Suggestions and inputs on NCONF’s natural farming certification system

———- Forwarded message ———
From: ASHA Kisan Swaraj<asha.kisanswaraj@gmail.com>
Date: Sat, Aug 2, 2025 at 3:48 PM
Subject: ASHA Kisan Swaraj’s letter with suggestions and inputs on NCONF’s natural farming certification system
To: <subodh.kum@gov.in>
Cc: <nbdc@nic.in>, <drgagnesh.sharma@gov.in>, <agrimin.india@gmail.com>, <chauhansr@mpls.sansad.in>, <maninder.edu@nic.in>

To:

Shri Subodh Kumar,

Deputy Secretary to Govt of India,

Ministry of Agriculture & Farmers’ Welfare,

Government of India.

Email: subodh.kum@gov.in 

August 2nd, 2025

Dear Shri Subodh Kumar,

Greetings! This is with regard to the Natural Farming Certification System (NFCS) being proposed in India, as per a letter dated 9/6/2025 from you to seniormost officials of all states/UTs’ Departments of Agriculture. We would like to offer our inputs on NFCS in a constructive spirit, and we hope that the Department of Agriculture and Farmers’ Welfare will take this feedback from the ground, emerging from experiences of working with farmers in the agro-ecology movement in India and with the PGS-India system of certification, to make improvements in the NFCS. 

1. Please do not limit NFCS to only a few practices like Jeevamrit – Make non-chemical and non-GM farming as the non-negotiable common denominator: Despite whatever is written as Standards in one part of the document, the ‘Natural Farming Practices’ section in Annexure I reveal that the NFCS is being aligned almost exclusively to what was earlier called as ZBNF and subsequently SPNF, which assumes that only a few bio-inputs are a part of Natural Farming in India. The reality on the ground is that farmers are constantly innovating, and are even adopting systems from elsewhere, even as they are internalising the input preparation into their farming systems, or creating community level mechanisms which need not necessarily be BRCs alone. This includes Panchagavya, Go-kripamritha, some Korean methods for bio-inoculants, simple bio-digesters etc. Against such a reality of a large number of committed practitioners who are scientific, self-reliant and committed to natural farming, the emphasis on only a few practices in NFCS is unscientific and non-inclusive. Please do not penalise tens of thousands of natural farmers due to this design problem being built into NFCS. Emphasise mainly on the non-negotiable common denominator of non-chemical and non-GM farming. The prohibition of GMOs and products thereof should appear with equal emphasis all through the document. Following this, the importance of diversity-based farming should receive additional weightage, along with use of locally suited traditional varieties of seeds etc. 

The technical manual on natural farming has a much broader set of practices/inputs encouraged for natural farming. The certification document should align to these principles/practices there and more practices must be listed in Annexure I. Likewise, rather than putting livestock as local/exotic cow and other livestock, listing down which animals are being reared by the farmer household, and of which breed should be done. A farmer can have 2 local cows, 3 exotic cows, 1 pair of bullock, 2 local goats and 1 hybrid buffalo. The data captured should be able to capture all of these. Current data capture does not seem to be designed to capture these. The technical manual allows for tree, grass – which are not reflected in NFCS Annexure I.

2. Natural Farming as well as Organic Farming should ideally be self-reliant but procuring from anywhere other than BRCs is not necessarily a breach of the paradigm: In the NMNF program, the kharif season of 2025 has started but BRCs have not been initiated everywhere. Nor have the farmers enrolled everywhere received meaningful trainings that will allow them to make their own preparations. Inability to make all bio-input preparations may be the experience of farmers outside the NMNF program too, and it is not as though BRCs have been set up to cater to all interested natural farmers. In such a situation, limiting NFCS Standards to only those farmers who are preparing their own inputs or purchasing from BRCs is not advisable. After all, the ecological purpose of non-chemical farming, as well as provision of safe food for consumers is still being done. Therefore, the rating system in NFCS cannot be created on this basis. The problem is because the NFCS creation has relied too much on the CETARA system of Himachal Pradesh rather than think originally in an inclusive manner to cover all kinds of interested farmers across the country.   

