Saturday, September 29, 2012


Who does not want to look lean and strong and besides the cosmetic value a good personality radiates, lean body mass is a scientifically proven route to keep good health. While following a strictly balanced daily diet is the surest way to good health, as in many cases of human life, such disciplined eating is more easily talked about rather than being followed! This human weakness for good tasting food with irresistible  flavor and texture credentials is being exploited by many industry players with utter disdain for consumer well being. There are a number of preachers for weight reduction like Atkins, South Beach, Portion Planners etc and billions of dollars of business is riding on this area of health management. How far they are able to substitute human determination and self exercised will power is a mute point as long as there are willing consumers to believe in such unnatural means of achieving weight reduction as quickly as possible.

One of the earliest theories which was floated to achieve longevity and good health was practicing a diet low in calories, much lower than what is recommended, which is supposed to control the body metabolism for preventing fat accumulation responsible for weight increase over a period of time. It was in 1934 that Restricted Calorie (CR) diet theory sprouted in Cornell University, USA based on demonstrable effect of such a diet in extending the life span 100% in rats under laboratory conditions. Since then hundreds of studies in different parts of the world did show that reducing calories in daily diets to the extent of 10-25% could prevent undue weight gain in many animal models. It has been claimed by these studies that such diets are successful in controlling blood pressure, fasting glucose, fasting insulin, BMI, body fat percentage, C-reactive proteins, carotid IMT, Platelet derived growth factor AB and boosting memory status among the animals studied.

An indication about calorie restriction effect was obtained during early studies with yeast, fish, rodents and dogs and such CR diet regimen without causing micro nutrient deficiency was shown to increase both median and maximum life span among the animals studied. Though these results were taken as proof of the scientific basis for confirming the effectiveness of CR diets and promoted for human beings also without adequate mammalian or human studies, there has never been a "sufficiently powered" long term randomized clinical trials of CR in humans to confirm or deny its efficacy in achieving what has been seen in animals. The longest running scientific study of CR in primates has been undertaken in University of Wisconsin and is going on since 1989 without coming to any definitive conclusions regarding the success of CR diet universally.    

CR diet intervention and its usefulness in prolonging life became a focal point of attention recently when National Institute of Health came out with some startling news based on studies in its Institute of Aging (NIA) that CR diets might not be as effective as being claimed during the last several years. After 25 years of observations, it came out that rhesus monkeys fed only a lower-calorie diet lived no longer than their rhesus mates who ate a little more and weighed a little more. This is in stark contrast to what was reported earlier from a slightly different study led by investigators in Wisconsin. which found healthier life for their group of starving monkeys. The NIA study was of a blow to many enthusiasts who whole heartedly welcomed the idea proving that "less equals more when it comes to eating"!. Unfortunately this finding may have the consequences of nullifying the mindset among many consumers that self restraint, continence, and composure in controlling one's appetite pays off in the long run. But the jury is still out on this issue and a closer look at the results may suggest it's not time to indulge in foods ad libitum just yet.

A critical question that may haunt weight watchers and "long life' lovers is whether the new information will allow one to eat a bad, sugary diet, provided too much of it is not eaten. The simple fact is that if one eats more of such foods without control, death is likely to visit sooner than later!. However if good food in terms of balanced nutrition with low sugar, salt and fat using more of whole grains, it may not matter even if more is eaten. In terms of longevity whether CR diet or rich diet, life span may be same though those in the latter category, eating more will still live long albeit weighed down by diabetes and other medical conditions. At least that is the current take on this interesting issue!


Sunday, September 23, 2012


Jute cultivation and production are more or less concentrated in the Indian subcontinent and being the second most important natural fiber after cotton, it has garnered for itself a distinct market during the last 300 years. Britishers, the colonial overlords in this region till the first half of last century were literally looting countries like India by taking the harvest to the UK to process into value added product for local use. Though the jute fiber extraction and processing were predominantly manual, Britishers still found it a good source of high quality fiber with many potential industrial uses. It is a fact of history that Britishers discovered a special way to make jute fiber amenable to machine processing involving treatment with Whale oil. It is another matter that many innovative products have been developed using jute as a base and jute is meeting the new aspirations of the modern world to move away from synthetic fossil fuel based fibers by providing an excellent natural alternative.

