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CERTIFICATION OF ORGANIC/NATURAL FARMING PRODUCE IN INDIA

When it comes to organic produce supply chains, an issue that one is often confronted with is
that of “quality assurance” - of whether something that is being claimed to be from organic or
natural farming is indeed organic. While this is so when it comes to raw produce, in ultra-
processed foods with multiple ingredients, the matter becomes more complex, to check whether
all ingredients used are organic or not. This issue becomes complex when the supply chain
becomes longer too. Moreover, the entry of online organic platforms where producers and
consumers get distanced by a virtual world in between, is adding to the already complex
situation. That is where “certification regimes” come into the picture, to provide quality
assurance to those seeking a guarantee or vouching of the authenticity of the organic/naturally-
produced product. As can be seen, this is the need of the consumer, and not really the need of
the genuine organic/natural producer. But since the market demands it, producers are also
compelled to seek certification of their farming practices.

Worldover, the organic farming movement realised long ago that when the ecological farming
paradigm is adopted, what needs to be certified is not the product produced, but the practices
adopted and inputs used (there could be instances when a farmer is fully organic, but
contamination with residues can happen through runoff from neighbors etc.; on the other hand,
even chemical farming can be passed off as organic if pesticide residues are below detectable
levels). Therefore, certification regimes centre around farming, and not the end product in a
super-market shelf. However, to doubly be sure about the output too, certification regimes also
combine some testing measures of the product too. All of this is both good and bad, for the
farmer who is trying to make the shift to an ecological paradigm.

Moreover, the certification regimes that have been evolved and deployed have their own
shortcomings, and while they might meet the consumer requirements to an extent, have started
posing various issues to farmers who would like to shift to organic farming or continue in the
ecological farming paradigm. In this Discussion Note, we would like to pen down the key issues
with regard to certification regimes from the consumers’ end as well as from the farmers’ end,
and see if win-win solutions are possible.

From the consumer end:

● It is not always possible to know the farmers from where one is sourcing one’s food
from, and therefore, having to rely on some quality assurance system becomes necessary.
● However, most consumers are not aware of what the certification regimes are all about -
who and how are the certification bodies certifying or vouching for is not known to the
consumer. There is a blind belief that certified organic products must be truly organic. However,
this has been belied time and again, for a variety of reasons. This Discussion Note is not going
into the details of which aspects of the current certification regimes are deficient, leaving scope
for cheating in the name of organic.

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This is a Discussion Note created for the 5th Kisan Swaraj Sammelan in Mysuru during Nov.11-13, 2022. For any
queries, or more information, you can write to asha.kisanswaraj@gmail.com
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● Consumers are also not aware of the fact that certified organic produce also means
more expensive pricing, because the price is passed on to the end consumer, of new players
(certification bodies) who are not there in ‘conventional’/chemically produced supply chains.
● It is important for consumers to know that ‘certification’ of the current kind may not be the
only kind of quality assurance system that they are seeking, and that there could be other ways
by which systems that can guarantee authenticity can be evolved and strengthened.

From the ecological farmer end

● A certified farmer does get more/easier opportunities for marketing.
● However, as the ecological farming paradigms are being scaled up rapidly, no affordable
or free, accessible and simple systems have been put in place for those farmers who are
actually helping the environment, consumer and even the government, through shift to agro-
ecology. In fact, they are being penalised by making certification mandatory for any organic food
being sold in the market, with a few meaningless exemptions put in.
● It is important to note that while a well-meaning organic farming is being mandated to
prove herself or himself in terms of the practices adopted, those who are using poisonous
products in our food systems are getting away with lax regulations that do not require them to
label their products for the toxic residues contained therein etc.
● The alternative to the expensive, onerous and external-party driven third party
certification system was thought to be the Participatory Guarantee System (PGS) of small
groups of grassroots, practising farmers, who act as peer-to-peer guarantee for each other,
even as the farmers in a group get collective support of each other for various aspects of their
farming. However, in practice, this PGS system is not equipped to run on its own without
external, sensitive facilitators. It is also being seen that players being accredited or recognised
as legitimate parties in the PGS regime are in fact those that are part of the third party
certification regimes. Further, given that PGS works as a group-based system (like in the case
of women’s SHGs where members stand as collateral or guarantee for each other), motivated
individual organic farmers, dispersed geographically here and there, are not able to use the
PGS system of certification.
● It is worth remembering that in vast tracts of India, where adivasi farmers do not use
synthetic chemicals in their farming and mostly follow traditional practices, certification regimes
do not mean much; however, these farmers are also organic! At the macro level too, India’s
organic market is estimated to be equal in terms of certified organic and uncertified organic.

