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by Kavitha

More than 50 organic farming entities write to FSSAI on its draft regulations on organic foods

12:34 pm in News by Kavitha

To:                                                                                                     May 30th 2017


The Chief Executive Officer,

Food Safety and Standards Authority of India,

03rd Floor, Food and Drug Administration Bhawan,

Kotla Road, New Delhi – 110002




Sub: Draft Organic Foods Regulations 2017 – Mandatory certification/PGS neither viable nor guaranteed to provide “organicity” – need greater exemption from this proposal – reg.


Ref: FSSAI’s Draft Food Safety and Standards (Organic Foods) Regulations, 2017 – F.No.CPB/03/Standards/FSSAI/2016



Dear Sir,


This is with regard to FSSAI’s notice calling for suggestions, views, comments etc. from stakeholders on its draft regulations related to Organic Foods. We had in the past communicated our views with the FSSAI ( and would like to reiterate a few points once more:


  1. At the outset, we would like to emphasise the importance of the current issue under discussion, and the ramifications that this has in future too. This then deserves wider consultations and not just the one that was done in Delhi in December 2016. FSSAI should be going to at least those states where organic farming is being promoted and practised on a large scale, to take up wider consultations before it freezes its proposals related to regulating organic foods in India. We hope that this suggestion from our side will be taken up seriously by the Authority.


  1. Organic agriculture and produce contribute tremendously to the mandate of FSSAI – that of ensuring safe food for all. We find that FSSAI is showing undue haste in wanting to regulate organic produce, without first providing any rationale for how fake organic produce is going to endanger food safety nor what is the extent of problem of fake organic in India, based on sound scientific evidence. We are concerned about this because we believe that organic agriculture is in a nascent stage and needs a lot of support to grow, and not impediments that curtail its growth, in the name of regulation or anything else. On the other hand, we find that FSSAI has not taken any pro-active action so far with regard to hazardous foods like pesticides-laced food or GM foods.


  1. Current quality assurance systems like third party certification or Participatory Guarantee System (PGS) do not really enhance the authenticity of organic, for the simple reason that there is an inbuilt conflict of interest in both the systems. Therefore, consumer interests do not necessarily get protected by making adoption of either system as mandatory as per Indian regulations.


Both of these have serious implications for smallholder organic farmers, who are not organized and have no external hand holding by government or civil society groups or the FSSAI. The PGS system is of course preferable compared to the third party certification system in that it at least builds a peer support system for beginners and others. The onus of providing PGS support to every last farmer who wants to opt for organic agriculture should then fall on the concerned State agencies, which currently is not the case. No department is obligated to ensure PGS facilitation as of now for those farmers who want to shift to organic outside the scheme-based support. Meanwhile, third party certification continues to be expensive, except in its group certification form, which would mean the same situation as PGS as far as individual farmers desirous of shifting to organic are concerned. Given this big gap between the need to shift more farmers to organic farming and the actual support systems on the ground, it is not advisable for FSSAI to make either of these quality assurance systems mandatory.


  1. Quality assurance can be enhanced by setting up a lot of testing facilities that are accessible to all citizens, as well as education of consumers whereby they understand that traceability is an important component of quality assurance. FSSAI somehow refuses to work along these lines assuming that it is not in their mandate to be doing so (setting up labs or getting citizens access to affordable testing facilities) – in reality, this would facilitate FSSAI’s mandate enormously, with active citizen involvement.


  1. It is important to note that the organic supply chains usually are direct, from production to retail in the current scenario, except in the case of branded organic products which take up direct retailing spaces or supply to (organic) food retailers. To that extent, traceability is a more important component than certification ridden by conflict of interest. To that extent farmers should be able to self-certify themselves and sell through retail entities. Apart from PGS/third party certification with their built in traceability systems, and direct marketing which brings consumers face to face with their producers, retailers within an annual turnover cutoff (put in an exemption category) can be mandated to maintain traceability through display board with all relevant details of sourcing with no requirement for mandatory certification/guarantee through PGS.


  1. PGS-Organic Council, which was a precursor to PGS-India, should also be notified straightaway as a valid quality assurance system that is already in place.


  1. 7.   It is not out of place to point out that FSSAI neither is authorized to, nor capable of regulating anything at the production end. The statute itself keeps farmers out of the purview of the Act. To create regulations that are based on production end processes is therefore questionable.  


  1. It would be useful if FSSAI actually lays down better regulations for organic certification agencies and insists on sample testing of organic produce within the certification procedures laid down (this is the case in European, Chinese and American regulation of organic, as pertaining to certification agencies’ responsibilities and procedures) rather than insist on mandatory certification.


  1. We are attaching our key suggestions/comments on the draft regulations in the prescribed formats, apart from sharing our earlier correspondence on the subject. Our main demand is that FSSAI regulate the big players in the organic sector at this point of time (using a cut-off related to turnover of an entity) without stifling the producers or small retail related to organic in the name of mandatory certification/guarantee. Such a cut-off on turnover should be revised upwards periodically.




