, and
. In case of multipiece package the list of ingredients, nutritional information, date of packaging, best-before and vegetarian logo may not be specified

Prohibitions

Specific restrictions on product labels
The information on the label has to be appropriately given for the convenience of the consumer. Any statement, claim, design, etc., which is false, or may mislead a consumer about the quality, nutrition value or quantity of a food product is strictly prohibited. Every food business operator (FBO) dealing with pre-packaged food products has to follow the Food Safety and Standards (Packaging and Labelling) Regulations, 2011.

Label not to contain reference of the Act, Rules or Regulations contradictory to required particulars

The label shall not contain any reference to the Act or any of the regulations, or any comment on, or reference in the label which, directly or by implication, contradicts, qualifies or modifies such particulars or declaration.

Label not to use words implying recommended by medical practitioners

There shall not appear in the label of any package containing food for sale the word recommended by medical profession or any words which imply or suggest that the food is recommended, prescribed or approved by medical practitioners.

Labels not to contain unauthorised use of words showing imitation

There shall not be written in the statement or label attached to any package containing any article of
food the word imitation or any word, or words implying that the article is a substitute for any food, unless the use of the said word or words is specifically permitted under these regulations.

Any fruit syrup, fruit juice, fruit squash, fruit beverages, cordial, crush or any other fruit products standardised under the Food Safety and Standards (Food Products Standards and Food Additives) Regulations, 2011, which does not contain the prescribed amount of fruit juice or fruit pulp or fruit content shall not be described as a fruit syrup, fruit juice, fruit squash, fruit beverages, cordial, crush or any other fruit product, as the case may be.

Any food product which does not contain the specified amount of fruit and is likely to deceive or mislead or give a false impression to the consumer that the product contains fruit, whether by use of words or pictorial representation, shall be clearly and conspicuously marked on the label as added (name of the fruit) flavour.

Any food product which contains only fruit flavours, whether natural flavours and natural flavouring substances or nature identical flavouring substances, artificial flavouring substances as single or in combination thereof, shall not be described as a fruit product and the word added (name of the fruit) flavour shall be used in describing such a product.

Carbonated water containing no fruit juice or fruit pulp shall not have a label which may lead the
consumer into believing that it is a fruit product.

Any fruit and vegetable product alleged to be fortified with vitamin C shall contain not less than 40mg of ascorbic acid per 100g of the product.

Imitations not to be marked pure

The word pure, or any word or words of the same significance, shall not be included in the label of a package that contains an imitation of any food.

Restriction on advertisement

There shall be no advertisement of any food which is misleading or contravening the provisions of the Food Safety and Standards Act, 2006 (34 of 2006) or the rules/regulations made there under.

Non-compliance with regulations

If the food product is not labelled in accordance to the regulations, or it does not provide the required complete information, or the food product is promoted for sale with false, misleading or deceptive claims, it is considered misbranded food and attracts the penalties as follows:

Misbranded food upto Rs 3 lakh, and

Misleading advertisement upto Rs 10 lakh

Conclusion
The ready-to-eat food business is growing, and most of the consumers are literate and aware of the regulations. Thus it is very important to adhere to FSSA and Regulations.

The food business operator is responsible for providing the correct and requisite information on the label to the consumers.
To sell food and drink products, the label must be

• Clear and easy to read;
• Permanent;
• Easy to understand;
• Easily visible, and
• Not misleading

Finally, FBO are responsible for all label defects, and it is advisable to comply with the regulations before regulator initiates any action.
(The author is vice-president, Association of Food Scientists and Technologists, India [AFST], Mysore)

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