Government of India’s Regulations & Latest Developments

In India, the third party certification regime called the NPOP regime (National Program on
Organic Production) was set up by the Ministry of Commerce several decades ago, mainly
keeping export markets in mind. This regime was visualised as a voluntary certification system
of organic operators desirous of proving their credibility in the market, and to comply with
standards in other countries. This, like any other certification regime, consists of its own
Standards, institutional structures, and processes for certification. This system is expensive,
inaccessible to many smallholder organic farmers in many regions of the country, onerous in
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This is a Discussion Note created for the 5th Kisan Swaraj Sammelan in Mysuru during Nov.11-13, 2022. For any
queries, or more information, you can write to asha.kisanswaraj@gmail.com
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terms of the data and online traceability systems it imposes, opaque in terms of not sharing the
information of the farmers in the public domain. The accredited agencies are limited in number,
and like any other market service provider, most agencies get very choosy about who they will
provide their service to and where.

Due to civil society efforts of networks like Organic Farming Association of India (OFAI), an
alternative to the third party regime evolved in the 1990s called the Participatory Guarantee
System (PGS) where groups of farmers were to stand surety for each other. Government of
India adopted this system and PGS-India slowly became the certification regime of the Ministry
of Agriculture, Government of India. However, while the initial civil society effort called PGS-OC
(PGS Organic Council) continues to cater to one relatively small group of farmers, the PGS-
India system tried to scale up dramatically at one point of time, and met with numerous
problems. This regime is constantly undergoing numerous changes, and presents its own
design and implementation issues to organic farmers of the country.

In 2017, a regulatory body entered the picture - the Food Safety & Standards Authority of India
(FSSAI). While it is not clear how FSSAI has cracked down on toxic chemical residues that end
up in our food chain, it chose to notify statutory regulations under the Food Safety & Standards
Act 2006 that make certification mandatory for any organic food to be sold in the market, with
some minor exemptions that do not mean much for most organic farmers of India. Importantly,
ASHA states that this is ultra vires the FSS Act 2006, where Sec.18(3) explicitly excludes
farmers and farming operations from the purview of the Act, whereas certification regimes which
have been made mandatory by FSSAI are about ‘farmers, farming operations, supplies used
and products of crops’.

A more recent development (2022) is that the Ministry of Agriculture, Government of India, for
reasons that are unclear, has evolved separate certification regimes, including separate
standards, for produce from natural farming (NFCS). This could confuse ordinary consumers to
an extent, not understanding what is the difference between organic and natural farming
produce. As far as the consumer is concerned, both products are similar, while in the
government’s conception, natural farming farmers will not purchase any bio-inputs from outside.

What is a good framework that evolves win-win solutions for Farmers and Consumers

● Backward traceability systems (not farmer-upwards which once again makes the system
onerous for the producer) at every point of the supply chain, along with transparency, will
ensure that dubious players do not enter the market too easily in the name of organic or
natural produce.

● As a consumer, attempting to know your farmer and be as close to your producers as

possible, will give you the best guarantee of authenticity. As a consumer, you will also need a
diversity of commodities and therefore, opting for CSA models (community supported
agriculture which should ideally involve groups of consumers working as a community, to
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This is a Discussion Note created for the 5th Kisan Swaraj Sammelan in Mysuru during Nov.11-13, 2022. For any
queries, or more information, you can write to asha.kisanswaraj@gmail.com
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support a group of producers) and helping farmer groups to diversify adequately, will be a
great win-win. For you and the farmer. But also for the environment, with monocropping
avoided by the farmers, with the farmers’ group having to collectivise and work together for
production end planning and execution. While CSA models in their true sense are not always
easy to establish, requiring both producers and consumers to walk an extra mile (with the
need for a sensitive facilitator or promoter agency also to begin with), farmers’ direct markets
of organic/natural produce and one-step-away small retail outlets are quite possible, to have
trust-based quality assurance systems that can do away with any certification needs.

