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FOOD TESTING IMPORTED AND EXPORTED FOODS AND REGULATORY

CHALLENGES

Food testing and analy-sis is an essential part of the food safety eco-system to assure that Ihe
food is safe to consume. Fssai defines 'Unsafe food' as an article of food whose nature,
substance or quality is affected as to render it in-jurious to health. The most significant thing
for food testing is the Lab-oratories which perform the tests should be accred-ited by NABL,
FSSAI, BIS, CDSCO, ISM&H, APEDA, EIC/EIA, AGMARK etc. Procedure for import and
export activities involves en-suring licensing and compli-ance before the shipping of goods,
arranging for trans-port and warehousing after int. • .ioading of goods, cer-tificate of mod
analysis with complying to all regulations' and getting customs clear-ance as well as paying
taxes before the release of goods. Food Testing Requirements ■ Prior Trading our prod-uct in
a new market, most countries demand that products conform to na-tional and international
standards. As a result, products need to be de-signed and tested so that they can be sold in the
tar-get countries. ■ Exporters and Importers face continuous rejections in the market due to
health and food safety concerns such as violations includ-ing mislabeling, allergen products,
use of non-approved pesticides, mi-crobial contamination and manifestation of pests. ▪ M
mit- Imported food it by India fresh Veg-c s and Fruits, Fresh ies and. Cereals, Ed-ls, and
Petroleum cs. Food items it, rice, edible oils, noodles, snacks, products, and car-drinks and
juices ccted. rricultural prod-h as mangoes, ry leaves, pea-,. grapes, chil-ls, shrimps, and face
rejections stain non-com-

• All the Goods shall com-ply and be within the safe-ty limit and not violate any regulation.
Significance of Food Testing Considering current con-ditions which contain high amounts of
pesticides, heavy metals, adulterations, food frauds which costs consumers their life, food
testing has be-come mandatory. Food test-ing includes product analysis based on Chemical
analysis, Microbiological analysis, Chemical analysis and Organ-oleptic analysis . People
initially consumed food products from markets which are low grade sold at less price, but
they had no knowledge that these can be harmful, let's take an exam-ple of vegetables for
Export purpose which contain high amounts of pesticides and arc rejected and arc sold in the
lo-cal market at low price . The Food Standards sets out the requirements for the
manufacture, processing and packing of: processed foods, both own brand and custom-er-
branded, raw materials or ingredients for use by food service companies, catering companies
and/or food man-ufacturers, primary products such as fruit and vegetables. Testing is also
required for pet foods for domestic animals.

Barriers to Exports Related to Food Safety and Health Standards: ■ Rigid Import regulation
in the destination country ■ Low MRLs without any scientific justification ■ High levels of
pesticides residues ■ Low harmonized Stan-dards across countries ■ High risk diseases ■
Allergen issue Best Ex-ample : Peanuts [allergen] processing takes place on the same
equipment as well as cranberry which is [non -allergen] . All FBOS should test their food
product for safety, con-tamination or residue, and ac-curate nutrition composition.

Food Tests include : Testing for Food claims :

Health claims Nutrition claims etc., all these are to be tested initially

so that claim is verified be the Authority based on the re-ports. If a brand claims their product
is sugar free, preser-vatives free one should under-go a test of the same product . Pesticide
Residue Analysis: For agricultural products, pesticides sprayed during farming can be
harmful carcinogenic to human be-ings, if they are used be-yond threshold limit. As global
food trade and the importance of monitoring increase, the food industry and regulatory
laboratories are also considering min-iaturised high-throughput methods. Pesticide Resi-due
Analysis is a signifi-cant component to ensure human safety as pesticides control insects and
pests so as to increase crop pro-duction. Pesticide residue analysis tests are done to identify
and quantify the residues from very com-plex food matrices.

Nutritional/Focal Labelling: Nutrition labeling where proteins, carbohydrates, vi tamins, fats

NIL. TA, PLIFA, Mit:intuit mitt s tiacroatut rl. tilts Mt tested in h id Until tory minerals sit
that entain) ens arc aware 01 the quality, quantity, contents, and nature of the food. It also
provides information on the source of the food.

