from: GM Free India <>
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Shri Pawan Kumar Agarwal,

Chief Executive Officer,

Food Safety & Standards Authority of India,

FDA Bhawan, near Bal Bhavan,

Kotla Road, New Delhi – 110002

Feb 6th 2019

Dear Shri Agarwal,

This is about the labelling requirement for genetically modified food. From the news articles below we understand that FSSAI is now proposing moving from a 5% threshold to 1% threshold for labelling genetically modified (GM) food.

While this is a step in the correct direction, this is a very small and unacceptable step. In our previous communication with you on this matter we did tell you about labs being able to detect GM food to a level of 0.01% threshold. Countries like Finland have put the highest possible threshold of 0.0% allowing for only technically unavoidable or adventitious presence. Please see Page 33 below for more reference

Given food safety is a topic of utmost importance in India and that genetically modified food is not allowed to be legally sold but is sold on a large scale as evident from Centre for Science & Environment’s study we must adopt the strictest standards of no genetic modification being allowed in our food. The threshold must be dependent on technical parameters only which currently corresponds to 0.01% and must continue to be adapted as the technical capability improves.

In addition animal-derived products must require GM labelling too. As can be seen from European regulation above, GM food detection must also ensure that animals have not been fed on GM feed. Countries like Finland have the same strict threshold detection of 0.0% allowing for only technically unavoidable/adventitious presence for animal feed as well.

In addition the regulation must not be based on just the end product but rather should be based on process-based qualitative screening ensuring that even if final product does not contain GM DNA, usage of GM ingredient is sufficient for it to be labelled as genetically modified. An audit trail identifying the origin of ingredient for packaged products must be maintained by Food Business Operator. Enforcement mechanism should be based on GM DNA qualitative screening too.

FSSAI’s focus must be on building testing capability to ensure citizens have low-cost and readily available testing avenues throughout the country in all districts too.

Experiments from around the world, using various research protocols, show clearly that GM foods are not safe. Adverse impacts include effects on growth and development of an organism, organ damage, immune system disorders, cancerous growth, reproductive health problems including infertility, allergies amongst other impacts. Domestically produced Bt cottonseed when consumed by animals in Mahyco’s own biosafety dossier for Bt cotton released in India showed difference in size of spleen, heart, uterus and weight of lung in animals having consumed it as reported in Supreme Court’s Technical Expert Committee Report. Not only this, cows fed Bt cotton feed had shown indications of having led to reduced milk yield as well as observed in the report. Same Bt cottonseed is being consumed by humans in the form of oil which is being sold illegally in packaged foods or vegetable oil containing it.

Nearly a year after we wrote to you on GM food being sold illegally and many other letters, we again reiterate you to take strict action against both illegally domestically produced and imported GM food products which have been flooding the food market.


Sridhar Radhakrishnan


Coalition for a GM-Free India

Sridhar Radhakrishnan,

TC 4/660, Sreevilas, Sreevilas Lane,

Kowdiar, Thiruvananthapuram – 695003,

Kerala, India.

Mobile: 09995358205.

Copy to: Ministry for Health & Family Welfare, Government of India, Ministry for Consumer Affairs, Food and Public Distribution, Ministry for Commerce & Industry, FSSAI’s Panel on Genetically Modified Food and Organisms, Centre for Science and Environment, Aruna Rodrigues