Mandatory Fortification is the new Chess Game - Sponsored by Vitamin Cartel

Nutrition is the new Chess Game - Sponsored by Vitamin Cartel

Implications of 'Mandatory Fortification' & 'Mandatory Packaging' of Edible Oil

FSSAI should design "National Food Fortification Policy"

- Implementation to Start with Junk Food and Beverages First -

Disclaimer: Views are personal.

Mandatory Fortification is the new Chess Game in Trade politics:

There is no doubt that we have serious problem on nutrition in the country. There is serious deficiency of micro-nutrients among various vulnerable sections. In some pockets of India, there are serious issues with human malnutrition and food security.

We must investigate why this is happening and how to address them in most cost effective way without hurting the food security, without escalating the cost of food and without creating unemployment and without compromising farmers interest as well, without coming under pressure of large commercial interests trying to interfere in India's food security and supply systems. 

Read this before taking sympathetic view on this issue:

Vitamin cartel fined for price fixing 

Click here:

https://www.theguardian.com/money/2001/nov/21/personalfinancenews.europeanunion

Tearing down the facade of Vitamins Inc

Click here: http://www.nytimes.com/1999/10/10/business/tearing-down-the-facade-of-vitamins-inc.html

Vested interests are using Nutrition as new Chess Game:

We must address these issues in war footing but without coming under pressure of interest groups which are shifting the focus from source of problem to maximisation of profits for few may be their sponsors or donors.

Why products with poor nutritional value (i.e Junk foods) is not the starting point?

Many approaches were suggested by experts to address the same but no one is suggesting how to improve nutritional value of junk foods. All are targeting food which are crucial for India's food security. Why so much concern for these products only? Why no concern of the products which are hurting nutritional status of kids and citizens. 

After losing interest in middle east and fuel, Food is new front for political-economy: 

Let me quote few examples to elaborate how food science is used by hiding facts in power politics with commercial agenda:

1.For Food Security and Productivity, everyone was advocating India must adopt GM crops for food application, but due to various conflicting reports on the same topic. Indian policy makers refused to adopt GM technology based on face value, even various experts are having difference of opinion,  and focused on more conventional and sustainable agriculture system based on good agriculture practices. Still jury is out, who to prevent monopolisation and cartel of technologies to ensure choice with farmers and policy makers. What should be the technology policy and how to protect all stakeholders in this technology regime.

2. To push Soybean Oil in India, Mustard oil was declared unfit for human consumption by western experts and scientists. No one expert questioned their finding that Mustard oil is in use for centuries in India. Today, the modern science says there is so such evidence. Fact is all MNCs are selling the same product in India. 

3. Antibiotics was and is promoted as growth promoter in livestock industry by experts and companies, now we are finding the evidence that this is disaster and we were taken for ride by global experts in the name of productivity enhancement and better health. They all made money at the cost of public health in India. Till date, Government of India is not able to change this policy because many policy makers are under the influence of these big corporates.

4.If medicines and agro-chemicals are under patent regime, we get all positive reports, as soon as the patent is expired, the same media is flooded with reports highlighting how dangerous and bad these molecules are.

5. Large number of environmental research findings are under question and they are emerging as tempered documents by vested interests support by experts and scientists. Large car and pharma companies tempered with data for decades, they are still respectable. 

6. Large number of medical research is under question including role of cholesterol in human health, role of antibiotic, vaccination data & deaths associated with vaccinations, etc. Why there is resistance in sharing these data?

Please note these all these reports were backed by technical experts and these were used to influence our policy makers and industry players to follow and adopt the pre-designed targeted trap for commercial interest. 

This raises serious doubt when someone wants to make fortification of food and packaging mandatory in India. What is the game, why suddenly world is keen about health status in India. Reason is simple, mandatory fortification means billion dollar market every year and with price escalation every year. 

There are many such examples in agriculture, medicine, environmental and healthcare sectors.


Trade Politics is integral part of world trade order. These things will continue, in India and in developing economy we have to be vigilant of these mover and we must learn to protect our interests. India is a huge market, all sorts of tricks and techniques will be used to penetrate in this market. 

India needs Sensible Nutrition and Fortification Policy:

There is an attempt by FSSAI to push for mandatory fortification and packaging of edible oil. At the outset, the approach looks very sensible but the hidden dangers and implications are not discussed. The way it is pushed and the way difference of opinions are suppressed this shows there is more than what is visible to the outside world. 