The jute plant belonging to the genus Corcherous yields long, soft, shiny vegetable fibers, found very strong with many desirable physical properties. It is a ligno-cellulosic substance containing both cellulose (plant fiber) and Lignin (wood ) and hence provides the softness of celluloe as well as the strength of wood. There are similar fiber sources growing wild like Kenaf, industrial hemp, Flax, Ramie etc which are available only in limited quantities in some parts of the world. Organized cultivation of jute is confined to India, Bangladesh, Myanmar and to a smaller extent in some other countries and the most prolific producers are India and Bangladesh, accounting for more than 95% of world production to day. While Bangladesh exports a substantial portion of its jute production, in India there is enough domestic demand to absorb the entire production leaving very little for export.

As many jute mills are reporting losses in their operations because of the advent of more economical and convenient plastics based bags, it had the effect of reducing demand for jute bags progressively. Government of India in its wisdom came to the rescue of jute mills, probably considering the adverse impact large scale closure of these mills might have on jute farmers and mill employees, promulgated coercive laws to force two commodities viz, food grains and sugar to be sold only in jute bags. It is true that jute is eminently suited for packing these materials but providing such a prop for a section of the industry raises some questions regarding its impropriety. How can the rich jute mill owners have any incentive to bring in innovation and improvisation for modernizing the production facilities and diversifying its use into other more profitable areas under such a protective regime? Is it not that the government is exposing its weakness by the blackmailing tactics of the jute mills by way of threatening their closure frequently?

Why should the jute industry be given such protection? Is the price of jute in India very high compared to prevailing prices in the neighboring countries? What prompted the government (GOI) in this country shoot down a proposal to import jute from Nepal and Bangladesh in the light of complaints by the users about shortage? The ruling price for jute in Bangladesh is about Rs 7000 for a bale of 180 kg while in India the corresponding price is Rs 3000 per 100 kg which is some what cheaper and therefore importing jute from that country is going to be costlier. Unless there is a significant quality superiority who is going to buy jute from Bangladesh?   

The Jute Packaging Materials Act (JPMA)-1987, a Central legislation, provides for 100 per cent mandatory reservation for jute bags for packaging of sugar and food grain. Since both sugar and foodgrains are under the reserved sector, the Union law ministry has expressed reservations over import of gunny bags from Nepal and Bangladesh under the garb of legal and technical difficulties. It should be recalled that the very GOI had allowed such imports earlier, probably for use by industries other than food grains and sugar packers. If the Jute Mills Association (IJMA) spokesman is to be believed only one million tonnes (mt) of jute sacks are needed to pack food grains and 0.2 mt for packing sugar. This can be met comfortably by the Indian jute industry which has the capacity to churn out 1.5 mt of sacks and sacking capacity is almost 0.55 mt higher than peak government demand. One wonders whether these calculations are really realistic considering the bumper production of food grains this year with the possibility of a substantial portion of the surplus production forced to be stored under the CAP mode using gunny sacks as primary packing material. 

Bangladesh, considered an "all weather" friendly neighbor to India, produces around 0.5 mt of gunny bags each year as against India's 1.1 mt. Bangladesh's raw jute production is around five million bales (1 bale is 180 kg) in comparison to India's 11 million bales. What is notable is that Bangladesh is a more prominent player than India when it comes to international trading in jute products. There is an allegation that this country mostly thrives on discounts that are covered up by huge government subsidy, enabling the jute industry there to export over 60 per cent of its products while Indian export is hardly 10-12 per cent. Interestingly the jute bag order exempts packing below 25 kg and above 100 kg from its purview! Major industrial sugar users like giant beverage manufacturers still refuse to use Indian gunny bags as they contend that sugar packed in these bags is unsuitable for their manufacturing process! 

It is time that the closed Indian mindset in controlling "every thing and every body" through the brutal power at the disposal of the government is changed in favor of a free regime as under the WTO regime and allow free trade for attaining its own equilibrium through market forces. If Bangladesh is using unfair means for dumping its jute bags in the Indian market there are always policy and legal options to check them. Jute is a precious natural resource which is likely to be pole-vaulted into prominence in the near future because of its multifaceted advantages. It is 100% biodegradable, cheapest fiber available, high tensile strength, low extensibility, better breathability, low thermal conductivity, good aquastic insulating property etc. Of course its poor drapability, poor crease resistance, britleness, fiber shredding tendency and gradual yellowing may make it unsuitable for some applications. Even if a fraction of the investment going on cotton fiber development in India, were to be made for improving jute fiber, the results would have been phenomenal by now! Scientific neglect of this sector has ensured that it remains an archival piece on the modern industrial landscape in the country. 


