1

Regulatory Landscape of

India: International Trade

Dr. S K Saxena,

Director,

Export Inspection Council (EIC)

Ministry of Commerce and Industry

New Delhi

director@eicindia.gov.in

www.eicindia.gov.in

2

Trade Dimensions

Import

Domestic

Export

3

4

The World at our Local Grocery Shop

5

Global Food safety issues

6

Food Safety Issues Travel Very Fast Food Safety Information Travel Faster than

Sound and Light

7

Importer Regulatory Authority

Exporter Regulatory Authority

Relation b/w Trade Partners

8

TRADE REGULATIONS

DEVELOPED & ADVANCED

COUNTRIES

DEVELOPING

COUNTRIES

LEAST DEVELOPED

COUNTRIES

Most Stringent

Under Process of Harmonization

Under Process of Adoption/Development

9

Mandate of National Food Control System

1. Consumer Safety

(Prime Importance)

2. Fair Trade Practice

(Fraud/Adulteration)

WTO (CODEX, OIE, IPPC)

EIC/FSSAI

10

Food Control in India

National Food Control System

Internal Market (Domestic + Imports)

External Market (Exports)

Food Safety & Standards Authority of

India

Export Inspection Council of India

11

Food Safety Concerns of Developing Countries

Inefficient food control systems

Lack of basic hygiene in food handling

Food adulteration is widely practiced

Uninformed consumer

limited participation in international standard setting work

Difficulty in meeting international standards or standards of importing countries

12

Important Pillars of National Food Control System

1. Legislation/Regulation

2. Inspection

3. Laboratory Testing (Backbone)

4. Enforcement

13

14

National Food Control

External Market

Ministry of Commerce & Industry

Other Agencies APEDA: Agriculture and Processed Food Export Development Authority MPEDA: Marine Product Export Development Authority CAA: Coastal Aquaculture Authority CIFT: Central Institute of Fisheries Technologies CAPEXIL: Chemical and Allied Products Export Promotion Council Spice Board & Cashew Export Promotion Council look after the exports of Spice

& Cashew

EIC is the official export certification body

15

Competent Authority

Means the Central Official Authority of a Country

Competent to Ensure Compliance with the Requirements of Regulations of Importing Countries(Food Safety by Sampling, Testing, Certification, and Traceability etc.)

16

Assessment of CA By Trade Partners (Regulators of Importing Countries)

FVO Missions:

Legal Basis, Implementation, Technical Competence and Traceability Etc.

Monitoring of Residues of Contaminants (RMP)

Monitoring of FSMS

Root Cause Analysis of RASSF Notifications

(Accreditation Support This Aspect)

17

Use of Accreditation by EIC

Inspection : Required Accreditation as per ISO:17020 (Inspection Agencies)

Testing: Required Accreditation as per ISO: 17025 (Testing and Calibration Labs)

Certification: Required Accredited Certification as per ISO: 22000/HACCP, 9001, 14001 etc. (Industry)

18

RAPID ALERT SYSTEM FOR FOOD & FEED (RASFF)

• Operating since 1979.

• Included in the EU Food Legislation (Regulation 178/2002, Chap. IV) in 2002

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TYPES OF RASFF

1. ALERT NOTIFICATIONS

2. INFORMATION NOTIFICATIONS

3. BORDER REJECTIONS

4. NEWS

20

0

10

20

30

40

50

60

2009 2010 2011 2012 2013 as on 23 August 2013

No

. of

RA

SFF

Years

RASFF Complaints -Fish & Fishery Products (Controlled Commodity)

Total RASFF Antebiotics

Heavy metals Micorbilogical

Histamine Bad temp/ Alternerd organoleptic

Colour/ additives Others

21

0

1

2

3

4

5

6

2011 2012 2013 as on 23 August 2013

No

. of

RA

SFF

Years

RASFF Complaints -Basmati Rice (controlled Commodity)

Total RASFF on account of Aflatoxins

On account of Carbendazim On account of Genetic modification

On account of Insects Others

22

0

20

40

60

80

100

120

2011 2012 2013 as on 23 August 2013

No

. of

RA

SFF

Years

RASFF Complaints - Ground nuts / Pea nuts

Total RASFF on account of Aflatoxin On account of Oranoleptic charatericts On account of Malathion Others

