FSSAI’s draft labeling notice is inconsistent & ultra vires-Remember, GM foods are not permitted in India!

———- Forwarded message ———-
From: GM Free India <indiagmfree@gmail.com>
Date: 7 May 2018 at 08:29
Subject: Our comment on Draft Notice on Food Safety & Standards (labelling and display) Regulations 2018
To: regulation@fssai.gov.in


Shri Pawan Kumar Agarwal

Chief Executive Officer,

Food Safety and Standards Authority of India,

3rd Floor,  FDA Bhawan,

Kotla Road, New Delhi – 110002

Email: regulation@fssai.gov.in


Subject: Notice Calling for suggestions, views, comments etc. from stakeholders on the draft notice related to Food Safety and Standards (Labelling and Display) Regulations, 2018 on 11/4/2018, F.No.1-94/FSSAI/SP (Labelling/2014(Pt-2) at



Dear Sir,

We introduce ourselves as a large informal network of organisations and individuals called “Coalition for a GM-Free India” seeking to establish lasting, farmer-controlled, safe and sustainable solutions for any problems in our food and farming systems, and not unsafe, irreversible and uncontrollable technologies like transgenics. Below are our comments on the draft notice for Food Safety and Standards (Labeling and Display)  Regulations, 2018.


Sl Name & Address of the Organisation/ Person, contact number and Email Relevant Section in the Draft Notice on which comments are being provided Comments & Suggestions Rationale Remarks
1 Sridhar Radhakrishnan, Co-Convenor, on behalf of Coalition for GM Free India.


Address: OD-3, Jawaharnagar, Kawdiar P.O. Thiruvananthapuram, Kerala.
PIN 695 003
Mobile: 09995358205. Email: indiagmfree@gmail.com

Schedule IV (Page 42) 2.7. Labelling of Genetically Engineered or Modified Foods DELETE Schedule IV’s Section 2.7. on Labelling of Genetically Engineered or Modified Foods.

It is inconsistent and ultra vires for FSSAI to issue a draft notification that allows for GM ingredients, at a time when any selling, stocking, distributing of GM foods itself is illegal, as per FSSAI’s affidavit in the Supreme Court.  FSSAI must remove this entirely.

Your draft regulation on Labelling and Display is inconsistent with the fact that GM foods are not permitted to be sold in India by FSSAI (attached is FSSAI’s affidavit in the Supreme Court for ready reference). Therefore, to say that “All food products having total Genetically Engineered (GE) ingredients 5% or more shall be labeled” allows for GM foods to come into the food supply chain and on shop shelves, with a simple labeling proviso being fulfilled, when it is illegal to sell GM foods in the first instance. Given that no food products with GE ingredients are allowed to be legally sold in India, no labeling and threshold-level fixing can be allowed for the same.  


Copy of FSSAI Affidavit in Supreme Court in May 2017 available here: https://photos.app.goo.gl/wJCvyhEOEmuyK1az1



Date: 07/05/2018


Place:  Trivandrum                                                                                                                                                                 Name and signature: Sridhar Radhakrishnan (Mob. 9995358205)

Coalition for a GM-free India 

Website: www.indiagminfo.org, email : indiagmfree@gmail.com,  Facebook pageGM Watch India

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