How Indian oil economy was changed in favour of world market players?

To understand this, we must understand why and how India became the largest importer of edible oils in the world and how systematically our oilseed and livestock is destroyed by such foreign funded experts and advisers.

Let us be clear no one is funding these so called charity work or development activity to make India as healthy and developed nation because no one wants India to become powerful and competitor, so we must be careful about these imported advises and advisers.

How Systematically India’s oil industry is destroyed?

Today, India imports more than USD 10 billion worth of edible oil. Our dependency on oil has become 60 to 70%.

How all this started?

Oil seed crushing and edible oil industry was reserved for Small Scale industry. Suddenly, at the time of liberalisation, there was a movement in India that we want to scale-up and allow FDI. Many players said we will bring better technologies so that we can set-up modern facilities and this will help farmers and more production will help Indian farmers and they will get better price. After repeated request to think carefully about this, it  may not happen because in edible oil processing there is no rocket science and productivity has nothing to do with processing technology. No one was willing to accept these facts in industry and in policy makers. Policy was changed under pressure. In order to give political comfort government announced 150% to 300% bound duty in edible oils under WTO agreement. This was all done on the advise of imported experts in planning commission and in trade related discussion in Industry associations. 

What is the outcome?

Once the policy was liberalised in the name of helping the farmers by large scale investment in edible oil sector, large players started investing in edible oil sector. But where? These investments were at ports but not near production areas or for processing of oilseeds from farmers but to process imported and subsidised edible oil from the countries whose experts and guidance we imported as role models.

Now, Indian farmers have to face competition from cheaper imported oil and crushing units near farming areas for oilseeds became unviable. Slowly large number of small scale units closed and farmers suffered the most. Oil seed production and productivity virtually came to standstill.

All our traditional oils from Groundnut, Sunflower, Sesame, etc. went out of market due to high cost of production in comparison to cheaper soybean and palm oil.

This impacted the whole drive of oil seeds production in India. India’s oil seed started stagnating or moving down in many states or remain stagnant. This means for our growing population dependency on imports started moving upwards and today we are importing almost 65% of our edible oil requirement.

Damage is serious and multi-fold:

The worst affected sector due to loss of crushing units is our livestock sector. When oil seed is crushed oil meal is also produced which is the only and most popular source of protein for livestock sector. When oil seed crushing goes down supply of oil meal will also go down. This will create acute shortage of nutrition for milking animals like cows and buffaloes, poultry and fisheries. This means our animals will not have proper meal to improve productivity and cost of milk product will go up due to shortage of feed and fodder. This is precisely what is happening. Our milk prices are going up. Now there is demand to allow import of milk and milk products from the world market at lower duty, because local cost of production is higher than world market.

Now, who is gaining from the policy change of Government of India as advised by foreign funded experts? India, Indian farmers or the sponsors of these experts. Think about it.

Think about mandatory fortification and mandatory packaging policies seriously, when commercial and trading interests are involved, no one is saint here. After all who is funding NGOs and what is their interest in India that too in oil. Why they are not working with Junk food where nutritional improvement is badly required.  

Now let us talk about new agenda pushed by foreign funded NGOs and Experts called “Mandatory Fortification and Mandatory Packaging of Edible Oils” in detail.

Opening statement is bound to be for good cause i.e. let us address nutritional deficiency mainly in kids, ladies, etc.. Oil is the only commodity consumed by all. Now agenda is let us use edible oil as vehicle for change and nutritional welfare.

What is the agenda?

Hidden agenda is all large players have already captured urban edible oil market. Now agenda is how to capture rural market so that import of oil can further increase because in world market there is surplus and they need market to sustain prices. The best way is stop loose oil sale and make fortification mandatory under the caption of nutrition and adulteration. It is a noble cause.

It means either upgrade or close down. Minute there is mandatory clause, all suppliers will jack-up the prices.  Small scale oil crushing units will be closed, India’s oil seed production and crushing sector will further shrink due to lack of market for farmers output and import of edible oil and oil meals for cattle feed will further go up. The best way to keep India under check and out of world market. This is also one of the reason why our animal productivity is so low because there is no oil meal which is the source of protein for animals.

