"As awareness grows about food safety issues, the need for countries to provide greater assurance about the safety and quality of food also grows....This brief reviews (1) how India utilizes the international framework for food safety standards set forth by the Codex Alimentarius Commission (hereafter referred to as Codex), and (2) how India provides safety assurances for exports and promotes access to international markets for exporters." from TextFood safety ,food security ,Public health ,

Sareen, Shashi

English

Research Papers in Economics

FOR FOOD,AGRICULTURE,
AND THE ENVIRONMENT
FOCUS 10  •  BRIEF 11 OF 17  •  SEPTEMBER 2003
FOOD SAFETY IN FOOD SECURITY AND FOODTRADE
Case Study: India Responds to International Food Safety 
Requirements
SHASHI SAREEN
A
s awareness grows about food safety issues,the need for
countries to provide greater assurance about the safety
and quality of food also grows. The increase in world food trade
and the advent of the Sanitary and Phytosanitary (SPS)
Agreement under the World Trade Organization (WTO) have
also raised interest in food safety requirements.To ensure a
strong presence in global markets,India realizes the need to
meet these challenges and keep pace with international develop-
ments. This brief reviews (1) how India utilizes the international
framework for food safety standards set forth by the Codex
Alimentarius Commission (hereafter referred to as Codex),and
(2) how India provides safety assurances for exports and pro-
motes access to international markets for exporters.
CODEX STANDARDS AND INDIA’S FOOD 
SAFETY SYSTEM
The SPS Agreement provides for harmonization of the SPS
measures of member countries with the international stan-
dards set by Codex.The Agreement, however, allows members
to lay down more stringent standards than those of Codex,
providing they can be scientifically justified (see Brief 5).
In India, international standards, guidelines, and recommen-
dations are increasingly used to guide domestic as well as
international trade. The Directorate General of Health
Services in the Ministry of Health and Family Welfare is work-
ing to integrate Codex standards into national food laws as
much as possible.Where specific local needs justify more strin-
gent requirements, specifications are being fixed based on sci-
entific data. India is now reorienting its food laws to empha-
size food safety as well as food quality. National standards for
both domestic and export trade lay down parameters for pes-
ticide residues, antibiotic residues, heavy metals, aflatoxin,
pathogens, and other contaminants.
The Export Inspection Council of India (EIC), the official
certification body for exports, is developing standards for
exports based mainly on Codex, but it also takes into account
that an importing country may impose stiffer requirements.
Because Codex standards are increasingly used as a bench-
mark for global trade,India has increased its participation in sev-
eral Codex  committees to ensure that domestic conditions are
reflected in the development of international safety standards,
thereby facilitating acceptance of Indian products in global markets.
At Codex meetings,India has proposed that risk assessment stud-
ies be conducted in developing countries and that the resulting
data be taken into consideration when framing Codex standards.
Within India,risk analysis and setting of national standards are
supported by new data generated at several research institutes.
The Hazard Analysis Critical Control Point (HACCP)
approach has been recognized by Codex as a tool for assessing
hazards and establishing control systems that focus on preven-
tive measures rather than relying primarily on end-product
testing. Besides incorporating the HACCP approach into the
new hygienic codes, Codex is developing guidelines for applying
HACCP systems to small or less-developed businesses. The
Codex HACCP and food-hygiene standards have been adopted
by the Bureau of Indian Standards, the national standards body
in India. Food processing units are being encouraged to adopt
these systems on a voluntary basis.
EXPORT INSPECTION AND CERTIFICATION 
In view of the import controls being imposed by importing
countries,export controls have acquired renewed relevance.
Export certification,which had been made voluntary with liber-
alization,has once again been made mandatory by the Indian
government in sensitive areas such as marine,milk,meat,poultry,
and egg products and honey.
Inspection and certification in India has a regulatory basis
in the form of the Export (Quality Control and Inspection) Act
of 1963.The EIC was set up under this Act with statutory sta-
tus to certify the quality of products for exports. Under the
EIC, there are five Export Inspection Agencies (at New Delhi,
Kolkata, Kochi, Chennai, and Mumbai) that carry out inspection
and certification activities, with 41 suboffices and laboratories
to provide backup.All inspection agencies are gearing up to
implement ISO 17020, “General Criteria for the Operation of
Various Types of Bodies Performing Inspection,” issued by the
International Organization for Standardization (ISO), as well as
the Codex “Guidelines for the Design, Operation,Assessment,
and Accreditation of Food Import and Export Inspection and
Certification Systems.”   
The main system of export inspection and certification
being followed in the Indian food sector is the Food Safety
Management Systems-based Certification (FSMSC), which is
founded on international standards including HACCP, Good
Management Practices (GMP), and Good Hygiene Practices
(GHP). Under this certification system, exporting firms are
approved based on an assessment of how they measure up
against international requirements.Approval is normally grant-
ed for two years, and the responsibility for maintaining quality
lies with the firm. However, periodic surveillance, in the form
of monitoring visits, supervisory visits, and corporate audits, is
carried out to ensure continued conformity to the require-
ments.Through this system, international requirements are met
and rejections reduced at the importing end.
All units approved by EIC necessarily have to implement
HACCP/GMP/GHP at all stages of food production, in addition
to meeting end-product requirements.There are also various
export promotion bodies under the Ministry of Commerce
and Industries that assist processors in implementing safety
