ASHA’s response to the Draft National Policy Framework on Agricultural Marketing
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From: ASHA Kisan Swaraj<asha.kisanswaraj@gmail.com>
Date: Sun, Dec 15, 2024 at 8:49 AM
Subject: Draft “National Policy Framework on Agricultural Marketing” – Public Comments
To: <surendrak.singh@nic.in>
Cc: <fa.kidwai@nic.in>
To:
Shri Surendra K Singh,
Dy. Agriculture Marketing Adviser and
Convener of Drafting Committee,
Department of Agriculture & Farmers’ Welfare,
Ministry of Agriculture & Farmers’ Welfare,
Government of India.
Dear Shri Singh,
Namaste. This is about the Draft National Policy Framework on Agricultural Marketing that has been put out by you on 25th November 2024, with public comments and feedback to be received within 15 days. While 15 days is a short time window for a matter of such great importance to farm livelihoods of millions of farmers across India (and without adequate publicity, the draft would have reached many farmers’ organisations only in the recent past), we assume that these are 15 working days and that we are within that time period for you to take cognisance of the comments being shared here.
At the outset, we would like to state that even a quick glance through the document clearly shows that it is an attempt by the Union Government to revive its agenda of de-regulating agricultural markets, and leaving the farmers at the mercy of corporate players. We went through the document carefully to understand the proposals.
1. The draft policy takes cognisance of the fact that Agricultural Marketing is a state subject under Entry 18 of List II (State subjects) under Seventh Schedule in the Constitution of India. This is of course welcome, given the fact that the Government of India had refused to accept this when the three farm laws were forced upon state governments and farmers of the country. However, for this to be followed in letter and spirit, this National Policy Framework itself should have been drafted in widespread consultations with state governments! It does not appear to have been done so. (Reference: Page 3, Chapter 3 Mission).
2. The fact that the Draft Policy Framework does not talk about Regulation of agricultural markets as a key strategy reinforces our apprehension that the repealed farm laws are being brought in once again through a backdoor entry. It is clear that competition gets enhanced by visibilising trade transactions. Such visibilising requires government oversight and regulation. Without regulation, talking about multiple channels of marketing which can also be exploitative as well as deceitful, does not fulfill the stated vision of the draft policy.
3. A legal entitlement for all farmers with regard to MSP is a long-pending demand of farmers, as you are aware, and if this policy framework is to enable farmers to realise best price for their produce, the benchmark has to be set at MSP at least. This draft does not take this demand of legal guarantee of MSP into consideration at all, and this needs to be addressed.
4. The draft policy framework focuses on institutional reforms, and does not specify what the Union Government will do specifically towards bridging marketing and auxiliary infrastructure gaps in terms of financing and supporting state governments. (Reference: Mission Statement 3.1 on Page 3 and Point 4.2.1. on Policy Interventions)
5. The Mission objectives do not mention international trade policies and commitments of the Government of India. This is a serious lacuna in this draft policy framework. There are highly unpredictable bans and other restrictions imposed on exports from India, and lowering of import duties on products from elsewhere which are often unjustly subsidised by their respective governments. This draft policy does not have any clear commitments to making such trade-related decisions keeping farmers in mind for the Vision to be fulfilled. This applies to many upcoming free trade agreements too.
6. Situational Analysis under 4.1 correctly identifies that the issue of data unavailability with regard to unregulated wholesale markets in some states (4.1.2 on page 5). Further, the problem statement in 4.1.5. on Private Wholesale Markets is also related.
However, in the draft policy, there are no proposals to address these issues, even as private markets or unregulated markets are promoted in a non-reasoned manner. It is not clear how the acknowledged problems can be addressed without regulation of these markets whereas regulation does not find any mention in the draft policy.
7. About Farmers Direct Markets to Consumers (under 4.1.6 of Page 6), there is a broad-brush statement made about lack of infrastructure facilities, whereas there are published papers that are showing the importance of Rythu Bazaars for perishables, with the kind of facilities that have been envisioned in undivided Andhra Pradesh when such Bazaars were started, including free transportation facility for registered farmers. The Situation Analysis should have acknowledged that where infrastructure facilities have been provided for direct marketing by farmers, there is evidence pointing to farmers benefiting substantially. Such investments are what are expected from the government.
8. Under 5.1.1. related to Value Chain Centric Infrastructure, the policy draft should have firmly committed to FPOs being supported in an all-out manner for VCCI because it has emerged that primary processing alone is not bringing substantial benefits to FPO members in many cases. However, this is not made into a central strategy.
9. Under 6.1.1. related to value addition and food processing in APMCs, FPOs should have been a focus and PPP expanded to become Public-Community Partnership (PCP). However, this is missing.
10. For Marketing of Organic Produce (Policy Intervention 6.1.3.), it is important to have segregated facilities with traceability maintained for organic produce throughout the supply chain. Under 6.2.1., despite the clarion call given by the Prime Minister to farmers of India to shun agro-chemicals and opt for organic/natural farming, the entire responsibility has been put on state governments, without specifying how the Union Government is going to support this initiative.
11. Reform Initiatives in Agricultural Laws (under 7.1.2) is essentially an attempt to revive the key provisions in the Farm Laws that had to be repealed, owing to farmers’ resistance. These were resisted because the government was giving up its responsibilities in protecting farmers’ interests and presenting de-regulation as an answer. Private markets under 7.1.3.1, Whole direct purchase by processors/exporters/organised retailers/bulk buyers from farm gates under 7.1.3.2, Deemed Market Yards under 7.1.3.3, Deregulation of Perishables outside the market yards under 7.1.3.10 in the draft policy frameworks, are some examples for this. The policy thrust on non-restrictive business-oriented uniform rules is also an illustration of revival of key elements of repealed farm laws.
Meanwhile, the Table under 7.1.3.12, on the status of adoption of reforms, clearly indicates that such reforms have not provided a solution to the market woes of farmers even where they have been adopted and rules notified. Therefore, it is not clear why the draft policy framework is stressing on the same so-called reforms.
Given this background, the effectiveness of an “Empowered Agricultural Marketing Reform Committee” a la GST Committee is questionable. (Refer to proposal 7.2.2. on page 18). This proposal seems to be a method through which all BJP-ruled states can be coerced to accept the Union Government’s proposals, so that any resistance at the national level due to genuine issues can be ignored and sidelined.
12. “Ease of doing agri-trade” (Chapter 8) cannot be at the expense of protection of farmers’ interests. Whereas an Index is being proposed for this purpose of ease of doing agri-trade, no such Index has been created or proposed to be created for farmer-centric farmer-empowering markets to begin with.
13. Promotion of Contract Farming (under Chapter 10) once again reeks of revival of one of the repealed farm laws around Contract Farming.
In conclusion, ASHA-Kisan Swaraj suggests that the Ministry of Agriculture and Farmers’ Welfare not proceed with this draft policy framework, since it is an attempt at reviving the massively-rejected agri-market reforms that were contained in the three infamous farm laws which had to be repealed.
Sincerely,
Dr Rajinder Chaudhary &
Kavitha Kuruganti,
Co-Convenors, ASHA
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Alliance for Sustainable & Holistic Agriculture (ASHA-Kisan Swaraj)
FOOD – FARMERS – FREEDOM
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