In India, the smart protein sector has grown at an exponential rate over the last 2 years. In the midst of a pandemic that ravaged the country, it became evident that we need a more secure and sustainable protein supply.
At this year’s Smart Protein Summit, GFI had a single-minded focus on accelerating the momentum, forging collaborations, and leaving no stone unturned in the way of making Smart Protein a key pillar of India’s new green economy.
On the second day of the summit, GFI hosted a panel discussion on the topic “Regulatory Path to Market: An enabling environment for transformative innovation”. The panel discussion was aimed at having a back-and-forth on how the regulatory ecosystem in India can play a pivotal role in enhancing the ease of doing business in new innovations and shaping consumer perception about smart protein products - particularly in new and emerging categories.
The panel discussion witnessed valuable inputs from eminent dignitaries like Dr. Jasvir Singh, Lead - Regulatory, Scientific & Government Affairs, IFF, Vikram Jeet Singh, partner, BTG Legal, and Abhinav Singh, head of FICCI Food Processing Division & Confederation of Indian Food Trade & Industry (CIFTI-FICCI). The discussion was moderated by Astha Gaur, GFI India.
Evolution of the policy and regulatory framework
Dr. Jasvir Singh, Lead - Regulatory, Scientific & Government Affairs, IFF said, “One thing that we need to understand is that the regulations also have a life cycle. They go from the starting point to a phase where they mature and then ultimately, they lead to where the understanding of all those regulations becomes the same across stakeholders. This sector is at a very basic state; hence, you do find a lot of variations and the maturity level of regulations across geographies. There are countries that are still discussing how to evaluate these aspects related to safety communication, and there are countries which are in between these two extremes.”
Regarding the basic framework, he said that the challenge is coming from the newer areas of scientific development such as cultivated meat which are products or materials not present in the food supply chain in many countries so far. Those regulators need to understand the various challenges associated with it and will need time to do that.
Legal framework for plant-based foods
Sharing his thoughts on the legal framework for plant-based foods, Vikram Jeet Singh, partner, BTG Legal said, “The nuance with plant-based meat substitute is that it's not defined regulatorily. And it's something that you have to test out in the market. For novel foods or non-specified foods, you have to go to the government to get approval every single time, the idea being that is that these are not food items that are regularly consumed by humans.”
He also shed light on the fact that after 2015, the government has come up with the 2017 non-specified food regulations that require the companies to share details like what they want to market, how they want to market, the benefits associated with it and if the food is allowed in other countries.
Simplifying the path to market for smart protein products
FICCI and GFI India will be setting up a center for excellence for simplifying the path to market for smart protein products. Elaborating on this, Abhinav Singh, Head of FICCI Food Processing Division & Co nfederation of Indian Food Trade & Industry (CIFTI-FICCI) said, “The center of excellence will act as a nodal framework with all the information required. Anyone can access it, anyone can reach out to the secretary and it will be reported. As we move forward, I'm hopeful that we will have more new arenas, more ways to support the sector under the center for excellence.”
The center for excellence will be the next logical step to advance the smart building sector in India to relationship-building discussions, and knowledge exchange, to advance the policy and regulatory boundaries.
Addressing challenges to the Indian regulatory framework
With technological advancements happening every day, the regulations involved in the smart protein sector will have to be dynamic, adaptive, and collaborative. Dr. Jasvir Singh said, “Harmonization is one word that the Indian regulators need to keep in mind to benefit the Indian regulatory framework. The other area is looking at principles because there are variations from country to country in terms of consumer understanding and maturity of society and society is an important stakeholder in this whole regulatory framework.”
He added, “The outcome that we expect from regulation should be clear before we set it up. The regulation should be clear, simple, and predictable. When I say predictable, it means that I should be having confidence that if I generate this data, the regulator is going to approve my product. The processes and outcome should be predictable if the input is right.”
He further talked about the need for companies to have clarity about their product with respect to the category it falls in and how they have to ensure compliance. He informed the audience about predictable risk assessment and its two aspects which are scientific and local-level exposure. Explaining these, he said, “The scientific aspects are where we look at whether the material is safe or not safe and those are well-established scientific principles. The other is your local level exposure to material of the population in cases where you take a calculated view of what kind of exposure should be. The scientific part can be well harmonized across the country because you will have variations in size settings. And I think with that, at least broadly, we will have a framework which enables a sector to grow at the same time, it ensures safety for the consumer.”
Importance of appropriate labeling in building consumer confidence
Labeling plays a very important part in theory and in effectively communicating the primary characteristics of the products to the consumer. Giving his opinion on the role of labeling smart protein products, Vikram Jeet Singh said that labeling is important so that the consumer knows what he is buying. He added, “I think labeling is one area in which one size fits all will not apply. You have to look at national and regional variations because what might work for one part of India might not work for the other. This is an area in which you cannot just legislate and prescribe a certain set of standards.”
Risk assessment and management
Talking about the importance of risk assessment and management with respect to smart proteins, Dr. Jasvir Singh said, “We require capability around risk assessment and choosing the right risk management option. This is where we still need to work a lot and probably GFI can anchor that sort of discussion going forward and build a broad level of understanding and support from various stakeholders whether it is from the industry or from the regulatory authorities or from the government bodies. We need to have national-level risk assessment centers whose output or scientific opinions are respected by everybody because of the credibility of those scientific opinions.”
Collaborating to build industry capacity
Dr. Jasvir Singh said that in order to build industry capacity within this growing sector to navigate effectively, collaboration is the key. According to him, collaboration both as a group with each other to build everybody's capacities and with regulators to share the pain points and reality would go a long way in bringing everybody to the same level of understanding.
He added, “The regulators depend a lot on the scientific panel. Members of the scientific panels or employees come from US academic institutions. Their engagement with the industry is extremely limited. So, it's our responsibility that we engage with the outside world, and educate them on what we do, and what are the best practices that we follow, so that they also get that degree of confidence in believing when we say that we sell safe products.”
The session concluded with a closing remark from Astha Gaur, GFI India, “People have clearly indicated that they want smart protein products and based on that, to act on the regulatory pathways and to collaboratively work towards that, the time is now. We have this incredible opportunity to model this industry, keeping consumer safety in mind, and ensuring that the regulations are well-grounded and enable “innovation now”. India cannot be left behind and we need a strong regulatory framework under the smart protein program to advance clear and simplified regulatory pathways to market.”