GMO Food Test: The cultivation of geneti-cally modified (GM) crops has increased
significantly around the world over the last decade. 'this escalation inproduction has been
combined with the synchronous and complex regulatory approval process, necessitating
testing agricultural and products for GM content to regulate international trade. GMO
(genetically modified organism) testing confirms the identity and nature of the product at
every step along the supply chain and assures com-pliance with import or labelling

rcg flied Le.dr fi cally GI iiten-Frce Pond Test: Omen is It complex pro-tein iound to wheat,
barley, rye, and toticale. For celiac disease, a },,Ititc n free diet is solelf medit all accepted
cure. If a p•rson kVIIC.11 in-tolerant, lie/she might suffer from die inflammatory skin
condin( In due to wheat ex-posure, if the person is glu-ten intolerant. Gluten-free food tests
are done to know about the amount of gluten present in food. Organic Food Testing: Organic
food should be free from synthetic chemicals and regulated with strict guide-lines. Organic
food should not only be chemical-free but should be grown without ar-tificial pesticides and
fertiliz-ers. The organic food testing helps in finding out about the presence of these
pesticides and fertilisers.

Our HSHT Heat Stable Red is a proprietary clean label solution that includes the addition of
some antioxidants to stabilise the pigmentproducing a deep Red Velvet shade. It is an
excellent solution for Cake Mixes, however the performance in Cereal is dependent on the
specific extrusion process for each manufacturer. Some processes with extreme heat or
pressure can result in browning or color degradation.
Varnacol Food Colorings Research indicates that5I% of the total population considers
colourings of Narural origin "very important" when it comes to "kid-centric" products such as
Cereals and certain sweet treats like Cookies & cakes. Consumer demand for natural colour is
a having a big impact on product formulations particularly replacement of the artificial Reds
in Baking & Dry Grocery. This conversion has been challenging for developers in the
pastdue to heat, pH & oil stability of some natural sources of Red Colourings,

Food allergen

■ Dairy Products Testing: Dairy products testing includes analysis of milk, cheese, other
dairy products, as well as products containing ingredients derived from milk, cheese, and
other dairy prod-ucts. These tests arc done to determine ash, alkalinity, dis-pensability, fat,
milk fat, lac-tose, milk solids, non — fatty substances, moisture, min-erals, microbiological
tests, protein by Kicklahl method, combustion, solids (total) in milk, titratable acidity and vi-
tamins.

Food Allergen testing: Food allergens are naturally proteins in food or their de-rivatives
causing abnormal immune response. Every product is first tested for po-tential allergen in the
ingredi-ent of the final product. Al-lergic components commonly found in food products in-
clude gluten, eggs, peanuts, nuts, soybeans and milk. Vis-ible labels with warning about the
potential allergic contents should be printed on packag-ing. Food related .allergies are
something that stays life long. So, it is important for food manufacturers to conduct regular
tests for potential al-lergens that may contaminate their products. Sensory Testing: • The
identification of a food product by human senses (sight, smell, touch, hearing and taste) is
used for evalu-ating consumer products. Special taste assessors are ap-pointed to test the taste
of the finished food product in industries. This can be seen through: ■ Sight- for determining
color of a food product ■ Smell-for detecting pres-ence of rancidity in food ■ Taste-for
testing flavor of a food product ■ Touch-for checking the texture of any food com-modit► ■
Hearing- e.g. Crunchiness of potato chips Under the EIA Export Act for Agricultural and
Pro-cessed Food Products, Gov-ernment of India has found-ed a common authority that
approves any food item be-fore extorting outside India. Shipments of products such as
basmati rice and ground-nuts get contaminated with aflatoxins due to poor stor-age, poor
transportation con-ditions, unhygienic conditions and limited pack houses. ■ The Agricultural
and Pro-

cessed Food Products Export Development Authority (APEDA) per-forms all the duties to
ensure that no unreliable food product is exported to any other country from India. It also
checks for scheduled products in-eluding meat and poultry products, dairy products, bakery
products, alcoholic and non-alcoholic bever-ages, cereal products, nuts, floriculture products,
me-dicinal plants etc. ■ It has been advised by the APEDA that all the ex-porters registered
under it should get a Flealth certif-icate issued for export of their food products. Health
certificate (issued by EIC/EIA) is a single sheet document, duly signed and dated. Original
health certificate is required during custom clearance proceedings at the destination place.
Any consignment with a photocopy or fax copy of the original certificate will not clear
custom formali-ties without presenting the original copy of the cer-tificate. ■ In India, the
Export In-spection Council (EIC) is the competent authority recognised by the Euro-pean
Commission to ver-ify and certify Fishery and Aquaculture products. For shipping of food
products a shipping bill/bill of ex-ports has to be issued by the Custom Authority. Some of
the challenges rele-vant in Food Industry include 1. Regulatory Require-ments going
Stringent Regulatory part is the heart of the Food industry to ensure food being delivered is
safe, le-gal. Maintaining food regulato-ry practices allow importers and exporters manage
risk associ-ated with everyday procedures. Regulations to ensure Finished Goods used only
approved ad-ditives for example :Improvers, emulsifying agents-stabilising agents single or
in combination, acidity regulators . Addition of all these should be as Approved GMPList.

