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
Author
Bejon Misra, assisted by
P.K Dhingra, Puneet Kalra & the VOICE team
Voluntary Organisation in
Interest of Consumer 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 QUESTIONS
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.
METHODOLOGY
Stage - 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.
METHODOLOGY
Stage - II
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.
METHODOLOGY
Stage -III
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.
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
Germany
11%
USA
32%
Thailand
16%
Malaysia
16%
UK
25%
HIGHLIGHTS OF THE ANALYSIS
Distribution by Countries
Others
56%
Top Five
44%
Other Countries:
Korea,
Italy,
Denmark,
Australia,
Indonesia,
Switzerland, Holland, Singapore, Japan, China, France,
Hong Kong, UAE etc.
MAJOR
VIOLATIONS
Confectionery Beverage Meat
Value
Products
Products Products Added Food
(357)
(39)
(21)
Products
(40)
276/357
39/39
20/21
38/40
PFA
(77%)
(100%)
(95%)
(95%)
Rules 32
(1955)
282/357
39/39
19/21
31/40
PCR
(79%)
(100%)
(90%)
(77%)
Rules 33
(1977)
Total
(457)
373/457
(81%)
371/457
(81%)
MAJOR
VIOLATIONS
Importers
Address
Confectionery
Products
(357)
Beverage
Products
(39)
269/357
(75%)
36/39
(90%)
Meat
Value Added Total
Products
Food
(457)
(21)
Products
(40)
18/21
25/40
315/457
(86%)
(62%)
(69%)
MAJOR
VIOLATIONS
Lot/ Batch No
MRP
Separate Declaration
on A ddition of NonPermitted Chemicals
Confectionery
Products
(357)
Beverage
Products
(39)
Meat
Products
(21)
179/ 357
(50%)
228/ 357
(63%)
236/ 357
(66%)
36/ 39
(92%)
27/ 39
(69%)
27/ 39
(69%)
39/ 21
(62%)
13/ 21
(62%)
2/ 21
(10%)
Value
Added
Food
Products
(40)
25/ 40
(62%)
27/ 40
(67%)
12/ 40
(30%)
Total
(457)
279/ 457
(61%)
295/ 457
(64%)
277/ 457
(61%)
MAJOR VIOLATIONS
FPO (1955)
PFA (1954)
A dulterated
Ingredients List
Best before
N on-Permitted Colour
/ A gent Declaration
Separate Declaration
on
A ddition
of
Fats/ O ils
Common Name
M anufacturers
A ddress
Confectionery
Products
(357)
Beverage
Products
(39)
Meat
Products
(21)
7/ 357
(2%)
16/ 357
(4 %)
88/ 357
(25%)
14/ 357
(4%)
83/ 257
(23%)
65/ 357
(18%)
33/ 357
(9%)
-
-
Value
Added
Food
Products
(40)
-
-
-
-
4/ 39
(10%)
1/ 39
(2%)
10/ 39
(27%)
-
2/ 21
(9%)
-
6/ 40
(15%)
-
8/ 21
(38%)
1/ 21
(5%)
-
15/ 40
(37%)
7/ 40
(17%)
-
-
-
10/ 39
(27%)
15/ 21
(71%)
2/ 40
(5%)
9/ 40
(22%)
20/ 357
(5%)
64/ 357
(18%)
01/ 39
(2%)
Total
(457)
7/ 457
(1%)
16/ 457
(3%)
100/ 457
(22%)
15/ 457
(3%)
116/ 457
(25%)
73/ 457
(16%)
34/ 457
(7%)
22/ 457
(5%)
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 is in the case of
ingredient’s list, as laid down under the
provisions of our existing law.
RECOMMENDATIONS
•
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:.
CONCLUSION
1. 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.
Contd..
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.
THANKYOU