By Ashmeet Kapoor, CEO of I Say Organic
The FSSAI (Food Safety and Standards Authority of India) is in the midst of creating regulations for Organic Food in India, for which they came out with a draft a few months ago, and will be enforcing them soon if the buzz is to be believed.
Let’s first look at what “regulation” means when certification for organic food has existed in India for so long. As organic consumers, you’re likely familiar with the “India Organic” logo that is on many products sold as organic. The presence of that logo indicates that this product has been certified to meet the standards defined by India (under APEDA) for organic food. However, despite certification, what has been lacking so far is regulating the use of word organic. So anyone can use the word “Organic” without having to comply with any standards or certifications. Many companies dealing in organic products have come up with their own terms, often as an attempt to be able to be more transparent. Some examples of these are Natural, Near-Organic, Non-certified Organic, Organic by Trust, Default Organic. While the intent is to be transparent, my assessment based on various interactions is that these have largely confused consumers and made them believe that the term organic is just indiscriminately used. I should add that this isn’t just the case with organic. Terms like Healthy can be used on literally any food item. Many countries regulate the use of such terms as well.
I am of the opinion that regulating the term organic, and many other terms, is important. I also believe that certification for organic products is important – while a lot boils down to trust in any industry, setting standards is important. However, I also think, in the interest of food safety, standards need to extend beyond organic to chemically farmed products also. There should be transparency there as well, so consumers know how much pesticide is used, whether the seeds are genetically modified or not, whether the fruit is naturally or artificially ripened.
Let’s just look at the organic regulations that have been proposed, and will be enforced any day now. It’s fairly simple. Anything being sold as organic needs to be certified organic, under one of the two acceptable methods of certification – third party or PGS (participatory guarantee system). The certifications validate that the product meets the standards set by the government, referred to as the NPOP (national program for organic production). Third party is when an accredited agency audits farms, traders, processors etc to ensure they meet all the standards. And naturally, there is a cost associated. PGS was started as an alternate system primarily for clusters of smallholder farmers who find the certification costs prohibitive. They self organize in groups and certify each other. The caveat being that if even one of them is found to not comply, then they all lose their certification. So far, PGS had been only for farmers, meaning that if companies like I Say Organic were buying from PGS farmers, they couldn’t use the PGS logo for their products. This is now likely to change, which is great! There are some other details the implications of which are currently grey. What if we use some third party and some PGS products to make a processed item, like a cookie? Who certifies this? How do the two systems marry? This should get clearer as things unfold further. Overall, I feel this is a good first step, as it sets a standard, and over time it should help build some trust in consumers. I have a few issues though, with certification and with this regulation.
- No regulation for incorporating “Organic” in the brand name
Many companies make some organic and some non organic products, and indicate it honestly somewhere on the package, however their brand name has the word organic, which either gives the wrong perception that everything they sell is organic, or causes some level of mistrust from more discerning consumers. Worse yet, there are some food or cosmetics companies with “organic” in their brand names, but nothing they sell is organic. While they don’t claim the products to be organic, the brand name definitely builds a different perception. I for one have been quite turned off by several such companies when upon reading their labels it was pretty evident that nothing about those products was “organic” as per how it ought to be defined. The proposed regulations don’t address these issues. I know this is a problem because we get people at our store asking for certain products and brand, and when we tell them the reason is that they’re not organic, they’re shocked! I understand that this will add complexities to businesses as there are cases when certain specialty products are only available with non certified farmers, but I feel in interest of consumers, brands shouldn’t be able to call themselves organic if what they sell isn’t. I think it’s alright for a brand to say that this product is organic without certification, if they are willing to give their guarantee, and the FSSAI should then hold them accountable to their due diligence and claims. But to sell something chemically grown under a brand that uses the word organic is just not ok! Under the current regulations, companies will be able to do that.
- Organic companies can’t blindly trust certification
I recently wrote this article explaining that a lot of effort by companies like ours is spent on building trust, and why we spend so much energy and time in farmer selection, which actually is a trade off with business growth. It would be great, if certifications and regulations were made in a way that added some level of validation to make it easier for us to trust who we are sourcing from. Certification has loopholes, and doesn’t ensure, in my opinion, that the product will definitely be organic. So, at I Say Organic, we spend a few months doing our own audits, relationship building, lab testing etc. before we start sourcing from the farmers, and these activities continue even after. If the authorities could address these loopholes better, so that we could trust certification more, the landscape would become more business friendly. In the current scenario, the implication is, that if a company is found to be selling a product that has residue of chemicals, the company and the certification agency will both be penalized, and blacklisted. Yes, regulations like these are also needed, but the joint liability doesn’t make sense to me. If the company bought certified products and didn’t do anything unethical, should not only the certification agency and the farmer be penalized? Also, while the penalties might be imposed on various entities, the brand image of the company will be tarnished as soon as the news makes headlines, even if the company had the most genuine intentions. The ideal scenario would be to conduct an investigation to determine where the breach happened. Otherwise, certification will become merely a formality for us, without actually adding much value, as we’ll never be able to fully trust it. We will happily comply, as it is a good move towards building consumer trust towards organic labels. But we’d be delighted when these regulations can be crafted to also make things smoother for businesses, without compromising on authenticity.
- Residue levels for organic are not defined
There is another big issue that’s not yet gotten addressed by the certifiers or the regulators. In our effort to offer authenticity, we regularly get lab tests done. What that means is that lab technicians come to our warehouse and pick up samples, and then test them in their facilities for residue levels of various chemicals. While we get the reports, there is no standard defined for what the residue levels should be for the product to meet organic standards. The FSSAI defines what the maximum residue levels should be for vegetables but not for organic, and of course the acceptable levels for organic should be much lower. The best we can do is look at the standards of another country, but what India defines as acceptable residue levels is unclear still. Some of you might be wondering – why should an organic product have any residue? It’s because there are chemicals in the atmosphere from the water to the air, that produce comes in contact with from the time it’s planted to while it’s getting harvested, transported, packaged. So nothing can be really fully without any residue. While we’re at it, let’s just set the standard for residues as well!
- Transaction Certificates for fresh produce
This point is slightly technical. Each transaction between an organic buyer and supplier is validated with what’s called a Transaction Certificate (TC). So, if I Say Organic is buying 1,000 tonnes of Red Rice from farmer Pinku, the respective certification agencies get involved to validate this transaction, ensuring that Pinku was in fact growing red rice and got it certified, and I Say Organic has been accredited to sell certified red rice. I Say Organic then gets the TC as proof that the red rice they have is organic. Only then can I Say Organic put the “India Organic” certification logo on this product. This works great for non perishable products. However, this is not practical for fruits and vegetables because the transactions are too frequent and this process would make them more cumbersome (and dealing in fresh produce is already quite complex!), and since new TC’s will be needed pretty much everyday, the cost implications would mean that consumers will have to pay more. We’ve spoken to certifiers and policy makers (in casual friendly conversations) and they have agreed that this is not practical and that we should not get into the hassle of TC’s for fresh produce. And that’s fine because anyway we’re not packaging them and don’t put the certification logo on them. But, I don’t need to explain why this is a loophole. It would be great if the policies can clearly state the regulations for fresh produce as well.
Overall, the move to regulate organic fills a much needed void. We hope this is only the beginning and the momentum to standardize the food industry at large and ensure food safety for the nation keeps growing. I hope the regulations also get extended to not allowing brands to use the word organic if their products aren’t. I also would love to see terms other than organic, that have been used indiscriminately just for marketing purposes without any real meaning – like natural, whole grain, real, healthy etc. get strictly defined soon!