Sunday, September 16, 2012


Body Mass Index, better known as BMI world over, is supposed to be a marker for considering whether a person is healthy, over weight or obese and this has stood the test of time for decades without seriously being challenged by any other more appropriate body health monitor. BMI was first suggested by Adolph Quetelet, the reputed Belgian mathematician of nineteenth century, around the year 1832, for comparing the health conditions of people based on the body parameters, height and weight and it was known as Quetelet Index or QI. As it became the golden standard since then, the only change that was seen subsequently was changing the name to Body Mass Index in 1972 to make it more explicit and reflect its relation to human health. There are some variants of this evolved later like Fat Free Mass Index (FFMI) and Fat Mass Index (FMI) which take into consideration the influence of body fat in distorting the BMI values. In spite of all these developments BMI is still the universally adopted testing protocol for body weight related problems in populations around the world.

BMI is the ratio of the body weight to the square of height of a person and both Metric and British measuring units can be used to arrive at the figure. For example a person with a weight of 75 kg and height of 1.7 meter is deemed to have a BMI equal to 75 divided by square of 1.7 which comes to 28.9. If British units are used it must be weight in pounds divided by square of height in inches. According to present norms a BMI figure between 18.5 and 25 is considered optimal and if the same is outside this range remedial steps are called for to correct it through appropriate measures. While BMI less than 18.5 is considered to represent underweight, any value above 25 is not taken as normal. In to days world when the number of obese people is increasing at a phenomenal pace through out the world, especially among populations in affluent countries, values of BMI are very relevant to assess the healthiness of people. BMI values 25-30 represent over weight, 30-35 moderately obese (Class I), 35-40 severely obese (Class II) and beyond 40 very seriously obese or morbidly obese (Class III). Obese people do need medical attention while morbidly obese people may even require surgical intervention like gastric banding. According to social scientists monitoring the heavy damage caused by obesity in a country like America, same may work out to $ 344 billion by way of increased medical bills and $ 73 billion through lost productivity!

BMI Prime is another mathematical tool to compare body weights among the population though it is not clear why there should be another such yardstick when BMI monitoring has served the world admirably well for the last 180 years. BMI Prime is the ratio between the actual calculated BMI value and the optimal BMI value of 25 and when it is 1 body weight is considered normal.  Aberrations in BMI values do occur in many cases and there is some ambiguity as to how far they are true reflection of health status at least in some people. For example athletes with high lean body mass invariably show higher BMI figures while they are actually very healthy. Same is true with people with varying body frames but same weight. When it comes to Asians, in stead of BMI of 25 as normal, the recommended optimum BMI value is 23. Fat levels in the  body, especially the visceral fat is not considered in the BMI calculations as it very significantly plays a role in obesity and there fore the protocols like FFMI and FMI are being mentioned as more appropriate to determine the body health of the population. 

As fat levels have great influence in body weight changes, many health experts believe BMI needs to be linked to the body fat content some way to reflect the real health of a person. Total body fat varies any where from 20% to 30% for human beings with women having almost one and a half time that of men. If the body fat content exceeds 32% it is considered as reflecting  real obesity in women while in case of men values above 25 indicate on set of obesity. But measuring body fat is not that easy because of enormous variations encountered with different techniques available to day. Hydrostatic weighing or underwater weighing is often considered as most reliable method of fat assessment in human body though other techniques like skin fold measurement, body girth determination, body impedance, air displacement method, body scanning etc are also deployed for the same purpose by different investigators.   

