ANNEXURE V

ibma

INDIAN BISCUITS MANUFACTURERS’ ASSOCIATION

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CLAUSE - WISE SUGGESTIONS ONNOTIFICATION

NO GSR -380 (E) DATED 15 MAY 2008

S. No / Subject / Suggestions
1 / Implementation time / Since this notification introduced new labeling norms, adequate implementation time needs to be given to the industries. Please clarify that the date of implementation would be applicable to products manufactured after that date.
2(ii) / Definition of “ FSDUs” / Change suggested:
“…..physiological condition and/or specific diseases….”
3.2 (iii) / Compound ingredient / Exemption of 5% is too less and needs to be increased at least to 10%
3.2 (vi) (B) / Specify quantity of sugar / Change suggested:
“Specify quantity of added sugar”
3.2 (vi) (F), (G) / Additional clauses on nutrient claims / The requirement under these clauses are already covered under clause 3.2 (vi) (C) and its proviso. Hence these clauses could be deleted.
3.2 (vi) proviso after (G) part (a) / Exemption list to nutritional labeling / (a) The nutritional information mayshall not be necessary…..
3.2 (vi) proviso after (G) part (c ), (d), (e) and subsequent proviso / Related to trans fat / These are a set of new clauses that were not part of GSR 491(E) but included in this notification on transfat. Ambiguities exist in these clauses. It is suggested that these new clauses be deleted.
3.2 (V) (I) (ii) / Exemption from BBD for packages < 10 cm2 / It is suggested that the exemption area of < 10cm2 is too less and needs to be increased at least be 25 cm2
4. (a) (1) / Mandating all information to be provided on Principal Display Panel (PDP) / All information could not be adjusted on Principal Display Panel (PDP), especially in Small Packages. Hence exemption be given, as in the case of Best Before Date (3.2 (v) (I) (ii)).
4 (a) (1) (iii) / Online information be grouped together in other place / The scope of online printing should not be restricted to only inkjet printing.
8 / Declaration of added flavour / The declaration of flavours should not be in a box.