3. Inter-operability of certification regimes is very important: Most farmers who have transitioned to the agroecology paradigm find that they need multiple marketing channels for their different products, and may be even in the case of the same commodity, for different lots. This then means that there has to be an in-built inter-operability between different certification regimes, which allows them to market their products, using different quality assurance regimes seamlessly. Logically, this should be possible since NPOP standards and PGS-India Organic standards are the same, though the verification systems are different. Moreover, NF standards are also the same (even if incentives in the star-rating system are different), apart from the additional requirements of getting bio-inputs internalised into the farming system to the maximum extent possible, that too done through the rating system. Any farmer who meets the standards of natural farming will also meet the standards of organic farming as well. A Scope Certificate and Transaction Certificate issued in one system should be useful in transactions in any other system’s supply chain too, ending with any one of the labels as far as the domestic market is concerned. 

4. Star-rating System should be evolved through wide-consultations, and even make it state-specific at the production systems’ end, if needed – should gradually lead to possibility of PES mechanisms: There is no reason why Subhash Palekar’s system or Himachal Pradesh’s CETARA system should be replicated as is in the star-rating system created in NFCS. In fact, looking into the future, the NFCS should be imagined as a system that is amenable for Payment for Ecosystem Services or PES. The certification regime can have even a 5-star rating system, but centering it around only whether Palekar Farming practices have been adopted or not, and whether bio-inputs are being purchased or not is not enough. The carefully calibrated system should incorporate diversity integration, IFS models adopted, water conservation and management practices, tree integration etc. in the star-rating accorded. Here, it is important that the non-negotiable of non-chemical farming without the use of GMOs/products thereof (including gene editing) is adhered to, to get even one star rating. Only after two seasons of verified non-chemical and non-GM farming is done should even one star accrue to a farmer. The Himachal Pradesh CETARA system is currently not doing so, and this will compromise on consumer trust in the system. 

5. Do not keep changing the Regional Councils frequently: The PGS-India system under PKVY had initially approved the establishment of hundreds of Regional Councils and later, in the name of conflict of interest, removed most of them. In the current plan that NFCS system has, of having at least one RC per district whether it is a CSO or FPO or even a consumer group, let there not be the issue of conflict of interest come in the way. Verification systems to bolster LG peer appraisal and RC endorsement can be put into place. Such foolproof verification systems should be more than video clips being uploaded.

6. Transition period should be more than 6 months: Transition period allowed in NFCS should be more than 6 months. Scheme-based transitions are unreliable and certification systems should be based on more than 2 years of transition, unless an area is traditionally non-chemical in adivasi pockets of the country. Even here, an institutional authority should authorise the same. However, inter-operability between systems where a farmer is already certified in one system should be minimal. Field verification is a must by the local designated authorities for at least 3 years, season after season. In some states like Karnataka, on the ground, even NPOP system has been reduced to ‘seasonal organic’ while chemicals are being used in the other season of the year. These kinds of compromises should be avoided in NFCS and therefore, the bar has to be set high from the beginning. The eagerness to get some advantage into this NFCS system so that it surpasses PGS-India Organic will prove to be detrimental in the medium and long term, if any compromises in the quality assurance systems are made.

7. NFCS should flow till the end-consumer: Groups of farmers are not always involved in processing and value addition. Therefore, it is important to visualise the NFCS certification regime to be flowing till the end-consumer. If first stage procurers/buyers do not find possibilities of marketing from that stage onwards to the end-consumers because the NFCS regime is not applicable if farmer groups are not involved, then the earlier stage NFCS certificate will also become de-facto useless as far as market potential for the farmer is concerned. Inter-operability options should at least exist at any stage of the supply chain, and such inter-operability should be with at least PGS-India Organic.

8. NFCS should cover animal-rearing also: This is a major shortcoming in the NFCS evolved right now, whereas the PGS-India regime has an animal production module finally evolved. The standards and systems from there can be replicated here. 

9. Certificate Language: Certificate language should also be in local language(s). 

10. Contamination Parameters Data Capture: Data related to potential contamination in various forms (including GM seed contamination) must be captured through specific parameters and this should in turn be able to provide pointers to which samples to draw for lab-testing for residues, or to even understand where the residues are emerging from.

We have a few more points penned below, drawing your attention to some specific articulations in the document circulated on NFCS. 

