"We need an integrated approach to packaging safety"

What is the current status of the food industry in India from the safety point of view?
Pawan Kumar Agarwal (PA): Currently, the food industry in India is evolving and is making efforts to provide safe and wholesome food. To ensure delivery of safe food to consumers, food business operators (FBOs) are required to comply with the Food Safety and Standards Regulations, 2011. Further, efforts are on towards risk analysis and its management and self-compliance mechanisms.

Where are the loopholes that FSSAI is trying to plug with the new regulations? What role, according to you, does packaging play in ensuring food safety?
PA: With the anticipated growth in the sector, it becomes equally important to channelize packaging safety to ensure the objective of food safety. Packaging has been always considered as a protection for food, but has been overlooked as a source of potential contaminants.

Through the proposed packaging regulations, FSSAI is aiming to achieve safety of pre-packaged articles of food. As packaging plays an important role in ensuring food safety and it’s the primary contact material through which migration of harmful substances may occur, and it may affect food quality and safety both at the same time. Therefore, to ensure that packed food is safe, FSSAI has proposed these regulations.

What role does the FSSAI play in ensuring the quality of food-contact packaging?
PA: In ensuring the quality of food contact primary materials, FSSAI’s role is to formulate science-based standards taking into consideration available literature and international best practices.

In order to achieve your vision of food safety, what are the parameters that a package should qualify?
PA: To achieve food safety, the packaging materials shall be of food grade quality which is safe and suitable for their intended use, and shall not endanger human health or result in an unacceptable change in the composition of the food or organoleptic characteristics.

FSSAI has released a draft of Food Safety and Standard (Packaging) Regulation 2018. Can you brief us on what does it entail and how this will make consumer health safer?
PA: The proposed regulations are aimed at establishing requirements for packaging materials so as to ensure that they are safe for use in food packaging. It prescribes general and specific requirements with respect to packaging material such as plastics, metal and metal alloys, paper and board materials, and glass. It also prohibits the use of newspaper and other such materials for packing or wrapping of food and provides a suggestive list of packaging materials which may be used for packaging of food.

Did the industry stakeholders, especially the packaging converters, respond to the draft? What have been their observations and demands?
PA: Yes, stakeholders responded to the draft regulations and their comments were considered before finalising the regulations.

How prepared according to you is the packaging supply chain in India to comply with the new regulations?
PA: With these new regulations coming in place, FBOs have to take responsibility that the packaging material supplier is providing the safe and food grade material complying with the standards provided in the regulations. FBOs will be given an appropriate transition time period to comply with the finalised regulations.

What are the challenges that you face in the implementation of the new packaging regulations?
PA: Until and unless packaging regulations are practically implemented, nothing could be commented in this regard. Standardisation is an evolving area and we would learn with the experience.

What timelines does FSSAI prescribe for implementation of regulations? Are you engaged in a dialogue with the packaging converters?
PA: For the implementation of regulations, the appropriate transition time is given. Generally, a period of minimum six months is provided. For example, regulation is implemented either from first January or from first July depending on the final notification of the regulations. In certain cases, FBOs are provided extended timelines to comply with the regulations.

Do you see any proactive initiatives to deliver safe packages by brands?
PA: Yes, FSSAI came to know that the packaging industry has taken proactive initiatives like the manufacture of toluene free printing inks for packaging applications. Use of toluene-free inks on food packaging will, in turn, ensure consumer safety.

We do hear about toluene-free inks and mineral-oil free inks in the market. Is it something related to safe packaging?
PA: Yes, it is related to safe packaging. Considering the ill-effects of toluene, the manufacturing of toluene-free ink formulations intended for food packaging will ensure consumer safety.

What support are you expecting from the packaging industry stakeholders?
PA: It is the responsibility of all suppliers in the value chain to ensure that they comply with the regulations and their contributions do not in any way endanger consumer health through the migration of harmful constituents into the food stuff.

What is the current trend in food packaging?
PA: The food packaging industry is vibrant and highly competitive and it is growing at a fast pace to catch up with the latest trends coming up in the market. Food packaging market is by far the largest application segment of the packaging industry which is continuously engaged in innovation and is always on the look-out for packaging that can provide consumers with increased convenience as well as longer shelf life at a lower cost than their existing packaging.

How do you see packaging evolving in terms of compliances in the next five years?
PA: 100% compliance with the proposed regulations is our expectation in years to come.

What is the success mantra for implementing food packaging safety for brands and for a packaging converter?
PA: Success mantra for food business operators will be to start doing it and build experience before the proposed regulation is being put in place.

Your message for the Indian food packaging converters? 
PA: Industry needs to follow an integrated approach to packaging safety wherein information and knowledge needs to be shared across all partners of the supply chain to ensure consumer safety.

FSSAI headquarters, New Delhi