Aspects involved in food regulatory landscape in-clude: ■ Good manufacturing practices and
plant hy-giene prerequisite pro-grams ■ Hazard Analysis critical control points

Careful monitoring

■ FSMA ■ Food labeling ■ Food Defense

2. Supply chain - supply of resources With globalisation, the supply chain must be carefully
moni-tored to ensure imports meet food safety regulations and are free from tampering. To
get re-sources from approved vendors which have specifications similar to the existing
product .There are also issues due to seasonal varia-tion in crop lead* to changes in product,
competition amongst units to buy raw material, non-availability of raw material, poor quality
of raw material . 3. Expensive raw ingre-dients: Rising prices of flour (maida), the major
ingredient, and other raw materials oils, fats, eggs etc. 4. The price-sensitivity of the market
5. Lack of Brand Goodwill Another marketing problem which the units have reported to be
facing is the lack of brand goodwill. It implies that their product brand has not received

much public acceptance. It re-veals that 52 per cent of food processing industries as a whole
are facing this problem. 6. Inadequate Publicity through Mass Media Mass media expo-sure
is an essential ingredient for the smooth growth of an indus-try It helps entrepreneurs to plan
their activities in accordance with market trends, introduce goods to suit consumers' tastes
and get consumers informed of their product through advertising. To overcome the challenge
of rising production costs, many national and international com-panies have come forward
with solutions to reduce the produc-tion costs by offering on-site trial demonstrations, which
would reduce the percentage of gluten, fat, eggs and oil used in the recipe. Above all these it
should be Qual-ity over Quantity always Quality of product and time by delivery of the
product to customers is the key fac-tor to run continuously in any food industry
Serious gaps in ratio of food testing labs to FBOs: experts

Ashwanl Maindola, New Delhi

Food Safety and Standards Authority of India (FSSA I) has in the last _flew years put up
serious ("flow, in terms of food testing labs availability. However, experts feel that despite its
rigorous efforts, the Covid-19 pandemic has shown that ibod testing labo-ratories in India
have faced major challenges in the domains of man-power availability, equip-ment and
machinery, skill development, R&D (research and develop-ment), customer aware-ness as
well as capacity utilisation. It has also come to light that there have been seri-ous gaps in the
ratio of labs to the FBOs in the country. Moreover, due to chemical testing be-ing less
capital-intensive than pesticide residue and microbiological test-ing, many labs possessed
only the former infra-structure. Industry insiders feel that they must work towards increasing
the abilities of these labs and fill the gaps. Recently the Parlia-mentary Standing Com-mittee
on Health had also made several recom-mendations with respect to the FSSAI. On the
Committee's recommen-dations for a fully Cen-trally Sponsored Scheme for upgrading
manpow-er, strengthening infra-structure and robust sur-veillance systems at the state level,
FSSAI in its response has stated that it is implementing a Cen-tral Sector Scheme for
strengthening of food testing laboratories and upgrading manpower. FSSAI is incorporating a
Central Sector Scheme for Strengthening of Food Testing Ecosystem with a total expense of
Rs 481.95 crore. This in-cludes Rs 300 crore for building up a network of laboratories across
the nation as well as provi-sion of mobile food test-ing labs and other related equipment.

Under this scheme, 39 state food testing labs of 29 states/ UTs & 10 referral labs have been
bolstered with high-end equipment in order to enable efficient testing of safety pa-

rameters esticides, heavy metals and antibiotics). Till now, 60 mobile food labs have been
provided to 32 states/ UTs for training, testing and awareness generation even in

remote areas. Amidst the Cov-id-19 pandemic, a total of 179 online training programmes
with 37,000 participants have been conducted. Ashwin Bhadri, CEO, Equi-

nox Lab, stated that a core area of enhancing the food safety infrastructure involves
strengthening food testing laboratories for better func-tioning across stages.