23

0

20

40

60

80

100

120

140

160

180

200

2011 2012 2013 as on 23 August 2013

No

. of

RA

SFF

Years

RASFF Complaints - Okra

Total RASFF On account of Acephate / Acetamiprid

On account of Monocrotophos On account of Triazophos

Others

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Export Inspection Council (EIC)

DIRECTOR (I&Q/C)

JOINT DIRECTOR

EIA- CHENNAI

JOINT DIRECTOR

EIA-DELHI

JOINT DIRECTOR

EIA-KOCHI

JOINT DIRECTOR

EIA-KOLKATA

JOINT DIRECTOR

EIA- MUMBAI

BHIMAVARAM

COIMBATORE

HYDERABAD

NAGERCOIL

TUTICORIN

VISAKAPATTNAM

AGRA

INDORE

JAIPUR

JALANDHAR

LUDHIANA

MORADABAD

BANGALORE

MANGALORE

QUILON

BHUBNESWAR

DUM-DUM

AHMEDABAD

BARODA

GANDHIDHAM

GOA

PORBANDAR

PUNE

RAJKOT

RATNAGIRI

THANE

VERAVAL

PILOT TEST HOUSE

Note: Export Inspection Council (EIC) is the Apex Body

Director (I&Q/C) is the technical and administrative head for the organization i.e. EIC, India

Five Export Inspection Agencies (EIAs) are headed by Joint Directors and are under Technical &

Administrative control of Export Inspection Council of India.

Sub-Offices indicated with Red Solid fill have lab facility, Green without lab facility and Green is purely

laboratory.

Each EIA Head Office is having laboratory facility except Mumbai

KANPUR

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EIC Network

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Powers conferred under Act

To subject commodities to compulsory pre shipment inspection

To specify the type of quality control

or inspection that will be applied to such commodities

To establish, adopt or recognize

specifications for the commodity To prohibit the export of the notified

commodity unless it satisfies the conditions relating to quality control

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Types of Quality Control or Inspection

Consignment-wise Certification End product based approach

Segregation of ‘Good’ or ‘Bad’

Testing of entire lot or

representative sample

In-Process Quality Control (IPQC) based Certification Control on the process of manufacture

Food Safety Management System based Certification System based approach with added

focus on Food Safety and traceability

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Approval of Establishments

Adequacy audit (desk audit)

Assessment of infrastructure and facilities

Assessment of food safety management system (GMP, GHP, GVP, GAP, HACCP)

Approval of technologist

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3 Tier- Surveillance Mechanisms

Periodic Surveillance [Monitoring By EIA Officers]

Supervisory audit / visit- By senior Officers at EIA Level

Corporate audit – Independent audit by EIC team

Surveillance – External

Complaint / Deficiency Based

Residue Monitoring

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Strengths of EIC

Regulatory authority specifically created by GOI for quality assurance of exported products

No conflict of interest

Decades of experience and competence in quality control, inspection and certification

Nation wide presence of offices

Acceptance, Credence and Recognition at global level

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Technical Competence

50 years of Global Experience

Total strength of EIC : Over 500

Technical team : Over 200

Field team : Over 150

(The team working on field are trained lead auditors on various international standards like ISO 22000, ISO 17020, ISO 17025)

32

Proposed logistic control of primary production by EIC using

Accreditation

ShrimpNet

Hatchery

Farmer

/ Farm

State

Fisheries

Department

Pre-harvest

Screening

Labs

EIC

Referral

Labs

Export

Inspection

Council

(EIC)

Processing

Plant /

Exporter

Regn

By

CAA

Sourcing of

Seeds

Regn. By CAA/MPEDA

Failed Samples

SHRIMPNET Sample from Farm / Pond

for Testing

Sourcing from

Farms with Passed

Test Reports

Consignment

Creation

Inspection of

Consignment

Issue of Health

Certificate

Regn.

By

EIC

33

Important to Achieve ”Win-Win” Situation

Food trade access

International trade

capability

Safe national trade

Improved food safety

Less illness, Less Medical and

Social costs and Less Poverty

Improved health

Improved participation in

national development

Overall Development Of the Country Export Certification Cost should not be taken as Transaction Cost