To,

Shri Harsh Vardhan,

Minister of Health and Family Welfare

Date – 25^th Feb 2021

Reference: FSSAI order dated February 8th, 2021 regarding requirement of Non GM cum GM free certificate to accompany imported food consignments

Dear Harsh Vardhan ji,

Greetings,

We are writing to you on FSSAI’s proposed GM free certification policy which needs strengthening on threshold and scope.

 

Threshold –

The most recent letter from FSSAI for its proposed GM free certification policy for import states the threshold of GMOs to be kept at 1% permissible. https://fssai.gov.in/upload/advisories/2021/02/60212749e94b1Clarification_GM_Food_08_02_2021.pdf However this is an unacceptably high threshold, given capabilities in laboratories in India and globally to detect GM presence in food at a 0.01% threshold. Infact countries like Finland have been able to keep a 0.0% threshold for adventitious or technically unavoidable GM presence. This is our letter to FSSAI 2 years ago on GM certification parameters http://indiagminfo.org/our-objection-to-fssai-proposal-for-1-threshold-for-genetically-modified-labelling/

The aim must be for GM free certification to have zero GMO presence in imported food consignments including processed food. However, the Union Government should keep a threshold for adventitious presence of a maximum limit to 0.01%  for GM free certification for imported food consignments, which must be revised downwards (below 0.01%)  as technology advances allows detection to lower LODs (levels of detection).

Scope –

Also in addition to food crops, the threshold and certification must apply to processed food product imports too. Exempting processed food products as has been stated in FSSAI’s clarification from 12^th October, 2020 would mean that much of the GM food being sold illegally (reported in CSE publication) in India will continue. This must not be allowed.

The scope must also cover fish and cotton where GM varieties in other countries exist as well where the risk exists.

Similarly this must also be extended to seeds too. Our submission earlier shows import of seeds such as soybean, corn/maize, canola, sugarbeet seeds from countries whose cultivation has 90% of these crops being genetically modified. The suspicious seed packets exported from China to India earlier in 2020 just illustrate the need for tightening our seed import barriers. No imports must be allowed of any level of GMO content in seed. This must be zero and such rigour must extend to imports of seed from countries that grow GM crops or field test such crops, in view of possible contamination of seeds in these crops.

Infact eventually this must be extended to animal feed as well, with the regulation of animal feed coming under FSSAI. GM food regulation must also ensure that animals are not fed on GM feed.

FSSAI must also strengthen its testing capabilities to be able to ensure that the import ports and low-cost testing for citizens across the districts are able to test for GM food too.

Kind Regards,

Rajesh Krishnan

Vayalorathu House, Thrissilery PO, Wayanad, 670646, Kerala

07559915032

On behalf of Coalition for GM Free India

 

References from our earlier letters regarding this –

http://indiagminfo.org/coalitions-letter-to-fssai-on-its-order-dated-21st-aug-2020-requiring-non-gm-origin-and-gm-free-status-certificate-on-imports/

http://indiagminfo.org/2041-2/

http://indiagminfo.org/concerns-on-imports-of-genetically-modified-gm-agricultural-produce-seedsgrainfeed-and-foods-from-known-commercialised-gm-crops/

http://indiagminfo.org/our-objection-to-fssai-proposal-for-1-threshold-for-genetically-modified-labelling/

 

Copied to –

1)      Shri Rajesh Bhushan, Secretary, Ministry of Health and Family Welfare

2)      Shri Arun Singhal, CEO, FSSAI

3)      Shri Amit Sharma, Director (Imports), FSSAI