Devil is in the rules and God is in the implementation

India is today a galloping consumer society. We eat brands, drink brands and partake of everything literally through the pathway of packaging.

Brands depend heavily on packaging both for the functional and cosmetic needs of the brand in hand.

When you hold a bottle of Coke, the brand is all of the name, the colour red on the packaging, the dark brown colour of the drink, and most certainly the tactile feel of the bottle in hand.

This comes in different formats today for sure. There is the can and the PET bottle to boot. Brands, however, transition the cosmetics rather seamlessly across all formats of packaging, as they adopt them on the way.

Packaging is, however, not the cosmetics alone. It is all about the cost of packaging. Equally important is the functional value that packaging adds or depletes from branded offerings. 

A liquid for instance has the need to be packed at a particular temperature, cooled at a different temperature, and transported at temperatures that vary, unless in a cold chain.

And finally, once again at the point of retail, a bottle of soft drink, or a tetrapak of milk will go through a temperature that is different.

The liquid so packed will need to have the ability to preserve its originality, quality and purity right through this chain from factory to the consumer’s gullet. And packaging is meant to ensure that.

The proposed set of FSSAI rules for packaging are therefore welcome initiatives that will have the industry that packs, the industry that manufactures and equally the industry that transports it all, sit up and take note. 

While the organised sector of industry is by and large conformant, the new rules have the ability to shake up many a local player who somehow has compromised on packaging at the altar of cost.

While the organised sector will now grapple at the top end of the pyramid of packaging with ideas such as green packaging, clean packaging and zero footprint packaging, the middle and bottom end of the market in India for FMCG will, for a start, need to get its act right on the basics.

The FSSAI rules, therefore, set the ground rules for all, with the idea of the basic health of people at hand as the cornerstone comfort point to address.

The new rules will therefore aim to get the packaging act right across the terrain of packaging, preparation, storage, wrapping, transportation, sale and service of food and beverage products.

And this means deeper scrutiny on the material used for a start. Whether you are a user of paper and board, glass, metal or metal alloys, plastic, metalised polyester poly, PVC, PE, PET or PP, you will need to stand up and take note of both specification in use and the key issue of consumable product interface with the packaging that carries it.

Is packaging adding stuff to your food and beverage it must not? How neutral is packaging to the product? Is packaging the real enemy of the modern day consumptive classes? And must we be more watchful about it?

The FSSAI rules are therefore clear in intent and will see their merit not in their proclamation, but in the deep and wide manner in which it can be implemented in the great Indian market place for packaged products.

The ability of FSSAI to get the biggies in the business to toe the line is not an ability really. The big players are the ones who toe the line first and want to always be seen as the fairest of them all.

The FSSAI challenge will be in the manner in which it can get everyone else in the market who is not a big player to toe the line.

We buy bhajiyas on the road wrapped in used newsprint. We love the way the oil gets soaked up in it as we merrily munch away at the tasty bhajiya and ink as garnish. Can this be stopped now?

And starting from the most rudimentary packing of them all, can one climb into the realm of language that defines “food grade” as packaging that does not affect food composition at all?

While assessing food grade is simple, what is much more difficult is assessing the overall migration limit, or the non-volatile substances that get released into the food or beverage packed.

Think of it this way. When you order Chinese food at home, you want it delivered hot. It comes in a polythene, packed hot as ever. Have you ever wondered what has migrated from packaging plastic to spicy hot Schezwan Chicken soup?

Assessing migration limits is therefore a task that is laboratory-related. And the task will mean that you need that many more food labs to do the task at hand. FSSAI needs to gear up on that front as well.

Packaging is in for scrutiny for sure in the years ahead. The FSSAI will kick it off with a set of rules. But then, the Devil is in the rules and God is in the implementation.

Author is founder, Harish Bijoor Consults Inc