Fixing Assam tea’s pesticide testing bottlenecks

The draft amendments notified by the Food Safety and Standards Authority of India (FSSAI), proposing Maximum Residue Limits (MRLs) for two pesticides, acetamiprid and imidacloprid, in tea, have triggered fresh hopes for Small Tea Growers (STGs) in Assam and the rest of India, as their green leaf batches will no longer be flagged as adulterated due to the easing of the acceptable limits for these two pesticides. FSSAI’s proposed ceilings of MRLs of 20 mg/kg (20 ppm) for acetamiprid and 50 mg/kg (50 ppm) for imidacloprid in tea have brought more regulatory clarity to compliance and testing of samples of green leaf supplied by STGs to Bought Leaf Tea Factories (BLFs). Currently, if a testing laboratory detects the presence of 0.01 ppm traces of these two pesticides, the sample is flagged as unsafe or non-compliant. Rejection of samples of made tea due to the presence of 0.01 ppm of acetamiprid or imidacloprid in tea compelled BLFs to stop procurement of green leaf supplied by STGs if batches are not accompanied by laboratory certification on compliance with 0.01 ppm MRL ceilings for these two pesticides. The BLF association had moved the government that even though the Central Insecticides Board & Registration Committee formally approved and registered the two pesticides for crop safety, the FSSAI failed to notify the matching compliance norm, which led to the enforcement of the zero-tolerance norm or 0.01 ppm ceiling. The new ceilings proposed by the FSSAI for the safety of consumer health are expected to bring an end to the crisis triggered by such regulatory ambiguity and ease the tension between BLFs and STGs over the rejection of green leaves due to non-compliance with the zero-tolerance norm. A robust laboratory testing ecosystem is essential for the effective enforcement of the new ceilings. Ironically, even though Assam accounts for more than half of India’s total tea production and has over 1.5 lakh STGs, the state still lacks the necessary number of laboratories to support this level of production and the increase in small tea cultivation. As BLFs mix green leaves supplied by different STGs, the presence of pesticide residues higher than the limits prescribed by FSSAI in any batch supplied by a single STG increases the risk of rejection of the entire lot during auction. Since green leaf is a perishable commodity, long delays in obtaining laboratory certification make it difficult for small growers to comply with safety standards without losing their harvest. The STGs lose bargaining power and often resort to distress selling at prices arbitrarily fixed by factories. The lack of traceability regarding pesticide use by specific green leaf suppliers means that when supplies from a large pool of small tea growers (STGs) are mixed and processed to manufacture black tea, any sample found to contain pesticide residues often leads BLF to reject all green leaf from that group of growers. Even supplies from small growers who have not used any prohibited pesticides are rejected, creating a spiralling economic crisis for STGs. If the state does not address the issue of inadequate testing facilities, this problem will continue. As STGs account for nearly 50% of total tea production in Assam and are the backbone of the tea industry in the state, the persistence of financial distress gripping the small growers and the resulting rural livelihood crisis could drag the 200-year-old tea industry into a deep economic and operational abyss. This situation calls for the expedited establishment of new laboratories in major tea-growing districts and the strengthening of mobile testing facilities throughout the state. The central government claims that the proposed MRL of 20 ppm for acetamiprid in tea is lower than the corresponding limits of 30 ppm in Japan and 50 ppm in the United States of America, and the proposed limit of 50 ppm for imidacloprid aligns with the international Codex standards; however, it is not to impact much in the export of Assam tea to the European Union. The EU strictly enforces a 0.05 ppm residue limit for both these pesticides. As Assam accounts for nearly 75% to 85% of total tea exports to the EU and United Kingdom combined, the export-quality tea produced in the state will invariably be required to adhere to this strict residue limit to avoid rejection of export consignments. As health-conscious consumers prioritise safer food products over cost advantages, the enforcement of food safety standards has also gained prominence in the country. Once FSSAI accepts the proposed MRLs for final notification, the top food safety authority is expected to enforce the prescribed limits. The FSSAI move to bridge the regulatory gap is laudable and timely. Wide publicity for the draft notification will facilitate informed participation of all stakeholders in the tea industry, including STGs, in submitting their suggestions, feedback and comments on MRL regulations. The state is establishing strong and cost-effective testing facilities throughout the tea belts, which is a pressing necessity.