What can be better way than using mandatory “Vitamin Fortification” to achieve this objective. Most experts and scientists those who are invited to these conferences are used as pawn in these chess game without their own knowledge, because they are not aware of politics of trade. Vitamins will be INR 1000 crore business, if made mandatory, with huge margins.These companies can afford to spend these money to take care of experts the way they do in pharmaceutical industry. The experts feel their knowledge of nutrition is ultimate truth for the betterment of the world. yes, but they do not have any suggestion how to control trade politics and monopolises. 

Do we need mandatory fortification and mandatory packaging?

Answer is No. It will create more problems than proposed solution.

Mandatory fortification will hide bad practices in edible oil industry.

We have following questions, which FSSAI, policy makers and the NGOs should address.

1. In line with unpolished dal. Why filtered edible oil is not promoted by FSSAI? Filtered oil is better in nutrition and vitamins, this was our traditional concept, but FSSAI is not willing to promoted? Why only fortification? Who is doing brainwashing?

2. Refining destroyed nutritional value of edible oil. Only old and stale oil needs refining which is imported after prolong storage at ports. These NGOs will never criticise oil refining which is destroying nutritional value of edible oils. Why? Because they are told and funded to promote fortification, not nutritious methods of oils. This may not be in the interest of their donors.

3. Do we have quality and price norms for Vitamin Premixes to ensure purity of premixes? Let FSSAI place them on website for public comments.

4. Do we have enforceable mechanism to prevent cartelization of suppliers of vitamins? Let FSSAI place them on website for public comments.

5. Do we have testing methods which small scale unit can test the purity of the premix offered? Let FSSAI place them on website for public comments.

6. Premix is widely used in animal feed industry, what is the mechanism to differentiate between the two. Animal feed grade pre-mix will be far cheaper than human grade pre-mix. What are the labelling guidelines for pre-mixes. Let FSSAI place them on website for public comments.

7. What is the implication of heating and cooking temperature on Vit. A and Vit. D when used in combination? Please place those studies on website for comments. Will they not react with each other? Any data to prove this? Point because many experts raised this issue that is why in India we do not allow many additives in edible oils which are used worldwide. Let FSSAI place them on website for public comments.

8. What should be the price escalation of edible oils due to mandatory fortification and mandatory packaging? Will this help poor man's diet or distort it. Per unit price of oil intake will go up. Any analysis done by FSSAI for 130 crore population. Let FSSAI place them on website for public comments.

9. Who will ensure vitamin and oil industry follow these norms and there is no fake labelling on packed oils?

Fortification is not bad, but why to make it mandatory when there are no manufactures of vitamins in India. we only have pre-mix suppliers based on imported vitamins and we have no control over their quality and trade practices. 

Let all information with testing data should be displayed on FSSAI website. If FSSAI believes in transparency, so let these information be on the website for comments.

Mandatory Packaging is not the answer.

1. Can FSSAI ensure that all packaged food in the market are free of adulteration bearing FSSAI registration number? Can FSSAI give this undertaking to Parliament and courts? If not, it means packaging is not the answer.  

2. In fact, this will increase consumption of plastics and create environmental hazards. On one hand, Supreme Court is directing stop use of plastics, on the other hand FSSAI promoting use of plastics? Which packaging option FSSAI is suggesting?

3. Plastic files themselves are source of toxic residues and leaching of colors and plastic pigments and additives in oil is common problem. What quality specifications are proposed for fortified oil filling purpose.

4. If not stored properly, vitamins will lose their potency even faster. Exposure to heat, light, and air can cause vitamins to degrade faster. What is the shelf-life of vitamin pre-mix and what is the potency of vitamins in edible oil? In India, we have about 10,00,000 retail outlets. 

5. Which packaging materiel is suitable for fortified oil to ensure potency of vitamins added?

Closure of Local units due to mandatory fortification and mandatory packaging will lead to serious social, economic and political crisis in rural India.

1. Who will buy farmers produce? Can local crushing industry compete with low cost or subsidised oil coming from international market? Will this help in Doubling Farmers' Income?

2. Will FSSAI or government provide capital cost for upgradation? This is vital because overdosing can lead to toxicity and under dosing will be violation of the law. Human error can be fatal for consumers.