and quality-control systems.Today more than 1,000 units in
India have been certified for HACCP, of which at least 400 are
under compulsory export certification.
The export certification system is based on an HACCP
approach that requires the processor to deal with the hazardsarising from contaminants in the raw material as well as during
processing.Surveillance involves checking hygienic conditions in
and records maintained by the units,and drawing and testing
samples for various contaminants to ensure safety of the product.
The SPS Agreement encourages member countries to rec-
ognize the concept of equivalence in different safety measures.If
the exporting member objectively demonstrates to the import-
ing member that its measures achieve the importing member’s
appropriate level of sanitary or phytosanitary protection,the
importing member is obliged to accept these measures.India is
seeking equivalence agreements with the health authorities of
major trading partners. The EIC has already been designated a
competent authority by the European Commission (EC) for
marine products and basmati rice and by the U.S.for black pep-
per.For these commodities the EIC has the authority to approve
unit exports.It is awaiting similar recognition from the EC for egg,
milk,and poultry products. The EIC has also signed equivalence
agreements with Australia for marine products and with Sri
Lanka for 86 items.It is negotiating an agreement in various sec-
tors with Singapore and will soon have an agreement with Italy.
Under such agreements, in addition to recognition of EIC
certification, both sides will exchange information on specifica-
tions, methods of sampling, inspections and tests, provisions for
retest and appeal in case of rejections, and return of rejected
consignments. Such agreements facilitate trade and also lead to
less frequent inspection and rejection of India’s products in
overseas markets.
To meet these obligations,India needs to strengthen its reg-
ulatory framework.This process would include upgrading testing
facilities to meet international as well as importing-country
requirements;upgrading human capabilities or empowering per-
sonnel in areas of testing,risk analysis,and development and
auditing of HACCP plans;developing GMP/GHP/HACCP mod-
ules for implementation at both domestic and export levels;and
establishing databases on requirements of importing countries.
India is either funding these upgrades itself or seeking assis-
tance under programs funded by the Food and Agriculture
Organization of the United Nations (FAO) or the EC.Initiatives
include
• Upgrading of laboratories. Laboratories are being strength-
ened in terms of equipment,manpower,and systems.The EIC
laboratories used for export testing have been furnished with
state-of-the-art instruments.To meet the requirements for
testing,specifically for testing for chloramphenicol,nitrofurans,
and other antibiotics,the EIC labs and five other government
labs now have the capability to test at 0.02 parts per billion.
• Training and technical assistance. Training efforts in India
focus on developing and upgrading skills of industry and gov-
ernment personnel.A Human Resource and Quality
Development Centre has been established under the EIC. It
offers EIC certification personnel a chance to keep abreast
of the latest developments and take training programs for
implementing and monitoring food-product certification.
Similar training and awareness programs are being organized
for industry on various issues, including HACCP, testing, milk
quality, and rice quality.
• Establishing a database on importing-country require-
ments.Information on regulations and specifications regarding
methods of sampling,inspection,and testing in various coun-
tries is often unavailable or available only in the language of
the importing country.This lack of clarity about specific
requirements can sometimes lead to rejection at the point of
import.EIC is building a database of requirements of major
import partners that can be accessed by exporters.Technical
assistance in this area has been sought from the EC.
Some importing countries are imposing unjust measures
that conflict with Codex and impede trade. Some of these
measures include applying standards more stringent than
Codex without carrying out a risk analysis, destroying noncon-
forming consignments, imposing new requirements without
notification or information, and applying test methods that may
be different from internationally specified ones.To work out
solutions to such issues, India is entering into dialogue with
importing governments.
CONCLUSION
The safety measures described here have led to increased
export of food products and fewer inspections and rejections.
The impact has been especially significant in the marine sector,
in which export certification has been in operation since 1997.
In other areas such as milk and egg products, in which certifica-
tion has only recently been introduced, efforts are still under-
way to obtain recognition of Indian certification by the EC,
Australia, and other countries so that Indian products can gain
access to these markets.
In spite of all of the measures taken by India and other
developing countries to improve quality and strengthen safety
systems, rejections by developed countries continue as they
impose additional, new, and often unjustifiable SPS require-
ments. Such requirements include testing a wider range of
antibiotic residues, destroying rejected consignments, specifying
requirements without scientific justification, and using highly
sensitive test methods based on testing capability rather than
scientific need.These measures raise testing costs and lower
competitiveness of exports from developing countries.
India is trying to take advantage of WTO nontariff agree-
ments to address these obstacles.Thereby,Indian producers are
hoping to gain further access to global markets while providing
safe products.Developed countries need to recognize these
efforts and make their own efforts to facilitate trade,rather than
to impose new nontariff measures to protect their producers. ■
For further information see the Export Inspection Council
website at <www.eicindia.org>.
Ms. Shashi Sareen (director@eicindia.org, shashi_sareen@hotmail.com) is director of India’s Export Inspection Council.
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