Objection regarding FSSAI’s proposals on organic food certification

———- Forwarded message ———
From: ASHA Kisan Swaraj<asha.kisanswaraj@gmail.com>
Date: Tue, Jul 1, 2025 at 12:01 PM
Subject: Objection regarding FSSAI’s proposals on organic food certification
To: <chairperson@fssai.gov.in>, <ceo@fssai.gov.in>
Cc: <agrimin.india@gmail.com>, <chauhansr@mpls.sansad.in>

To: 1st July 2025

The Chairperson, 

Food Safety & Standards Authority of India.

The Chief Executive Officer,

Food Safety & Standards Authority of India.

Dear Madam/Sir,

Greetings! On 7th of May 2025, FSSAI held a hybrid meeting with “Organic Food stakeholders” to review the Food Safety and Standards (Organic Foods) Regulations 2017. Attached is the Meeting Notice. Most of the signatories to this letter, who are organic food stakeholders, got information about the key discussion points of the said meeting. We decided to send this letter without waiting for the Minutes, since it is not clear whether we will even get to see the Minutes. 

It has come to our notice that amongst several issues discussed, three key proposals have been placed on the table:

1. That FSSAI is proposing to remove exemptions that have been granted to “small original organic producer or producer organisation”, equivalent to a petty food manufacturer within an annual turnover ceiling of 12 lakhs per annum;
2. That FSSAI is proposing to remove exemptions provided to Aggregators or Intermediaries with direct sales to end consumers, with an annual turnover ceiling of 50 lakhs per annum;
3. That FSSAI is proposing to remove Regulation 4(1)(iii) which has the possibility of other standards and systems to be notified under the Regulations, which will effectively leave only NPOP and PGS-India as the recognised quality assurance regimes.

We also got information that FSSAI is questioning the certification regime adopted by the Ministry of Agriculture, which is PGS-India. FSSAI’s mandate is only food safety, while organic farming serves numerous other purposes of environmental conservation and ecological rejuvenation, in addition to livelihood security for millions. The issue of fake organic alone cannot be the issue that determines the overall approach to organic farming in India.

It appears that FSSAI wants to throw the baby out with the bathwater, when it wants to tackle “fake organic” as a big priority which is a misbranding issue if at all, and not a matter of food safety per se, because fake organic cannot be more unsafe than the conventional (grown with agrochemicals) food out there in our food chains at this point of time.

It is stakeholders like us, who on grounds of public interest, engaged with FSSAI and Secretary, Ministry of Health & Family Welfare between 2017 and 2021, to get the exemptions included. We wanted to ensure that Indian agriculture can move towards the very mandate of FSSAI viz., safe food from agroecological practices adopted by farmers and to ensure that small FBOs are not under pressure to close shop under the burden of compliance to impossible regulations. Importantly, FSSAI authorities at that time, after listening to detailed presentations, put out a Direction on 2nd April 2019, asking that regulations be considered as “enabling regulations”. 

https://fssai.gov.in/upload/advisories/2019/04/5ca5d8c31525dDirection_Organic_Food_03_04_2019.pdf

We take the liberty of re-articulating all the key issues with regard to organic agriculture and organic food regulations:

1. FARMERS, INCLUDING ORGANIC FARMERS, ARE EXCLUDED FROM FOOD SAFETY & STANDARDS ACT’ REGULATORY PURVIEW: We hear that the discussions in the hybrid meeting aforementioned touched upon organic farmers misusing the exemptions. There is no question of exempting organic farmers, since the Act of 2006 in itself excludes them from regulation under Sec. 18(3):

Sec. 18(3): The provisions of this Act shall not apply to any farmer or fisherman or farming operations or crops or livestock or aquaculture, and supplies used or produced in farming or products of crops produced by a farmer at farm level or a fisherman in his operations. 

Organic certification regimes are quality assurance systems around the practices of farmers, and the Act already excludes farming operations, supplies used as well as supplies and products produced in farming. Attempts to regulate organic farmers by FSSAI are, therefore, ultra vires.