3. How FSSAI or govt. will ensure that there is truthful labeling on oil packages about fortification. How consumer can identify the difference between fortified and unfortified oil with fake labels. Till date we have not seen any action by FSSAI against bad manufacturers? Where is the confidence level to ensure safe product to consumers.

4. Will pickle manufacturers and other food manufacturers will be forced to use fortified edible oil? What about carryover effect, will FSSAI laws permit the use of antioxidants in every food where edible oil is used?

Let all information with testing data should be displayed on FSSAI website.

Concern:

1. There are no representatives on behalf of Small and Cottage industries in the committees of FSSAI.

2. There is an attempt to stop the suppress the views from the domestic industry. Majority is against mandatory fortification, then why FSSAI is pushing it so aggressively, with answering above mentioned questions.

3. This means all decisions are taken by people those who have no interests in survival of small and cottage industries, the main source of employment in India. Domestic small and cottage industries is not part of expert committees of FSSAI. They are represented by vested interested groups via associations.

4. Please note: Companies those who are doing fortification is mainly dependent on imported oils for their refining business. It makes sense for them to use fortification because after refining they want to use fortification for branding purpose. By making mandatory fortification, FSSAI is forcing seed based local companies to bear more cost and loose competitive advantage. Why this approach by FSSAI is not clear?

The way forward: 

1.  Let NGOs start fortification with junk foods. Let nutritional experts work on how to make colas nutritionally better, as suggested by Hon'ble Prime Minister. Let these NGOs disclose how much work they have done to improve junk foods. Is this mandatory in these foods, if not the why target healthy food options like filtered oils?
2. Why NGOs are not promoting filtered oil consumption which are better in nutritional value and low in cost? Why are only keen to promote imported vitamins in India from donors countries into Indian food system? 
3. Why they are keen to make it mandatory in edible oils, when this is not the case in any other country?

Suggestion: 

1. Start with junk foods, make them better before targeting already nutritious & healthy options. Items which are not imported or traded by large corporations.

2. Fortification & Nutrition awareness must be the role of NGOs, but not forcing policy chnage in democratic countries. 

3. Let these NGOs help in technology transfer for "Make in India" for vitamin manufacturing before we think of making mandatory. Even today 100 percent Vitamins are imported by livestock sector. 

4. Promote Filtered oil and discourage refined oil, to address Vitamin deficiency problems. The traditional oils of India.

5. Promote balanced diet to promote balanced nutrition intake.

6. Work on alternate packaging methods to minimise use of plastics in oil packaging. 

7. Let NGOs suggest, how to neutralise the price rise impact of mandatory fortification and mandatory packaging on common man. 

8. Let NGOs also suggest, what about credible testing methods to know potency of Vitamins added in oil at consumer level to stop FSSAI inspector raj harassment.
9. When we have live examples of cartelization in Vitamin space, are these companies willing to enter into agreement with FSSAI that they will not increase the price of Vitamins either directly or indirectly.
10. Leave fortification as optional because many herbal and medicinal plants are integral part of Indian diets. Promote holistic & balanced diets in place of chemical additives as short-cuts. Fortification should be the last option, that too for targeted population. 

Concern: FSSAI should be seen neutral. So much affinity and aggressive attitude of senior officials for two Vitamins, which is always part of cartel world-over, is raising eye brows in food industry and trade. All are noticing and are concerned but rarely saying in open forum to avoid harassment by inspectors of FSSAI. 

Why such commitment is not visible in other issues and activities like ensuring transparency in functioning of laboratories, ensure food recall, book the bad suppliers, ensure mandatory testing of products facing rejection in the world market and these evidences are on website but no action, action against laboratories and certification companies to task issuing fake or wrong certificates, all supporting data of studies and trial reports used as basis to promote mandatory fortification, address corruption in field level by introducing whistle blowing scheme online to protect the affected parties and ensure integrity in sampling / testing, etc. Why there is no similar enthusiasm in addressing these issues which will ensure food safety for all. 

If all these issues are addressed on regular basis, I will request FSSAI to place all the records on the website in public interest.

Hope situation will improve with time and FSSAI will understand the concerns of food industry. Looking forward for better days ahead.

  Let me conclude by saying, fortification with essential nutrient is important but don't make it mandatory. This will eliminate small and medium scale industries, they will be at the mercy of cartel and inspectors will harness by saying your fortification is not proper. This will force the companies to go for packaging it means food costs will go up. Example: Today if a poor family buys 100 ml in Rs. 10, they will only be able to buy 50 ml in Rs. 10 after mandatory fortification and mandatory packaging. Is this good for them?