• Point 4.6 should say Voluntary but Binding. Not ‘non-binding’.
• Point 5.8 – CoNFs can also be RCs. Any registered consumer groups stepping forward to become RCs should also be allowed.
• Point 5.10 – should have individual farmers who are right now unconnected with other farmers, to be covered by the system. We know that the RCs are supposed to facilitate this, but this should appear explicitly in the document.
• Point 5.11 – Local Designated Authorities for field verification cannot be mixed up with RCs who are mainly doing online work, and some sampling work. 
• Point 5.12 – There is no point in connecting the LG to external people if the certification system cannot run till the end-consumer. This has to be put into place.
• Point 5.15 – 3 star rating system is not enough. It should be more graded, and should include PES parameters so that this can be converted into PES as and when possible. No star should be given based on only intention to transition, but should be given only upon actual transition. Let state governments decide on their parameters, if required. The minimum non-negotiable should be no chemicals and no GMOs and products thereof.
• Point 5.17 (VIII): The credibility can be established only after 3 years by random methods; otherwise, field verification should be insisted on, through diverse local designated authorities.
• Point 5.17 (XII): Certificate issued being applicable for that cropping season alone is problematic. What if natural farming status is maintained only during that cropping season and not the next season, and verification also happens only for that season. 
• Point 6 – Standards cannot be only “indicative”; they need to be firm. 
• Point 6.1.1.(III): Bio-inputs from external sources cannot be prohibited! They can at the most be discouraged through the rating system. It should be noted that a Company can be an FPC also in which a farmer is a Member! 
• Point 6.1.1 (iv): Conversion period brought down to one season/6 months is not reasonable or scientific, if the conversion is meant to take care of residues.
• Point 6.1.2 (i): “conventionally grown seeds can also be used but without any chemical

Treatment”. This might not be practical because often conventionally grown seeds available from market/from government are chemically treated, including for statutory reasons. It should rather be replaced with “conventionally grown seeds can also be used as a last resort but should be without any chemical treatment”.

• Point 6.1.3 (iv): “All certified natural farm products should be traded in packaged form”. This should not be the case. This insistence would lead to generation of a whole lot of packaging waste. It is also not feasible/desirable in a country like India where a lot of produce is still sold loose by small traders. 
• Point 6.1.2 (vi): “No buffer requirement needed between natural and organic farming farms is needed” must be added. Not mentioning this would leave it open for interpretation for everyone.
• Annexure I Self Declaration prevents women farmers from getting certification if the land title is in the name of male members in the family. Please do not allow the deficiencies of the existing regimes creep into NFCS, since natural farming is also a method of establishing social equity. Please indicate clearly that any certificate issued by an authorised person about the Farmer status of a certification-seeker will also be acceptable.
• Annexure I – Other farmers from the family working on the land must be added to the same form.
• Annexure I – Point 13 – Soil Health Card should not be incorporated until recommendations in Soil Health Card are conducive to natural farming. They are not currently conducive to natural farming.
• Annexure I – Training could be given by other entities too, given natural farming certification is not going to be tied to just farmers enrolled in NMNF.
• Annexure II – Farmers’ Pledge does not have a commitment on not using GMOs and products thereof (including gene editing).
• Annexure III should have geo-tagged, time-stamped pictures of peer appraisal, which should be possible given that schemes like NMNF have provided Krishi Sakhis with devices for this.
• NFCS Standards should emphasise on non-plastic mulching.
• In a scoring system, you cannot have a rider that even if you qualify for 3-star rating as per score card, you will not be given this star-rating if you fail in some other criterion. It has to be inbuilt. 

Sincerely,

Kavitha Kuruganti (8880067772)

Co-Convenor,

ASHA Kisan Swaraj

CC:

1. Shri Shivraj Singh Chauhan, Hon’ble Minister; MoA&FW

2. Dr Gagnesh Sharma, Director, NCONF;

3. Ms Maninder Kaur Dwivedi, Additional Secretary, Ministry of Agriculture & Farmers’ Welfare

Letter attached here too

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Alliance for Sustainable & Holistic Agriculture (ASHA-Kisan Swaraj)

FOOD – FARMERS – FREEDOM

www.kisanswaraj.in

www.indiaforsafefood.in
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Alliance for Sustainable & Holistic Agriculture (ASHA-Kisan Swaraj)

FOOD – FARMERS – FREEDOM

www.kisanswaraj.in

www.indiaforsafefood.in