Ramu Ramanathan (RR): What type of solutions should packaging manufacturers develop to address changes in food manufacturing, processing and handling?
Shirish Yadav (SY): The foremost would be an environment friendly packaging solution. While packaging is a necessary element of the product, it is not the primary product we buy. 

RR: True. 
SY: Packaging is left behind after product consumption, and is an unwanted leftover in the environment. Industry is trying to find a solution through unlocking the value in these leftovers, so that they get picked up and recycled. However, more environment friendly solutions are also required; not everything will ever get recycled and there will always be a net addition. 

RR: Is there a part of the solution required at the packaging manufacturing end? 
SY: Yes. That area is around value curve analysis. 
RR: Meaning?
SY: It is basically mapping the value of each attribute of your product and superimposing that with the consumer’s perception of value on it. Areas where the consumer does not perceive value are probable areas for optimisation and the areas where the consumer understands value are areas for value enhancement. 

RR: How prevalent is this value curve analysis in our packaging manufacturing industry?
SY: We keep doing this in the FMCG part of the organisation. But I would recommend that packaging manufacturers also look at their product from this angle, so that the cost can be optimised while increasing the consumer perceived value. This is about improving quality where it matters and not wasting money where it doesn’t. 

Shirish Yadav, vice president, ITC-Foods

RR: During the pandemic months, we saw a surge in the consumption of packaged food. However, we hear about decreasing levels of nutrition caused by many packaged food types. How can packaging play a role and help us achieve nutrition security along with food security?
SY: There is a lot of misconception in this area. Packing or packaging does not decrease the nutritional value or make the food unhealthy. On the contrary, packaging preserves the nutrients and keeps the food safe and healthy for a longer time. So, in a way packaging is already helping improve nutritional security along with food security: say by, making seasonal nutrients available round the year. Suitably designed modern packaging solutions can provide enhanced protections to nutrition and food safety.

RR: And yet, we do find packaging with reduced nutritional value of the product inside…
SY: That is because, having said the above, there are packaged products available with more nutritional value and there are products with less. Today a larger percentage of the consumers prefer the latter because of cost or taste factor and hence they are produced more. As the consumer preference shifts, the former will take precedence. 

RR: In this context, what is the role of agencies? For example, FSSAI has rolled out a lot of standards lately. Do you find them comprehensive? 
SY: We believe that all the standards being prepared by the regulator must have been established by evaluating the data from the industry and international scientific references which are best suited to the Indian context.

RR: What areas do you find them lacking in? 
SY: There is a scope for improvement. In case of the pesticides MRLs (minimum residue limits), there should be some comprehensive guidelines for monitoring at farm level. Fixing the default MRL of 0.1 ppm is not advisable at this moment. Recently few standards released by FSSAI need to be revisited with respect to quality parameters (alcoholic acidity, moisture and acid value) for millets (jowar, bajra, ragi and mixed millet), cashew and ghee.

RR: Any new clause or regulation that has been an apprehension?
SY: Yes, yes. The FSSAI annual return had proposed a clause about an amendment in Form D, which is very cumbersome to be filed by Food Business Operators (FBOs). It includes the number of FoSTaC training, of customer complaints and their resolutions, product test report and product category details. Vide order dated 18 December 2020 the amended Form D is made operationalised. 

RR: Even the re-labeller company is required to file the returns?
SY: Yes. In addition, there is a draft regulation on FSS (licensing and registration) regulations, 2020 (yet to be gazette notified) which has a proposed clause of additional step of product verification before applying for license.

RR: What is the industry’s take on this?
SY: The industry proposal is that such restriction should not be introduced as it further delays / extends timelines for grant of licenses. Moreover, such a system is not followed across the globe. FBOs have been technically improved and many support services are available like FSSAI Mitra and consultancy agencies.

RR: Is there duplicity of compliance requirements?
SY: In one particular case, yes. The Consumer Protection Act (CPA) 2019 has extended the definition of “goods” under Section 2 (21) of the CPA to include “food”. Following clauses are found to be duplicating (a) product liability (b) misleading advertisement (c) enforcement. For food products, FSSAI regulations are enough and CPA regulation will be duplicity. FSSAI is already a single reference point for all matters relating to food safety and standards.