All said and done, there are still gaps in the science of assessing obesity though BMI, the mainstay of medical research on body size and its relationship to health. But while the BMI is a fine measure of a large population's tendency toward illness and early death, it's a poor predictor of those outcomes in individual patients. According to a new study waist circumference may be a better predictor of health as it is an indication of presence dangerous fat deposits around visceral organs though measurement of this parameter is not easy as discussed above. The new paradigm called A Body Shape Index with the acronym ABSI is calculated as waist circumference in centimeters divided by the product of multiplying the square root of height in centimeters with cube root of BMI. If those who developed ABSI are to be taken seriously, this new technique can predict the chances of those who face higher risk of death within the next five years as per their extensive field studies of thousands of people with varying degree of over weight. It is known that those who are obese are more vulnerable to diseases like Type II diabetes, CVD and some types of cancers but the danger is more from the the unwanted fat deposits which are now factored into ABSI. With over 78 million adults and 12.5 million children reported as obese in the US, this country has a vital stake in developing this tool further to save enormously in terms of saved lives and wasted resources. 


Wednesday, September 12, 2012


Information Technology (IT) has changed the face of the modern society with PCs, Laptops, Mobile Phones, Tablets and Electronic Game consoles dominating the day to day lives of people. Younger generation cannot conceive of a life without these gadgets and if the educational and knowledge frontiers are continuously being pushed further, thanks are due to IT enabled daily lives. The famous Nitendo games like Wi are so popular that they tend to be addictive. Exclusive telecasting channels, dedicated to kids are doing extremely well financially. But for the electronic media, most of the consumer oriented products would not have raised the volume of business as they are able to do to day. Of course on the bad side of the coin, one can cite the negative impact of advertising unhealthy foods or so called junk foods which are causing severe strains on the health of the consumer in the form of many diseases, fighting against which billions of dollars are spent. 

One of the most remarkable developments in the electronic field is the smart phones and PC tablets with a variety of functions and highly user friendly features. Practically all daily chores can be done to day through smart phones including family purchases through on-line offerings or from established super markets. Dining has become a new experience because of Tweeting and Facebook. Food industry is benefited immensely by developments like fast safety monitoring devices, quick time gene sequencing gadgets, automated analyzers, electronic sorters, automated process controls, radio frequency based labeling etc. Supply chain vis-a-vis food is getting increasingly shortened because of electronic monitoring and protection of food in transit and storage. If past developments are extrapolated it can be assumed that no human endeavor is going to be left untouched by the electronic revolution that is taking place at a furious pace.

Practically no kid living in the US will be unaware of the Wi games being marketed by the Nitendo entertainment company and through simulation kids are made to perform a variety of games which gives a feeling of being in the midst of the game as a participant. This concept was used by Japanese first to sensitize the urban folks to the logistics involved in production of food in the rural areas, situated far away from their dwellings. Japanese made RPG series offering Harvest Moon, a popular entertainment program, was a big success and there have been many such programs which followed it. They included Sunshine Farm, Happy Farmer, Happy Fishpond, Happy Pigfarm, Farm Ville, Farm town etc all offered for exposing the urban folks to various aspects of agriculture production mostly located in far away rural areas. They are basically farm management simulation programs, popular mostly in China and Taiwan. They allow players to cultivate different crops, sell them in the market, stealing some from the farms next to them and similar activities associated with real growing in the field. 

The cultivation related video games are so popular in the East Asian countries that according to some estimates more than two million players are spending at least 5 hours each day on these programs! Why is that the urbanites are attracted to such games is still a mystery. Probably the fact that many of them are ignorant of the history of foods they consume every day and the inquisitiveness to understand the same may be the driving force behind this unique phenomenon. While this is understandable in a country like Japan with limited land available for agriculture, China is a vast country with millions of acres of land under cultivation by many small farmers and a few miles drive from any city can take curious citizens to see for real the agricultural operations with their own eyes. Video games are mainly "time killers" with the players able to relax for some time from their boring routines and agriculture simulating games have the added advantage of gaining knowledge, albeit unconsciously.

Against such a back ground one of the entrepreneurs in China has married the reality to virtual reality by offering real time pig raising facilities with a provision for participation by urban folks through computers as well as actual visits. Chinese are the biggest eaters of pork and any venture associated with pigs can be expected to attract attention. Unlike conventional system of rearing pigs, the new venture has created a vast net work of small covered areas for housing pig families which can roam freely within the farm and each unit called a "Pig Villa" has comfortable living facilities which is thought to raise the quality of meat from these animals. One of the USPs of this model is that urbanites have an option to invest on one or more pigs, suitably identified by investing at the piglet stage and monitoring the growth through closed circuit television facilities. Considering the critical importance attached to food safety, the pigs are fed with vegetables only and therefore the growth period may get extended from 6 months in a conventional farm to 10 months in Pig Villas. The farm also provides slaughtering services to recover meat and deliver to the owners. 

