Saturday, June 30, 2018

Unfolding the myths of FSSAI logo on food products



Marketing and advertisement play a key role in the consumer purchase decision of a product. The concerned teams in these department work tremendously on the product presentation to influence the consumer perceptions. In this context, many pre-packed goods come up with claims attributing to its safety and quality. Subsequently, such marketing practices have created popular fallacies among the consumers. which was evident since decades. However, there is an increasing trend of informed judgment in light of rising awareness of end user.

In this article, we would like to dwell upon one popular misconception among consumers of food products i.e. FSSAI logo on food products. Much to our bemuse, people perceive FSSAI logo as symbol of safety and/or quality. Consequently, even budding Ayurvedic and Pharmaceutical manufacturers approach us for obtaining FSSAI license in spite of having a valid license from their respective regulators. Hence let’s breakdown and understand what FSSAI logo on food labels signify?

Need & procedure for obtaining food license in India
Like any business to takeoff food business too require licenses or approvals from various government agencies in India and the prominent one for food business is FSSAI license. It is mandate for food business to obtain food license prior to the operations and the same was ratified in the act, rules and regulations i.e. per 2.1.2 of FSS licensing regulations, no person shall commence any food business unless he possesses a valid license.
In this regard, it is very prudent that a Food business operator (FBO) should apply and obtain FSSAI license from the respective regional offices based on the eligibility criteria defined in these regulations. As on date, the Indian food governing body have implemented the online licensing portal and have taken every efforts to form a paper free process barring few states in the eastern region. However, FBOs often face challenges in the processing timelines and undue clarifications from the licensing authorities. Subsequently upon proper documentation 14 digit conditioned food license will be awarded to the applicant on an average of 30-40 days from filling the application with certain set of conditions.

What is a conditioned license?
In spite taking many self-declarations and undertakings from the applicant (FBOs) the licensing division grants a license with conditions to upkeep and retain the same. License holder failing to comply with any of the 12 conditions (Check your license copy or the following link The Food Safety and Standards Regulations) that the Authority have prescribed in these regulations the likelihood of revoking or suspension of issued license are higher. Hence, in a nutshell continuous improvement is required in the processes to retain the Food license. It can be deduced from the above that, the FBO
  1. Declare products are safe for human consumption
  2. Undertake the responsibility for safety of the product
  3. Guarantee compliance to the rules, regulations (incl. standards)
Hence, FSSAI doesn’t own the responsibility for the safety of the food manufactured by the FBO owing to the sector size which is predominantly unorganized. As an analogy, one can relate with IT returns filing where the applicant declares the income details and post-facto the IT department corroborates the declared figures with actual through a risk based inspection leaving a window for self-compliance.

Then, how does FSSAI regulate the FBOs?
Importance of self-regulation - As per IBEF the Indian food industry, this is currently valued at US$ 39.71 billion and is expected to grow at a Compounded Annual Growth Rate (CAGR) of 11 percent to US$65.4 billion by 2018. As a result not even an estimate figure can be deduced in the number of food business units in India. Hence, off-loading the burden of 1.3 billon meals per day (Average 1 meal a day) to FSSAI is not level playing and rather it should be a joint responsibility of all the stakeholders in the ecosystem.
Hence, shifting towards the trend of self-compliance FSSAI provides necessary guidance, support and information for the FBOs to achieve the common objective of food safety. In this regard, Food businesses are required to place continuous improvement procedures to demonstrate the food safety attitude of their respective organizations

Does FSSAI license really signify quality of the product?
Basis the above explanation, it is evident that the food Authority doesn’t certify the safety of the product rather it only reviews the product composition for compliance basis the declaration by the applicant. However, the agency involve in regulating the products via. enforcement & surveillance measures. Further, to empower consumers FSSAI has enabled a forum to launch complaints called citizen connect a medium to monitor the grievances of the consumers related to food. Although, there would be no knee-jerk reaction by FSSAI in this forum but however it is known that the authority would be collecting data and risk profile the FBOs basis this complaints.

To augment the above hypothesis on FSSAI logo, very recently the Authority has proposed changes in the FSS Act, 2006 and point no 36 clearly stipulates that an impression that food article is approved by FSSAI either in the form of whether orally or in writing or by visible representation is restricted and prohibited as per section 25 (d) (in the rationale the food agency has specified that misusing FSSAI logo and license )

Snapshot of the changes proposed by FSSAI on the license   

Basis the new regulations, it is crystallized that FSSAI license cannot be misused by the manufacture for demonstrating the safety or approval* status of the product. Hence it is recommended for the food businesses to withdraw such claims in on the websites, advertisement contents etc., as a preventive measure before FSSAI finalizing these changes.
In conclusion, it is unfortunate that only few players started advertising or marketing with words “FSSAI Approved” “Endorsed by FSSAI“FSSAI Certified” etc., and the rest is a cliché  

*Approval/ NOC issued by FSSAI product approval division is not considered in the blog

For more clarifications or to vet the claims & advertisement content of your products, please write us back or call us at 040-48560467

(All content provided on this blog is for informational purposes only. The owner of this blog makes no representations as to the accuracy or completeness of any information on this site or found by following any link on this site)


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