Kavitha Kuruganti, Alliance for Sustainable & Holistic Agriculture (ASHA)


  1. Anantha Naturals Private Limited (Bio Basics), Tamil Nadu
  2. Aruna Rodrigues, Sunray Harvesters, Madhya Pradesh
  3. Banyan Roots Organics, Udaipur
  4. Bhoomgaadi Organic Farmers Producer Company Limited, Dantewada, Chattisgarh
  5. Buffalo Back, Bangalore
  6. Chaitanya, Green Current, The Organic Lifestyle Store, Mumbai
  7. Daxin Gujarat Sajiv Kheti Samaj, Tanachha
  8. Dharamitra and 500 associated farmers, Maharashtra
  9. Dilip V. Gode, Environment Conservationist

10. Dr Rajinder Chaudhary, Kudarti Kheti Abhiyan, Haryana

11. Dr Suhas Kolhekar, National Alliance for People’s Movements (NAPM)

12. Dr V S Vijayan, Salim Ali Foundation, Kerala

13. Earthcare Books, Kolkata

14. Go Organic Life, Chennai

15. Grainny’s, Gurgaon

16. Gurgaon Organic Farmers’ Group, Gurgaon

17. Jatan: A Mission for Organic Farming

18. Karnataka Alliance for Safe Food

19. Kerala Jaiva Karshaka Samithi, Kerala

20. Kheti Virasat Mission, Punjab

21. Kudrati Kheti Haat, Punjab

22. Living Farms, Odisha

23. Madhu Farms, Gandhi Asramam, Pollachi

24. Madhusoodhanan K, Dhaanyam Superstores Private Limited, Chennai

25. Madhya Gujarat Sajiv Kheti Samaj, Nadiad

26. Mahila Kisan Adhikaar Manch, India

27. Nanmai Organics, Tirupur

28. Nityanand Jayaraman, Chennai Solidarity Group, Chennai

29. OFM-Organic Farmers Market, Chennai

30. Oovya Farms, Gandhi Asramam, Pollachi

31. Organic Farmers and Nagpur Seed Festival Group, Maharashtra

32. Organic Farming Association of India

33. Purva Naturals, Divansapudur, Pollachi

34. Ramkrushna Trust, Madhapar, Kutch

35. reStore, Chennai

36. Rythu Swarajya Vedika, Andhra Pradesh

37. Rythu Swarajya Vedika, Telangana

38. Sabarkantha Sajiv Kheti Manch, Modasa

39. Safe Food Alliance, Tamil Nadu

40. Saro Mangal Farms, Gandhi Asramam, Pollachi

41. Saurashtra Sajiv Kheti Abhiyan, Gujarat

42. Shantigram Nirman Mandal, Tanachha

43. Slow Food, Udaipur, Rajasthan

44. Sriram Foods, Divansapudur, Pollachi

45. Thalanmai Uzhavar Iyakkam, Tamil Nadu

46. Thanal, Kerala

47. Tharcharbu Iyakkam, Sirkali, Tamil Nadu

48. Upavan, Gurgaon

49. Valam Community Farm, Chennai

50. Valam Organic Stores, Chennai

51. Vanvadi Agro-ecological Regeneration Association (VARA), Maharashtra

52. Vedha Vanam, Tirunelveli




Sr No. Name and Address of the organisation/person, contact number and E-mail Relevant section in the draft notification on which comments are being provided Comments/ Suggestions Rationale
1 & 2 Kavitha Kuruganti,







Address: A-124/6, First Floor, Katwaria Sarai, New Delhi 110 016.


Res: #302, Santhome Apartments, 33/1, 1st A Cross, Indiranagar I Stage, Bangalore 560038.

Chapter II. 4: Any food offered or promoted for sale as ‘organic food’ shall comply with all the applicable provisions of one of the following:

i. National Programme for Organic Production (NPOP);

ii. Participatory Guarantee System for India (PGS-India);

iii. Any other system or standards as may be notified by the Food Authority from time to time.

However, organic food that is marketed through direct sales by the original producer/producer organization to the end consumer is exempt from the need of verification of compliance. This exemption does not apply to processed organic food products.

ADD PGS Organic Council as II.4.iii. as an already recognized system.



DELETE the exemption restriction related to processed organic food products.






ADD exemption to retail sales of organic produce within an annual turnover of 2 crore rupees. This cut-off criterion is to be revised upwards periodically.

“However, organic food that is marketed through direct sales by the original producer/producer organization to the end consumer or to retail outlets within an annual turnover of 2 crore rupees (with this cut-off to be revised upwards periodically) are exempt from the need of verification of compliance”.


PGS Organic Council has been a long existing system, as a precursor to the PGS-India system.



There is no rationale for not providing the same exemption to the processed organic food products too, if an organic producer collective is able to procure various ingredients from its own members, take up processing and sell to end consumers, since original producers and producer organisations should indeed be encouraged to get into processing for greater incomes.