2. INFORMAL ORGANIC CONTINUES TO BE A MAJOR CHUNK OF INDIA’S ORGANIC MARKETS, WITHOUT FORMAL SUPPORT FROM GOVERNMENTS WHILE AT THE SAME TIME FULFILLING THE VERY MANDATE OF FSSAI: We presented to FSSAI in 2018 and 2019 that the informal organic supply chains (uncertified by any regime) are as large in value as the formal certified organic supply systems, and that such informal systems cannot be penalised with mandatory certification when the certification regimes themselves are unprepared to serve all the farmers who are ready to shift to organic farming, in government programs as well as outside such programs. This is further validated by a recent report by APEDA wherein the Indian organic market is estimated to be valued at Rs 16800 crore, as of fiscal 2023. While exports are estimated to have accounted for Rs. 5520 crores out of this, the organised domestic organic market is pegged at Rs.3340 crores. The unorganised domestic market is valued at Rs. 1600 crores, while a whopping 38% of the Indian organic market, ie., Rs 6340 crore of organic produce is sold as conventional (in the regular supply chains). This speaks about the severe lack of support, including of certification regimes, for such organic production. In such a scenario, instead of recognising multiple, appropriate quality assurance regimes that will comply against the same standards and use the same unified label at the back and front ends, FSSAI is proposing to remove the existing exemptions. 

3. SITUATION WITH AVAILABLE CERTIFICATION REGIMES HAS DETERIORATED – IS TACKLING MISBRANDING MORE IMPORTANT THAN ALLOWING SAFE FOOD PRODUCTION TO THRIVE?: FSSAI is going to kill a paradigm that aligns with its primary mandate, with its latest proposals of removal of exemptions. 

Consider this: In 2018 and 2019, when we engaged with FSSAI authorities at that time, there were 793 RCs in 2018, with only 371 that were reported to be active. This number further declined to 309 active RCs, out of a total of 527 RCs as of September 2020. At that time, on PGS India portal, it was reported that only 167056 certificates were generated for organic farmers. In contrast, today, only 77 Regional Councils are operational under PGS-India, with a meagre 210786 valid certificates at present. This is abysmally low compared to the scale of organic farming in India. 

Meanwhile, under NPOP, in 2020, it was reported that 13.63 lakh farmers are covered, that too mainly under Group Certification as part of 3968 ICS groups. Total “Operators” covered under NPOP by 29 certification bodies are 9568 in number, which includes individual farm producers, ICS groups, processors, traders and also wild harvest operators. 11 of the 29 Certification Bodies accredited by APEDA are state government agencies. 5 of the remaining 18 were also into the PGS India regime as Regional Councils. As of August 2024, number of certification agencies remains at 37, with adverse remarks against 11 of these bodies with 26 being active in effect. Only 13638 operators (with 2358267 farmers included in 6046 grower groups) are certified by the certification agencies. 

All in all, while APEDA report (Aug. 2024) acknowledges that 114 lakh farmers could be estimated to be organic in India, certification seems to be covering 23.7 (NPOP)+2.1 (PGS India) at this point of time. Apart from the significant shortfall of coverage by either regime of practising organic/natural farmers, there are deep shortcomings in both systems when it comes to maintaining integrity of organicity. Both the regimes have gaps in addressing fake organic. 

Meanwhile, FSSAI also did not accept and notify other certification regimes like PGS-OC in its regulations. Against this severe failure of governments and market players in setting up multiple diverse quality assurance regimes that should have been made accessible for all farmers in the country, FSSAI’s move to address misbranded organic will only end up penalising organic producers who have transitioned into this alternative paradigm of farming facing enormous number of challenges at every step.

Given the above, we urge the FSSAI to:

1. Not move forward with its proposed amendments to the existing regulations around organic foods;
2. Issue one more advisory/direction asking food safety officials to treat the extant organic food regulations as enabling regulations, rather than use it to penalise FBOs;
3. Notify multiple other quality assurance regimes like civil-society’s PGS-OC, Himachal Pradesh state government’s CETARA as the other options available to farmers to get their organic produce certified as such. Here, the standards for production will be the same for all farmers, and the label at the front end should be the same unified label so that consumers are not confused with multiple labels in the market. However, farmers need a multiplicity of options for the quality assurance mechanisms that will complete the certification process.

     Sincerely,

Sreedevi Lakshmikutty (96299 99081),

ASHA – Kisan Swaraj

CC: Shri Shivraj Singh Chauhan, Hon’ble Union Minister for Agriculture, Govt. of India

Full letter with 130+ endorsements attached in pdf tooLetter Endorsed By:

1. Prof Rajinder Chaudhary, Rohtak (Haryana) Advisor, Kudarti Kheti Abhiyan, Haryana and Jaivik Kisan Bikri Samooh, Haryana
2. Bhala Chandra Shadangi, Berhampur, All India Kishan Mazdoor Sabha (AIKMS)
3. Kavitha Kuruganti, Mysuru, ASHA – Kisan Swaraj
4. Dinesh Kothari, Indore, Banyan Tree
6. Tsongtili Sangtam, Angangba Village, Nagaland, Better Life Foundation
7. Akash Badave, Dantewada, Chhattisgarh, Bhoomgaadi
8. Anshuman Das, Kolkata, BhoomiKa
9. Ramesh Chandran, Coimbatore, Bio Basics
10. Natabar Sarangi Narisho Niali, Khorda, Odisha Chairman, Prachi Jaiba Chasi Samabaya
11. Raman Mann & Seema, Punjab, Chandigarh Organic Farmers Market
12. Nimish Shah Nagpur CQUEST
13. K. Suresh Kanna Nachikurichi, Trichy District, Tamil Nadu CREATE
14. Hasansahib Pinjar, Iddalgi, Hungund, Bagalkot, Karnataka EcoFarms EcoVillage
15. Manas Arvind, Gurugram Farmversities Alliance
16. Ashish Gupta-jee, Village Pangna, Dist Mandi Himachal Pradesh, Gram Disha Trust
17. Vidya Dinker, Mangalore, Dakshina Kannada Growthwatch
18. Dippak Basavaraj, Bengaluru/Karnataka, INGALA Earth LLP
19. Nataraj Gangadhar, Bangalore Insider Consulting Group
20. Govinda Pillai, Kannamangalam, Chettikulangara, Mavelikkara, Alapuzha, Kerala Jyothi Nellulpadaka samithy
21. John P T Pakkam,Pulpally,, Wayanad, Keralam. Kisan Mazdoor Morcha
22. Manjushree Tadvalkar, Maharashtra Pune, Know How Foundation
23. Sreeja K V, Arangottukara Thrissur Kerala,  Krishi Patasala, Arangottukara
24. Subas Chandra Sahu,  Bhubaneswar,   Loka Samabaya Pratisthan
25. Sajitha Karumaloor, NAFPO
26. R. Ajayan,  Thiruvananthapuram, Kerala OISCA International
27. Abha bhaiya, rakkar, Kangra district, HP One Billion Rising – global campaign

28. R.Bhasker, Chennai Organic Farmer’s Market(OFM)
29. Pushparaj, Chennai, Paanal Farms

30. Alauddin Ahamed, Atghara, North 24 parganas, Kolkata, West Bengal, Panitar Pally Unnayan Samiti (PPUS)
31. Shiburaj AK, Kozhikode, Kerala Panthi
32. Dr. Shakeelur Rahman,  Ranchi, Prakriti Bachao Foundation
33. P Srinivas, Bengaluru, S.O.I.L
34. Thilak Raj S, Chennai, Safe Food Alliance 
35. Ravi Dabbanda, visakhapatnam district,  Samata
36. Ushakumari, Trivandrum, Save Our Rice Network
37. Dr. Donthi Narasimha Reddy, Hyderabad, Telangana Seed Campaign
38. Raja Sankar Devarayapuram village, Coimbatore,  Sri Ram foods
39. KP Singh, Karnataka, Swaraj Abhiyan
40. Burnad Fathima Natesan, Tamil Nadu, Tamil Nadu Dalit Women’s Movement (TNDWM)
41. Karthik G Chennai, Tamil Nadu Iyarkai Velan Koottamaipu (TNIVK)
42. Selvam Ramasamy Arachalur, Erode Dist, Tamilnadu, Tamilnadu Organic Farmers Federation
43. Dwiji Guru, Bengaluru (K’taka) / Sitapur (UP), The millet foundation
44. Rajesh Krishnan, Wayanad Kerala, Thirunelly AgriProducer Company Ltd
45. Himakiran Komakkambedu, Tiruvallur, Tamil Nadu Thondaimandalam Foundation
46. Ms.R.Meera Bhakrapeta, Tirupati District Andhra Pradesh, WOMEN’S INITIATIVES(WINS) NGO

47. Syed ghani khan, Kirugavalu mandya dist karnataka, Organic farmer 

48. Seema
49. Sridhar Radhakrishnan, Thiruvananthapuram Kerala
50. Ishteyaque Ahmad, Patna, Bihar 
51. Deepa V M, Kaladi & Malappuram/Edappal/Kerala
52. Dinesh Kumar C P, Kozhikode