According to the pioneers of Pig Villa the farm is ecologically sound with no foul smell emanating as the bed provided for the animal is based on a specially designed mixture containing some agricultural waste materials. The pig droppings seem to get fermented and release beneficial bacteria which breaks down the excreta into harmless products. This system also avoids administering antibiotics to the animals because of the safe environment of each villa, not allowing pathogens to proliferate and cause safety problems. In a country where food scandals and frauds are rampant, Chinese people are increasingly getting concerned regarding the quality and safety of foods they consume. Though the pig villa project is termed unrealistic and expensive, there is safe bet that the insatiable demand for pork will drive the industry to seek innovative technologies and systems to boost the quality further and premium quality cuts can fetch good prices from a population flush with money due to the economic boom in that country.

Why is that Chinese are so attached to pork? Probably the old civilization with more than 7000 years of history behind had zeroed in on pork as the easiest and fastest way of producing. It is no wonder that half the population of pigs in this world are raised in China, numbering over 500 million, almost half the human population in that country! Demand for pork which was a measly 8 million tons in 1978, has soared to more than 70 million tons to day! The present production of 50 million tons of pork is slightly more than50% of global production and Chinese per capita consumption is estimated to be a whopping 40 kg per year. Intelligent as they are Chinese are even outsmarting the Americans by large scale import of better breed piglets and farming technology from that country and using less costlier operating practices they are able to produce pork at much lower cost than their American counterparts..

Spread over several hundred hectares, the Suining farm where pigs are raised scientifically to protect them from health problems is reported to be  building about 600 so called villas with each one home for 10 pigs. in an area covered by large banyan trees to provide shade and control temperature. Each villa is supposed to cost around 8,000 yuan ($1,260).In each cottage, about 10 piglets are raised on floors covered with a black, powdery mixture of wheat bran, rice husks and sawdust which acts as a natural fermentation bed that releases beneficial bacteria, which can break down a pig's excreta. Usually the piglets nuzzle up to their mother in the cottage, while some time they can be seen running around the property freely. The project is part of a comprehensive development plan by local authorities to better utilize the old channels of the Yellow River. The disused channels encompass a vast area of up to 12,000 hectares that has been identified as an ideal location for agriculture and agriculture oriented tourism. It is hoped that a consumer, say sitting in Beijing, will be able to adopt a piglet for 4,000 to 5,000 yuan a year, nearly double the price of an adult live hog in the market and enjoy the "fruits of his labor" after 10 months without moving from his chair or soiling his hand!. 

Wednesday, September 5, 2012


According to nutrition science calories, proteins, fats, carbohydrates, essential fatty acids, essential amino acids, vitamins and minerals required by the human body to grow and maintain good health need to be supplied through the food consumed. There are well laid down and universally accepted norms of nutrition vis-a-vis requirements of different nutrients. While carbohydrates in the food consumed provide bulk of the calories required by the body, fats account for about 30% of calorie needs. Proteins, though can supply energy, are used by the body mainly for building of tissues and generation of hundreds of enzymes that catalyze all the metabolic reactions in the body. Vitamins and minerals have their own roles to play in assisting various cellular functions. It is well accepted that a gram of carbohydrate and a gram of protein can supply 4 calories each under ideal conditions whereas a gram of fat yields 9 calories. A human being requires about 2000-2500 calories a day to maintain normal activity, about 50 gms each of proteins and fats besides recommended levels of micro nutrients and dietary fiber. 