RR: During your talk at the FICCI Foodworld India seminar, alluded to reducing energy on the shopfloor and in the factory…
SY: Energy is a national resource. We as the ITC group have taken a pledge to reduce specific energy consumption by 30% by 2030. In order to meet this goal, every individual of an organisation will have to take baby steps which will lead to a cascading effect and hence lead to achievement of desired goals.

RR: Can you share a few of these steps that factories in India can undertake to achieve energy consumption…
SY: I will give three examples.

RR: Please do. 
SY: Firstly, an absolute need-based usage. And so, wrong practices like compressed air usage for cleaning practices. Then there is zero wastage of energy.  In this, one has to arrest leakages, chilled air leakages, compressed air leakages and arresting non-productive run-ability of machines).

RR: And thirdly …
SY: Efficient operation of all equipment. That is, not running beyond the design speeds, achieving benchmark efficiencies in energy guzzling equipment like boiler, chiller, compressor, oven and fryer.

RR: You had said that manufacturers can refurbish existing models by only replacing the critical elements while most of the old line is retained. Please enlighten…
SY: Digital twin-based remote monitoring of line efficiency is the latest trend and an efficient way of manufacturing. Typically, the old lines or old machines do not support any information exchange like machine data and process data due to legacy control systems. 

 

RR: So, you basically refurbish the old machine control system… 
SY: Yes, with the latest PLC and communication protocol like Ethernet or Modbus TCP IP. It can help in establishing the real time monitoring of the machine performance and will result in better productivity. Especially in packaging lines where short product runs and high changeovers require continuous monitoring to minimise the underweight and overweight rejections, extra give away in products and improve the overall equipment efficiency (OEE) and reduce the total cost of ownership (TCO).

RR: Under what circumstances should a company opt for an upgrade?
SY: Before upgrading the company needs to assess first – the age of machines. For instance, very old machines can’t meet the speed and versatility and spare parts availability will be difficult. Second – assess the downtime, frequent breakdown and high repair time as well as the skilled resource constraints. And last – the cost of maintenance.

RR: If we were to launch a coding system to cover the entire lifecycle of packaging from its constituents to its functions and its ability to recycle what should it be?
SY: This is a huge need. Today biodegradability is the only factor which is considered and others are ignored, whereas what needs to be seen is the total environmental cost. A coding system based on life cycle assessment (LCA) is the way to go. 
 
RR: What should the form of this code be?
SY: It can be colour codes or numeric codes which the consumer will become familiar with over a period of time. What is important is a standardised process of LCA analysis, which is auditable, there should be no gaps in the process else, chances of misuse would be high. 

RR: In this context, a supplementary question. Do you think packaging is at times over-engineered? 
SY: In the Indian context, I wouldn’t say that there is a lot of over engineering. Within the packaging industry, India is an example of optimisation. We successfully run some of the most optimised packaging. Flexible packaging is the predominant packaging in India because it uses much less material per kg of product.  This is primarily because we are a value conscious society.

RR: Do you think packaging can be optimised/ standardised in some ways that can help make collection of post-consumer packaging easier?
SY: Standardisation can definitely help. If a given type of packaging has a given material of construct it becomes easier to segregate and reach the recycle value chain, example being PET bottles and milk pouches. The problem is that PET in bottles and LLDPE in milk pouches is used because they are the most optimum material for the product and not because of ease of recycling. 

RR: Does this rule apply to all or most products?
SY: No. When you try to use the same formula in other products the packing becomes sub-optimised in terms of cost or performance. A system of incentivising a given type of material for a given product may help, but actual benefit will come only when a packaging type completely switches over. Having said that, packaging is highly customised, designed to provide product safety, performance and differentiation. Hence blanket standardisation may not be feasible.

RR: Finally, you are an advocate for the Internet of Things (IoT). Different industries and diverse geographies spending on the internet of things have jumped over the past few years… 
SY: Industrial IoT or IIoT is getting adopted in all industries and likewise in food processing and packaging. It is used right from crop yield monitoring, raw material grading, shelf-life monitoring, batch traceability, manufacturing efficiency, inventory status, finished goods and point of sale.

RR: How should the food processing and packaging industry in India implement IoT across their organisations?
SY: IIoT is the first step for collecting data and storage on cloud and further big data analytics will add value using AI/ML models to predict the outputs, causes, failures, efficiency and trends. Overall, it will improve the process efficiency by close monitoring and taking corrective actions basis insights or else by establishing a close loop control system. IIoT will finally lead to smart operations be it a smart supply chain or a smart factory.