SUNIL GHEMICALS

Monufocturing Phormo lntermediotes & Foad lngredients...since 1981

FSSC 22OAO CERTIFIED

Smt. Harsimr-at I(aur Badal

I-Inion Cabinet Minister of F'ood Processing.
Government of India

Sub: Loss to Indian SSI due to flew FSSAI sampling mle

February 5,201,8

Dear Madam,

'fhank you for giving us an opportunity to present our

case personally to you. We rvrite to 1,61r as small-scaie
manufacturers of Citrate Salts like Sodium Citrate, Fotassium Citrate etc. Our main rarv material is Citr.ic
Acid.

Citflc Acid is being imported from China past 15-20 years as there is no Indian manufacrurer. This product is
used in
& approved bl'various industr-ies like pharmaceuticai, food, agro, chemrcais, eiectroplating, flavoring etc. India currently
imports 1,00,000 MT of this material annually ie 4000 containers of 25 MT each. China is supplying
to countries all
over the rvodd & catering to 7 Soh of global requir-emenr.

This month Food Safety Standards Authority of India (FSSAI) has suddenly decided that they rvill sample
each and
every container of imported Citric Acid to check if the material is as per FSSR. Tl-rey'rs also abruptly
sampling 500
other items under their purwiew thereby leading to massive delays and cletention/ production losscs to Indian
Small-
Scale Industry (SS!' trSSAI has now taised the rssue of NOC which is leading to detention
charges of approx. Rs.
101000/- per container. Thus, the total loss to Indian SSI is rnore tl-ran Rs. 2000 Cr. N.{ore
imporrantll,, all of this
rlloney is going to foreign shipping companies in USD and is a loss to the nation in INR.

Chinese manufacrurers are providing COA lvhich is in line with FSSR requirements so there is
no question of non-
compliance' f'here is a 2011 ruling in the US Supreme Court that acceptance of all, material
by end ,ser basecl on
specifications & repeat order impiies there is no question of quality which means rve should
be allorved to import frecl1,.

We request your kind attention to this serious issue plaguing SSI and wc offer our solutions herewith:

a Aliorv all to import without NOC for 3-4 rnonths ti1l industry understands formulated proceclure.
a Allorv actual end-users ro lmPort rvrthout NOC as we manufacrure intetnediates used in man1,
ildustries.
a Allow all to import without FSSAI NOC on the basis of NOC from CDSCO u,hich is drug authori{
and much
more stringcnt rhan FSSAL

Please ailow us to realize PNI's vision of "Make In India" rvhich will further help in ,,Ease of doing business,,

Once again rve thank you for )rour valuable time.

Yours Sincerely,

Iror Sunil Che Supported by For Amijal Chemicals

OFFICE :3ll-JA oFF VEERA DESAI ROAD, ANDHERI (W), MUMBAT - 400 053, MH, rNDr.A
TEL. : +91 22 2673 0ll4l03.l Email : abhishek.nayak@sunilchemicals.in I Website : www.sunilchemicals.in
FACTORY I : PAREKH TNDUSTRTAL ESTATE, CHANDANSAR ROAD, VIRAR(E), DIST. THANE - 4OI 303, MH, INDIA
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