What happens to the food after it is eaten is well known and even an elementary school student can elaborate on the sequence of changes that take place once food is ingested. Just to recap, the teeth are provided to chew the food and after mastication the fluid material goes through the stomach for protein break down, followed by further break down of carbohydrates and fats to simple molecules in the small intestine, suitable for absorption into the blood. The residue after "digestion" goes into the large intestine for resorption of water and fecal evacuation. Of course the entire digestion process is so complex that only those having necessary specialized knowledge about human anatomy and physiology can explain the same correctly and correctly. It is generally believed that 50% of the food passsing into the stomach is emptied in about 3 hrs time while 100% leaves in about 4-5 hrs. Similarly 50% of the content coming to the small intestine gets out in about 3 hours while it takes 30-40 hrs for the entire post digestion residue to transit through the colon. Having stated this, it has to be admitted that there are significant variations in these values from person to person and from food to food. Those who do not have regular bowel movement or others eating foods with low fiber may have fecal transit time as long as 48-72 hours.

One may ask why this interest now on an old topic like digestion in human body? Provocation comes from two recent scientific reports that the relationship between calorie content of a food and its actual availability to the body after it is consumed may vary enormously and the calorie content declared on front of the pack labels needs to be moderated to factor the individual variations in digestibility from person to person. For example it has been reported that when nuts like Pistachio and Almonds are eaten about 5-20% of the fat present in these nuts appear undigested in the feces indicating that human GI tract is not able to get the fat in some foods completely released for the same to be hydrolyzed and absorbed. There is a parallel one can find in protein utilization also and that is the reason why the terms like Biological Value, Protein Efficiency Ratio, Net Protein Utilization etc have been coined to reflect the extent of protein used from a food by the body. Similarly Glycemic Index values are useful in understanding the efficiency of carbohydrate utilization in human body though this parameter has more relevance to diabetic people with insulin insufficiency. 

While person to person variability, depending on many factors, is understandable, what complicates the issue is the nature of food consumed and the physical properties of the same. It is just common sense that food components in aqueous solutions are readily digested and absorbed fat, the process takes longer time and becomes more and more inefficient as the food eaten is under cooked or under processed putting more burden on the system. Food industry of modern days excel in making the product more and more GI tract riendly through the technologies used to process foods, most of them into ready to eat condition. Ultra mills, emulsifiers, homogenizers, grinders, extrusion cookers, pre-cookers, etc which are extensively used by the industry make the food readily digestible in double quick time. 

Monday, September 3, 2012


All India Food Processors' Association (AIFPA) based in Delhi is supposed to be an anchor point for pleading cases for the food industry by acting as an interface between the government agencies and the manufacturers. As its representative character is very wide, what it says has some relevance and its views are heard by the government though the response has always been one of ignoring their feelings during the time of taking decisions. This government shows same attitude to technical organizations like Association of Food Scientists and Technologists (AFST[I]) which is the largest body in Asia, representing thousands of scientists and engineers with experience in various facets of food processing and packaging. Still these bodies have a remarkable reservoir of patience and perseverance in pursuing matters of interest to the industry. 

The newly anointed Food Laws in the country are supposed to safeguard the health of the citizens in the country without unduly harming the operational atmosphere of the processing community and a balanced approach is always preferred in all countries. Under the pretext of integrating diverse rules and regulations that controlled and monitored different sectors of food industry under various ministries which were in vogue till recently, a monolithic body was set up under the exalted banner of Food Safety and Standards Authority of India (FSSAI), predominated by die-hard bureaucrats with no knowledge of the dynamics and technical complexities of the food industry and a set of rules and regulations were promulgated after an "exhaustive" planning of more than 6 years. Unfortunately this agency has only "Authority" to promulgate laws but no teeth to enforce the standards as the State governments only have the necessary infrastructure to operate in their areas. The result is that a "free for all" condition has been created with adulterators and fraudsters having a field day with no restraint on their nefarious activities. The judicial bodies in the country are passing stay orders in different parts of the country because of the badly drafted laws by the FSSAI.

Interestingly the "Babus" in FSSAI, used to wielding indiscriminate power, is passing orders, one after the other, many not in tune with the laws approved by the parliament which are considered injurious to the interests of the small scale food handlers and industry. Here is a typical example of its latest heavy handedness which deserves to be condemned in no uncertain terms, as pointed out by AIFPA in their letter to the government..  
-Sub-section (3) of Section-31 of FSS Act-2006 states that the prescribed fee is to be paid along with the application for grant of license. In pursuance to this, Schedule 3 under Regulation 2.1.3 of FSS (Licensing and Registration of Food Businesses) Regulations-2011 stipulates the fee to be charged for Registration/ License for new or renewal.

