The government intends to notify the provisions of the Food Safety and Standards Act shortly. The Act essentially is an amalgamation of six different acts that today govern food safety standards in the country. Currently, regulations like the Prevention of Food Adulteration Act, 1955, Meat Food Products Order, 1973, Fruit Product Order, 1955, the Standards of Weights and Measures Act, 1976 and the Standards of Weights and Measures (Package Commodities) Rules, 1977 and the Drugs and Cosmetics Act, 1940, among others regulate processed food packaging in India. All these acts focus on quality control rather than quality management.
Quality management has three main components: quality control, quality assurance and quality improvement. Its focus is on product quality, along with the means to achieve it. Therefore, the thrust is on both quality assurance and control of processes as well as of products. This enables consistency in quality. The existing laws that have now been unified under the Food Safety and Standards Act contain little more than technical guidelines that specify the quality of the packaging material but ignore the packaging process altogether.
One of the fastest growing sectors in the Indian economy is the food processing industry. Since most of the processed food items require packaging, the growth of the food processing industry has triggered the growth of the packaging industry too. With rapid urbanisation, changing life styles, growth in modern format retailing and preference for home delivery, there has been an increase in the demand for more conveniently and safely packaged food items. According to the India Food and Drinks report, 2009 by BMI, the per capita consumption of packaged food products in 2013 is expected to be 55.4 per cent more than the level in 2008. However, existing regulations governing the packaging industry are obsolete, partly because of the narrow focus of these regulations and partly because they fail to take into account technological change and the rapid growth in the variety of foods that are now being packaged.
In addition, manufacturers in the food processing industry normally outsource packaging of their products to contract manufacturers. Usually, manufacturers specify technical guidelines on the material to be used; rarely do they specify the process to be adopted for packaging. Consequently, the possibility of adulteration always exists. Besides, it is not mandatory for manufacturers to specify technical guidelines. As a result, there is no uniformity in the packaging standards adopted by different manufacturers.
Far more importantly, enforcement of quality standards at different stages of the value chain fall under the jurisdiction of different ministries, making it impossible to enforce accountability. For example, most of the raw material for the food processing industry is procured from the agriculture sector. While the Ministry of Food Processing Industry is entrusted with the responsibility of ensuring quality standards in processing, it has no power to ensure that the raw material procured meets required quality standards. Take, for instance, the case of processing milk. The food processing ministry can ensure quality standards in the processing stage but has no powers to ensure that milk is collected in a hygienic manner. Inter-linkages across different sectors/industries are generally not reflected in the regulations for these sectors/industries.
In addition, there are no packaging specifications to ensure that the packaging material used is environment friendly. Nor has any attempt been made to ensure that packaging standards are so set as to take into account different retail formats. For example, a product might be stored in a well ventilated, air conditioned modern retail format as well as in the open in a local neighbourhood store. In this instance, inappropriate packaging can lead to serious consequences, as it did a few years ago for renowned packaged food processors like Cadbury, PepsiCo and Coca Cola. Their products were taken off the shelves after they were found to have been contaminated due to inappropriate packaging. Thus, it is important that the packaging standards for processed foods be suitable to India�s climatic condition and appropriate for storage across all kinds of retail formats.
This throws light on two important shortcomings in the regulations governing the packaging industry. First, there are no specific standards for quality management for the food packaging industry and second, there is no uniformity in standards. Therefore, more than simply unifying existing law, it is time the government completely revamped food packaging standards and guidelines with a decided shift in focus from quality control to quality management.