To:

The Chief Executive Officer,

Food Safety & Standards Authority of India.

Dear Sir,

Re: FSSAI Order dated 21^st August 2020 (No. 1-1764/FSSAI/Imports/ 2018/Part-1) requiring Non-GM Origin and GM-Free Status Certificate on imports of 24 food products – reg.

Greetings! I am writing on behalf of the Alliance for Sustainable and Holistic Agriculture which is a large network of organisations and individuals from various fields such as doctors, agricultural scientists, biotechnologists, social scientists, ecologists and citizens concerned about safe food and sustainable farming. We have been concerned and have refuted from time to time the false claims made by the agri biotech companies, vested scientific researchers and corporate associations promoting Genetically Modified foods and crops. We have shown with scientific evidence that GMOs and products thereof are unneeded and are unsafe.  According to industry data itself, 99% of such crops either express a pesticide in every cell of the plant (eg Bt crops) or tolerate (HT crops) the spraying of a toxic herbicide that is absorbed by the plant and eventually consumed by humans, livestock or wild species and contaminating water and air apart from soil.

We congratulate the FSSAI on its Order of 21^st August (No. 1-1764/FSSAI/Imports/ 2018/Part-1) requiring a Non-GM Origin and GM Free Status Certificate on all imports of 24 food products with effect from 1^st January 2021.  This is a very necessary and welcome step and is indicative of a concern for consumer health and safety. 

Each phase of the GM journey has been marked by intense denials of harm to health, but responsible Governments have recognized the need to protect their populations as the risk is still being uncovered with new studies each year that show harm. We therefore urge the FSSAI to take forward its Order in a meaningful way to cover the following:

1.      All processed food products containing ingredients from products listed in the FSSAI Order’s Annexure, as also cotton seed oil, should require a Certificate that they do not contain GM ingredients.

2.      The Annexure needs to be updated to cover all GM products under testing. GM presence was detected in a rice variety and in wheat when these had not been approved for commercial release, but found their way into exports to EU, Japan etc, from American field trials.

3.      The testing mechanism in terms of both laboratories and testing capability, both material and human, at all points of entry into India as well as to cover all food markets should be geared up to make your order meaningful and not tokenistic. The relevant departments need to be alerted to the importance of this order and we can help you with data.

4.      Low cost testing should be available to consumers or done on consumer requests on foods suspected of containing GM ingredients.

There is also an additional issue cropping up with regard to imports from elsewhere. Making GM seeds coming in by way of imports unviable, as already mandated, is apparently not happening and this should be strictly ensured as the illegal spread of GM through seed is the greatest risk of GM entering the Indian food stream through unscrupulous seed importers/sellers. If necessary FSSAI as custodian of citizens food safety, needs to take up these issues with concerned Ministries. Thank you.

Sincerely,

Kavitha Kuruganti

Co-Convenor

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