-Sub-section (4) of Section-22 of FSS Act-2006 regarding Proprietary/Novel Foods does not stipulate any fee for obtaining license for Proprietary/Novel Foods. More so, no-where in the entire Section-22 on "Genetically Modified Foods, Organic Foods, Functional Foods, Proprietary Foods, etc.", there is any stipulation for charging/ payment of any fee for such type of foods. As such, the action of charging fee of INR 25000 for 'New Product/Ingredient Approval' is not justified and may please be immediately withdrawn.

- Perusal of Section-16 of FSS Act-2006 regarding "Duties and Functions of Food Authority"does not mention anywhere a provision under Section-16 of FSS Act-2006 or elsewhere in the Act of having given any authority to the Food Authority to impose any such fee as is being demanded now for 'New Product/Ingredient Approval'.

- Clause (o) of Subsection (2) of Section-92 of FSS Act- 2006 regarding "Power of Food Authority to make regulations" stipulates charging of fee, while making application for obtaining license only. No-where under these provisions, the Food Authority has been empowered to impose such fee of INR 25,000 for 'New Product/Ingredient Approval'. 

- Regulation 2.12 of the FSS (Food Products Standards and Food Additives) Regulations-2011 regarding Proprietary Foods does not also stipulate any such fee for 'New Product/Ingredient Approval'.  Even under Section-37-A of the repealed PFA Act-1955 and Regulations made there under, there was no stipulation for charging any fee for 'New Product/Ingredient Approval' in the past.

 -Where in any of the provisions of FSS Act-2006, there is any expressed or implied provision that the Food Authority can charge any type of fee from Food Businesses / Food- Business-Operators for 'New Product / Ingredient Approval' except License/Registration Fee.

- Charging of non-refundable fee of INR 25,000 along with application for 'New Product/Ingredient Approval' and an additional amount of INR 25,000 in the case of products falling under the "Category-B" involving risk assessment and establishment of its safety violates the very provisions mentioned under Section-18 regarding "General Principles of Food Safety" of Chapter-III of FSS Act-2006.

-Charging of INR 25,000 for 'New Product / Ingredient Approval' will kill innovation in the food sector and FBOs will not be able to bring out processed food products of high quality and safety both for domestic and international markets.

-Charging of such high fee will also put financial burden on micro, small and medium enterprises, intending to introduce new products in the market. For example, a very experienced Petty-Food-Business-Operator of having developed a new recipe will not be in a position to pay one time fee of INR 25,000 plus INR 25,000 in the case of products falling under the "Category-B", due to his financial position. Therefore, an Advisory on 'New Product / Ingredient Approval' is counter-productive to the concept of fast growth and development of Food Processing Sector in the country and must be withdrawn immediately.

The above piece is quoted from a "pleading" letter to FSSAI by AIFPAI imploring the "Authority" to stop such punishing steps which can only destroy the industry. Already India is a country which does not invest much money on food research and most of the technologies operating in the country are foreign originating, heavily mechanized and automated and to which small entrepreneurs have no access. The morbid public funded R & D bodies do not count much in providing much succor to the technology hungry micro and small scale enterprises in the country as they have scientists, especially the leaders, considered "square pegs in round holes" with very little insight into the working of food industry and inappropriate background to develop what is needed by the industry.

Is it not a tragedy of Himalayan proportion that the food sector is being suffocated from both sides, government as well as the scientific agencies, not encouraging to develop new industries? What logic one can use to charge exorbitant license fees and irrational fiscal impositions on the industry, especially the domestic ones which are more and more being sidelined by giant foreign players with strong financial muscle and wide international resources? Look at the domestic research scenario and how can the public funded R & D think of patenting their processes expecting huge financial gains, making it beyond the reach of thousands of small enterprises which find the dice heavily loaded against them? Whether it is CFTRI, DFRL or NDRI the prevalent system encourages these agencies to be highly secretive and put high price tags on their laboratory based processes! Unless there is a total overhaul of domestic R & D organizations with proven industry oriented food experts heading them and governments at both State and Central levels declare a moratorium on taxing food products, India is destined to become a "free for all" anarchic country with every multinational company including the Chinese capturing the market, sending most of the present indigenous players into oblivion!