● Like groups of farmers developing their own PGS, groups of consumers can choose to
verify, and build relationships with particular sets of farmers and stand guarantee for them.
This can be the Consumer Guarantee System of Organic/Natural Farming Producers. This
requires a more pro-active consumer behaviour, for the sake of themselves, their next
generations, the annadaatas who are trying to shift to alternatives and the environment.

● Large Area Certification will be economical and will also bring local-eco-system level
benefits for all farmers operating within a geographical unit with a shift to sustainable farming.
This will require appropriate and adequate investments to change the production systems
towards agro-ecological farming. Large scale collusion and cheating by farmers is not
possible, and peer pressure from many others who want to take advantage of the large area
declaration will keep away any unethical elements. This would also make regulation of
chemical inputs easier for local administration, and keep sales of such inputs out.

● Easy and affordable testing facilities that consumers can utilise to call out the deceitful
players in the market will bring down cheating in the organic market to an extent. This will in
itself be a deterrent on both farmers and traders passing off inorganic produce as organic. It is
worth knowing that India’s Food Safety and Standards Act 2006 contains a provision under
Sec.40 where a “purchaser may have food analysed” on the payment of a fee and on
following the laid-down procedure, and if the tested product is found to be in contravention of
the statutory provisions, the fee will be refunded. In fact, more and more citizens should get
various food articles tested, and not just organic products, so that food residue standards are
complied with by all.

● Doing away with, or Realising that Premium Organic Markets cannot and should not
exist for all time to come: It appears that consumers’ indignation about cheating in the organic
markets is higher because they also end up paying a premium price for organic produce,
assuming that they are getting a higher quality product. On the other hand, it is also this
premium price in the organic markets that attracts the dubious players too. Further, for those
of us who would like to see ecological farming spreading to more and more farmers, it is
apparent that premium price-based niche markets will not exist, and should not exist if our
vision has to be realised. In such a context, focusing on organic/natural farming for reasons
other than premium markets is a good way forward, in all our promotional efforts. At another
level, all food and good quality food at that, should not continue to be under-priced - this is an
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This is a Discussion Note created for the 5th Kisan Swaraj Sammelan in Mysuru during Nov.11-13, 2022. For any
queries, or more information, you can write to asha.kisanswaraj@gmail.com
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unhealthy factor affecting sustainability in our food systems, with desperate farmers resorting
to more and more unsustainable practices for their very survival.

What needs to be done now

1. ASHA-Kisan Swaraj Network has been demanding from the Food Safety & Standards
Authority of India (FSSAI) that mandatory certification on all organic food be stopped.
This has to be done at least until multiple quality assurance systems are put in place that
truly support more and more farmers to shift to organic and natural farming. ASHA has
even proposed product-based standards and compliance verification systems that
FSSAI can itself adopt, rather than fall back on existing farm-based certification
standards which have been created as voluntary systems.
2. ASHA has also been proposing that diverse, localised quality assurance systems should
be put into place, recognised and supported.
3. Large scale testing has to be put into place where empowered consumers will clean up
the market, by calling out and moving away from unscrupulous players.
4. Regimes to support organic/natural farmers to obtain Payment for Eco-System Services
for their contributions to ecosystems need to be instituted. They can be based on a
scoring and grading system, and can have numerous verification mechanisms in place
for farmers opting for such regimes. When there is a large scale shift of farmers into
PES-based incentive models, the issues with current certification regimes which are
based mainly on the narrow needs of consumers, will get subsumed and addressed. In
these PES systems which cannot be rigged too easily, the possibility of cheating by
farmers or traders in the name of organic would come down.

Ultimately, both farmers and consumers should realise that the shift to organic/natural farming is
not just about the health of the consumer or the viability for the farmer in her/his occupation. It is
about the regeneration of natural resources. It is about future generations finding a chance on
this planet. Therefore, it is important that we evolve win-win solutions which do exist!

Reading materials:

1. Kisan Swaraj | Blog | Tags | Organic-standards

2. Kisan Swaraj | Blog | FSSAI receives letter on concerns with regard to its organic food
regulations and implications for uncertified organic farmers

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This is a Discussion Note created for the 5th Kisan Swaraj Sammelan in Mysuru during Nov.11-13, 2022. For any
queries, or more information, you can write to asha.kisanswaraj@gmail.com