Those who want fortified product can also demand in their tender fortified product by changing  specifications of tender. They will get it.  Why make it mandatory and eliminate small and cottage industry and create another layer of corruption by inspectors.

There are many pre-mix suppliers, they are smoke screen, but they all are depended on original Vitamin suppliers and there are jut three companies in the world and their is Cartel as per EU and US authorities. We have live example what is happening in livestock feed industry where all are doing fortification and the problem of quality and cost they are facing.

 Those who want fortified commodities like state governments for PDS and Mid-day meal program, they can always add a condition of Vitamin A or Vitamin D or other micro-nutrients in tender document, those who are keen can supply to them.

Request to FSSAI:
Let FSSAI enter into agreement with Vitamin manufactures on price control formula first to prevent cartelization and discuss this with industry if they are serious about fortification.

Let FSSAI promote filtered oils in place of refined oils to address the same problem in lower cost than adding cost to common man. Nutritionally, filtered oil made by Small companies are far superiors than refined oils of large companies. This will help rural economy and farmers as well, mandatory fortification will help mainly port based refineries.

Pl. discuss the action plan on these two points with industry at the earliest if FSSAI is serious on addressing nutritional challenges in India. 

FSSAI must be aware that any decision which will hurt local Small and medium edible oil industry and farmers will face resistance.  

Before thinking of enforcing mandatory fortification FSSAI must gain trust of common man by addressing the existing problems of poor enforcement and massive corruption under existing food laws, before adding more problems for food industry operators. 

Let me sum-up by saying, Fortification is good for affected consumers, but the way FSSAI is pushing fortification in Indian edible oil industry is going have serious implications on Small and Medium industries. 

MANDATORY FORTIFICATION will lead to serious problem like another layer of corruption by food inspectors (we have seen in what happens when BIS was made mandatory for packaged water and biscuit industry), 

MANDATORY FORTIFICATION will lead to closure of small industries due to small scale of operation can't afford these capital investments, highly fragmented and exposed to sunlight distribution channels which will reduce the potency of Vitamins in products and lead to legal implication and monopolies of vitamin producers (livestock feed industry is already suffering), 

MANDATORY FORTIFICATION will lead to litigation due to lack of  reliable testing methods by FSSAI Labs (till date FSSAI is not able to enforce recall because FSSAI bosses do not trust their own laboratory results and lack of transparency in operation of sampling and laboratory systems of FSSAI) and lack of enforcement ability of FSSAI laws will also make this whole activity doubtful and misleading ( because large amount of adulterated products are already in market and food poisoning cases are common, but no VISIBLE action by FSSAI against defaulters), no investigation on companies, laboratories & certification companies whose samples are failing in the world market this list is updated every week and every month but no action by FSSAI by various food safety authorities around the world originating from India the same companies are offering doubtful products in Indian market, (it seems food safety is not the priority for FSSAI). These are clear evidences that mandatory fortification and mandatory packaging is not based on ground reality but some other consideration. 

Why FSSAI is not transparent and taking action against companies registered by FSSAI and offering bad product worldwide. Why this silence is not explained by FSSAI?

Even WHO and other global agencies says where there is highly fragmented industry like in India, MANDATORY FORTIFICATION will lead to problems of enforcement and is not advisable. So, why few officials of FSSAI, (many within FSSAI are also not comfortable with this approach),  are so keen to push this agenda based on advisory of foreign funded NGOs, planted within FSSAI offices (this itself is conflict of interests), those getting donation from Vitamin manufactures. This mystery is still unresolved.

In current form, the way it is pushed, MANDATORY Fortification (not voluntary) seems to be a cover for trade politics to eliminate small edible oil industry from India and this will disturb oil seed production in India and dependency on imported oil will go up...

What FSSAI should do is create awareness about nutrition and safe food among masses and who to selected good food like filtered oil in place of refined oil. The imposing unworkable & hidden agenda will ruin our edible oil economy and livestock sector will also suffer, if rural oil mills go away.  Beware of politics of trade. 

If everything is for noble cause and for the benefit of humanity, why Vitamin Cartel was fined by EU and US government?

Do you have any answer?