53. Amit Sengupta, Delhi, Journalist

54. Joseph M J Trivandrum
55. G Venugopal Kadthal, Telangana
56. Jyotika Sood, Gurugram
57. Ganeve Rajkotia
58. Mahadevan Ramaswamy New Delhi
59. Harish V Nileshwar
60. Fariha Fatima Hyderabad
61. Priya K Nair Kannamangalam, Chettikulangara, Mavelikkara, Alapuzha, Kerala
62. Sapna Kannapuram, Kannur, Kerala
63. R V Vinod 
64. NV Thankachan John, Pirayiri, Palakkad, Kerala
65. Archana Kaul, Delhi
66. Dr Latha, Bengaluru
67. Usha Balaraman, Sreekaryam, Trivandrum,Kerala
68. Roji Jacob, Kerala
69. Rajeev Kumaraswamy, Thiruvananthapuram
70. Ram, Chennai
71. Pushpanjali Reddy, Bangalore
72. Suresh Sanyasi, Doddaballapur Bengaluru, Karnataka
73. Praveen Barthur, Rayarakoppal/Alur Taluk/Hassan District/Karnataka
74. Agi Anna Joshua, Trivandrum
75. Yogini AD, Mangurda / Tal Kelapur / Dist Yavatmal / Maharashtra
76. Satheesan, Trivandrum, Kerala
77. Sandeep Singh, Village Changera, district Mohali,Punjab
78. Shankar Srinivasan, Anniyalam/Denkanikotta/Hosur/Tamil Nadu
79. Gopi, Chennai
80. Rosamma Thomas, Pala town Kerala
81. Bharati Saha, Kolkata
82. Jojo John Vallachira, Thrissur, Kerala
83. Devahuti Sarkar Kolkata, West Bengal
84. Rayson Thondamuthur, Coimbatore, Tamil Nadu
85. R Sheela, Madampatty Coimbatore
86. Filip Shenan A Trichy, Tamilnadu
87. Lalitha Vijayan Thrissur, Kerala
88. Shrikanta Mohanta Bhopal , Madhya Pradesh
89. Asha Nair Thiruvananthapuram, Kerala
90. Prof Amarendra Sahoo
91. Sudhir Pattnaik Bhubaneswar, Khorda
92. Pramel Gupta, Bhopal, MP
93. A T Samuel, Trivandrum
94. Civic Chandran, Kozhikode / keralam
95. Swadin Pattanayak Bhubaneswar
96. Karum, Kalpetta, Kerala
97. Nisha Kuruvilla, Vakathanam, Kerala 
98. S Syed Noor Mohamed, Panagudi, Tamil Nadu
99. Prof Sanjay Lodha Jaipur
100. Lokesh Jha, UP
101. Thirupathi Reddy Gurram, Farmer, Telangana 
102. Swarnamayee Tripathy Bhubaneswar
103. Dr. Ganesan Kittusamy Somanuthu, Sellam Palayam PO, Dharapuram Tk. Tiruppur Dt. Tamil Nadu
104. Dr Dhiraj Singh, Meerut, Retired Scientist
105. Babychan T J Thiruvallam, Trivandrum, Kerala
106. Aswathy K T Ezhikkara / Ernakulam / Kerala
107. KB Mohammed Kunhi Muliyar, Kasaragod, kerala
108. Gautam Singh Rampur Kalan/SAS Nagar
109. Satinder Brar, Hoshiarpur Mohali
110. Udaya Kumar, Bangalore Rural, Karnataka
111. Rejatha Thiruvananthapuram. Kerala
112. Tashmai, Nanjangud, Karnataka 
113. Jean Nettar, Trivandrum
114. Moncy M Thomas Thiruvananthapuram, Kerala
115. A J Vijayan Muttathara, Trivandrum, Kerala
116. Rama Tyagi Behung , Muradnagar, Ghaziabad Uttar Pradesh 
117. Uma Shankari, Venkatramapuram, Vallivedu, Andhra Pradesh 
118. Ramesan R V Thiroor, Kolazhy Village, Thrissur Dist
119. Pervin Sanghvi Maharashtra
120. Ashutosh Ramdas Kumthekar Tezu, District Lohit,East Arunachal Pradesh
121. Tarak Kate Wardha, Maharashtra
122. Rajeswari Raina New Delhi/ Delhi
123. Parthasarathy VM Pandeswaram, Tiruvallur, Tamilnadu
124. Ananthoo Chennai
125. Gayathri R Chennai
126. Kiran Rajendra Kamble Pune, Maharashtra
127. Raman Kalit, Ropar, Punjab
128. Vidhya v, Bengaluru, Karnataka
129. Vishali Ghamta, Chandigarh
130. Sundar Rajan, Madurai, Tamil Nadu 

131. Rohit, Chhattisgarh

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

FOOD – FARMERS – FREEDOM

www.kisanswaraj.in