Since small retail sales of organic produce is as good as direct marketing to end consumers by organic producers themselves (not many other players in the supply chain), and is only an easier conduit for direct sales by producers without producers themselves having to take on this role also, this exemption on compulsory certification/guarantee should be extended to them, upto a tune of 2 crore rupees annual turnover. However, even here, branded produce may be brought under compulsory certification. Such a system is followed in the USA.



by Kavitha

Adopt farmer-centric, community based models while shifting subsidies from chemical to organic fertilizers: ASHA tells Pawar

2:22 pm in News by Kavitha

Alliance for Sustainable and Holistic Agriculture (ASHA) congratulated Mr Sharad Pawar, Union Agriculture Minister for his statement in the Parliament on shifting subsidies from chemical to organic fertilizers. The Alliance also urged the minister to adopt farmer-centric, community-based models while shifting subsidies from chemical to organic. ASHA, an alliance which stands for food, farmers and freedom, has always demanded a shift in subsidies to promote eco-friendly farming systems.

The Government support systems created as part of Green revolution were external-input-based and industry-driven. The system promoted indiscriminate use of chemicals destroying natural resource base, in addition to pushing farmers into a debt trap leading to agrarian crisis and serious implications on human health.

The subsidy on chemical fertilizers has grown by leaps and bounds in the last decade. From Rs 13,800 crores in 2000-01, it has grown to Rs.67,198 crores in 2011-12 (revised estimate for the year as per the Union Budget 2012-13), with a peak of Rs 96,606 crores in 2008-09, corresponding to the fluctuations in fossil fuel prices. This mindless investment has led to the indiscriminate use, and deterioration of soil health. The new Nutrient Based Subsidy (NBS) system brought in as part of a fertilizer subsidy reforms in 2010 failed miserably in addressing the soil health crisis. NBS indirectly promoted overuse of nitrogenous fertilizers, further worsening the crisis. On the other hand, farmers received hardly any support for adding organic matter in the soil which is vital in maintaining soil health.

“ASHA believes that it is good that the Government became is developing sensitivity to these issues and is planning to take steps in the right direction. In the recent past, Prime Minister, Finance Minister and Planning Commission all have emphasized the need for investments in ecological fertilization, and now the Agriculture Minister has also expressed his commitment. We hope these statements don’t end as rhetoric as it has happened in the past when it comes to support for ecological farming/ fertilization. First step forward is to ensure a basic change in approach and we welcome this”, said an ASHA statement.

ASHA demands:

- Creation of Grassroots institutions to mobilize communities to kick start an ecological farming revolution in the country

- Shift 50% of the subsidies for chemical fertilizers to organic manures to start with. The amount may be utilized in supporting communities, incentivizing farmers, developing decentralized production systems and regeneration of commons

- Set targets during the 12th Five Year Plan period to systematically replace chemical fertilizers with organic manures in contiguous farm lands

- Provide research support for ecological fertilization and promote traditional wisdom and support farmer innovations

- Investing upon and developing cattle wealth in the villages

- Discourage the burning of crop residues particularly in some parts of the country where the issue has reached serious proportions

- Take up all seed breeding research in organic conditions


Kavitha Kuruganti
National Convenor, Alliance for Sustainable & Holistic Agriculture (ASHA)
A-124/6, First Floor, Katwaria Sarai, New Delhi 110 016
Phone: +91-9393001550; email:

Notes to the editor:

· ASHA (Alliance for Sustainable & Holistic Agriculture), is an informal network of hundreds of organizations, farmers and individuals across twenty states of India. ASHA’s road map submitted to the government, specifically the Planning Commission for a large scale shift to ecological farming (under Kisan Swaraj Neeti) is available at

· Mr. Sharad Pawar’s statement on shifting of subsidies as reported in the media can be accessed at:

· “We must also recognize the risks of an excessive reliance on hydrocarbon inputs in increasing agricultural production and we should explore more systematically, organic alternatives…” — Prime Minister Dr Manmohan Singh on July 16, 2011 (ICAR foundation day)

· “There has been deterioration in soil health due to removal of crop residues and indiscriminate use of chemical fertilizers, aided by distorted prices. To address these issues, the Government proposes to promote organic farming methods, combining modern technology with traditional farming practices like green manuring, …” – Mr. Pranab Mukherjee, Union Finance Minister, Budget speech (2011-12)

· “The way forward is to rejuvenate soil and restore soil health through addition of soilorganic matter in bulk quantities…” – Approach Paper prepared by the Planning Commission for the 12th Five Year Plan (approved by National Development Council in October 2011 and available at Planning Commission website, )


KisanSwarajYatra: Movement for Food, Farmers and Freedom in India

4:07 pm in Video by Kirankumar

The Kisan Swaraj Yatra is a nation-wide mobilization drawing fresh attention to the continuing agricultural crisis in India, and calling Read the rest of this entry →