Notification on "Standardization" of milk by Indian FDA

Details of the notification suggesting new labeling declaration on pre-packed milk

FSSAI has recently published amendments in the labeling requirements of pre-packed Milk. Further, it was mentioned in the notification that FSSAI has received representation from the industry on standardization of cow milk due to the practical challenges in attaining the product composition with desired legal specifications. In this context let us explore the details of the notification by understanding few areas of dairy technology and its economies

What is Standardization of milk?

Standardization of milk refers to the adjustment by either raising or lowering of fat and / or solids-not-fat (SNF) percentages of milk to a desired value in order to confirm to the legal or other internal specifications. Pearson’s square technique is widely accepted in the process of standardization 

Why is standardization of milk necessary?

The standardization of milk is commonly done to meet the market supply-demand and for manufacturing of other milk products like, condensed milk, milk powder, ice-cream and cheese etc., It is performed to obtain a uniform milk fat content in the finished dairy product so that the milk can be supplied to the consumers at affordable price and cater to large population. 

What are the factors that can impact the product supply and subsequently standardization?

Factors that primarily include kind of Species, Seasonal changes, Age of the cattle, irregularities in milking, lactation effect, udder diseases and psychological conditions

What is the notification all about?

FSSAI has earlier prescribed standards for Milk and Milk products dated 12th October 2017 which specifies the lower limits of Milk Fat & Milk solids not fat (SNF) for different classes of Milk. One has to give enough emphasis on the points mentioned near the table 2 (b) i.e.

1. The milk of different classes shall conform to the requirements for milk fat and milk solids-not - fat, “independently”, as specified in columns (4) and (5) of the table given below

Although, specifications for various classes were mentioned in the table including mixed standardized milk, FBOs should exercise caution in complying with the limits as specified independently in the table. For instance, if buffalo milk is being treated and packed by a business, then as per the table Minimum Milk fat and solids-not-fat shall be 6 & 9 percent respectively and accordingly the declarations on the labels are to be made i.e. buffalo milk

2. These standards would only be applicable at the points of sale

The specifications mentioned by FSSAI in the table would be applicable to pre-packed milk offered for sale to consumer and not at the collection centers. Hence, the product should comply with the declarations made when tested in an enforcement scenario 

To strengthen the above two points the Indian Food regulator have issued the current notification on 26th June 2018

“Point 3 of notification -  As the current regulations permit standardization to be specified Fat & Solid-not-fat (SNF) content only in respect of full cream, toned milk, double toned milk, skimmed milk and standardized milk, it is clarified that if milk and milk components used in the processing and standardization of these products are from the same species the name of the product may be preceded with the name of the species”

Alternatively, a declaration of “Made from___________Milk” (the blank to be filled with name of the species)

In the light of growing concerns among the consumers on the species of milk (A1, A2), these regulations would bring more clarity and transparency in the system. While specifying the name of the species on the milk packaging would open a pandora box and also create hardships for the industry (assuming FSSAI is seeking name of species in the notification and not the class). The reason being, unlike global regulators the Indian food agency doesn’t regulate the agriculture or farming sector (owing to inherent issues in the sector). As a result of this, the traceability to the species is challenging for both regulator as well as Industry. Further, currently there is no enough infrastructure to analyse & detect the exact nature of the species. 

In conclusion, recently the Indian regulator proposed to include animal feed into the FSS Act purview and it is more likely that even farming and agricultural practices may also become part of these regulations

For original notification, please click here 

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Special credits to the food safety professionals for providing the insights and contributing for this article

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