From: ASHA Kisan Swaraj <email@example.com>
Date: Wed, 8 Jul 2020 at 13:23
Subject: Concerns reg moves to ban loose sales of edible oil.
Cc: <firstname.lastname@example.org>, <email@example.com>
To: July 8th 2020
Ms Leena Nandan,
Department of Consumer Affairs,
Ministry of Consumer Affairs, Food & Public Distribution,
Government of India.
Sub: Centre’s advisory to the states asking edible oils not to be sold in loose form – Reported move through the Inter-Ministerial Panel set up for the purpose to ban loose sales of edible oil – reg.
Greetings! This is with regard to various media reports that have informed citizens about your Department’s advisory to state governments on July 2nd 2020 requesting “that prevention of adulteration may be enforced and the concerned officers may be directed to ensure that the edible oils meant for sale as pre-packed commodity are sold in their prescribed sizes and not in loose form”. We have not found this advisory on your website, and if it is only about oil that is meant to be sold as pre-packed commodity being sold in loose, that is one matter. However, a perusal of media reports and statements by Solvent Extractors Association of India which has investors in large scale processing of oilseeds and big oil brands as its members, indicates that there is a move to completely ban edible oil sale in loose form. It is to this latter proposal that we address this letter to.
While under Food Safety & Standards (Prohibition and Restriction on Sales) Regulations 2011, the FSSAI has prohibited under Regulation 2.1.1. a mixture of two or more edible oils as an edible oil, notwithstanding the provisions of 2.7 of labelling and packaging regulations, and with provisos that in respect of admixture of any two edible vegetable oils as one vegetable oil where the proportion by weight of any vegetable oil used in the admixture is not less than 20% by weight and the admixture is processed or packed and sold by certain agencies listed/authorised by the Department of Civil Supplies, or oilseeds growers’ entities or public sector undertakings in sealed packages weighing not more than 15 litres along with other conditions.
Further, under 2.3.15 of the regulations, special provisions relating to sale of vegetable oil and fat were laid down, wherein it was stated that no edible oil sale can take place which is not packed in a container, marked and labelled in the manner specified in regulations, with the additional provision that state governments may, in public interest, for reasons recorded in writing, in specific circumstances and for a specific period may exempt any edible oil from the provisions laid down.
Against this backdrop, the following are the issues that we would like raise, to express our concerns and objection to these regulations and latest developments:
1. It is clear that market spaces are not to be closed down for small players who are not going to get into the domains occupied more and more by big corporations and food brands. It is these small traders who in turn manage to support the daily needs of poor consumers who don’t find any support in supermarkets with branded, packaged produce. It is therefore a matter of protecting the interests of small traders as well as poor consumers. The small traders have their own unique ways of addressing their market needs and closing down their products will mean closing down their markets too eventually.
2. It is nobody’s case to argue that adulteration will never happen before being packed and branded. Packaging is not a fool-proof mechanism against adulteration.
3. In fact, there is a thin line being treaded between adulteration and blending right now, with well known edible oil brands not revealing either the proportion or the ingredients of blending as full disclosure to consumers. However, as long as it is being packaged, this is being allowed and it is not termed as adulteration! There is no regulation today that requires a full disclosure and there is no move to tackle this. Cheap imported (unhealthy) palmolein oil and unsafe genetically modified oils are used in the blending without any assessment being done by regulators on the safety of such foods, undisclosed and without any regulation of such illegal foods.
4. The chemicals used for processing (“refining”), or as preservatives are not being tackled for their harmful effects, and there is clearly an unscientific presumption that certain industrial processes are better than some traditional systems that shun the use of these chemicals. For instance, hexane, one of the main ingredients of refining process is documented to have health implications. There is limited but worth-exploring evidence to suggest that the risk of coronary heart disease increased in India after edible oil trends have changed towards industrially produced packaged refined oil. These are in fact areas worth studying by the health ministry.
5. There is a lot of debate to be had on packaging materials and their impact on health and environment too. Leaching and dissolving of plastic into the oil is not being discussed at all. Presenting packaging as a solution for all settings is in fact unscientific other than being unsustainable.
6. There are entire supply chains which rely on a completely different system of oilseeds and oil supply from farmers to consumers and that includes traditional processing and cold pressed oils. A blanket ban of the kind being proposed will affect such a system which actually promises better nutrition and food safety without chemicals/blending.
7. In countries like USA, bulk vending is allowed and specific regulations are stipulated for that.
In the recent past, aware Indian farmers, processors and consumers have opted to go back to traditional foods, traditionally processed foods and also into market interfaces that protect the environment by shunning unneeded packaging. This allows poor consumers to also buy locally, in smaller volumes that suit their pockets. These systems are about atmanirbharta, a concept well enunciated by India’s Prime Minister. Such systems are not only about self reliance and sovereignty, but also of nutrition security and ecological sustainability. Meanwhile, it is also clearly the duty of the government to check for adulteration and other malpractices without resorting to blanket bans.
We write to you to object to any plans for a blanket ban on loose sales of edible oils, and demand that our regulations in the name of prevention of adulteration and food safety be embedded on India’s unique conditions of production, processing, marketing and consumption. The corporate, branded food world will readily lobby for borrowed western frameworks to suit their profiteering interests and big capital, but regulation has to incorporate the reality of small players and all citizens.
Ananthasayanan Usha Soolapani
A2, Ananti apts, OD-3, Jawahar Nagar,
5, Eldams Road, Alwarpet, Kowdiar P. O .
1. Secretary, Ministry of Health & Family Welfare – Email: firstname.lastname@example.org;
2. CEO, Food Safety & Standards Authority of India (FSSAI) – Email: email@example.com