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Saturday, June 2, 2018

FSSAI provision for rectification of food product labels for seamless import clearance



Food import clearance in India is a laborious process which involves clearance from various stakeholders like Plant Quarantine (PQ), Animal Quarantine (AQ), FSSAI and so on. Since FSSAI is the controlling authority of food related matters in India the final clearance of shipment or consignment will depend on the certificate issued by FSSAI. 
In this regard, FSSAI have developed a workflow which primarily include inspection, sampling and safety analysis (an external laboratory perform the analysis) of the imported food products. Recently, FSSAI has issued a notification with provisions for rectification of labeling non-compliance's (or deficiencies) in addition to the few mentioned under Reg 6 (4) of FSS Import regulations. The following sections describe the key takeaways along with the advantages to the business 
  • In which stage of the import clearance life cycle this is applicable?

As per the import clearance process, the identification of deficiencies by FSSAI could happen in both application scrutiny and visual inspection stage
  • In which stage the importer can perform the rectification?
Either before visual inspection or re-inspection (typically happens post rectification of labels)
  • What is the process of rectification prescribed by FSSAI?
The rectification of the discrepancies is allowed to be performed in the customs bonded warehouse by affixing a single non-detachable sticker or by any other non-detachable method (like ink jet print etc.,) next to the principal display panel (PDP) without altering or masking the original label information in any manner. Additionally, to avail the permission for rectification the importers should provide an undertaking or an e-Sanchit stating the contents are true and genuine 
  • What are the rectifications allowed under Reg 6(4) of FSS import regulations?
      • Name and address of the importer
      • FSSAI license & logo 
      • Veg Logo or Non-veg Logo
      • Category or sub category along with generic name, nature and composition for proprietary food 
  • What are the additional rectifications allowed by FSSAI as per the recent order dated 02.05.2018?
Complete address of the manufacturer and/ or packer 
      • Importers should substantiate the complete address of the manufacturer and/ or packer with relevant documents like invoices, ingredient list, certificate of analysis, bill of entry etc.,
Lot/code/batch identification  
      • In case of no specific prefixes (like batch/ lot/ code) were mentioned alongside the number on label, the importer should provide an e-sanchit stating the number appearing on the label is lot/code/ batch
Date of manufacturing/ packing  
      • During instances like the date of manufacturing is either embedded in the batch code or not provided on the product label, the same has to be substantiated with relevant documents like COA, declaration from manufacturer etc.,
Declaration regarding food additives 
      • If class titles of additives are not provided on the product, the importer should provide relevant documentation along with declaration from the manufacturer for FSSAI to validate 
  • What are the advantages of this rectifications to the Importers?
      • Ease of doing trade by rectifying the labels in advance and mitigate the risk of non-compliance, demurrage etc.,
      • Swift movement of containers will lessen the traffic at ports & container freight stations (CFS)
For more information please write to smartcomplianz@outlook.com or call us at 040-48560467, Link to the FSSAI notification
  
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