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Greenpeace report on pesticide residues in Indian tea - full of holes
Tuesday, 26 August, 2014, 08 : 00 AM [IST]
Kunal Kishore
Tea, the favourite beverage of most people, was in the news recently but for wrong reasons.  Greenpeace, a leading voluntary organisation working on issues related to environment, in its report titled—Trouble brewing: Pesticide residues in tea samples from India—had pointed out that tea manufactured in India contained illegal pesticides and it was hazardous for health.

According to this report, Greenpeace collected samples of tea from the retail outlets of different places, namely Calcutta, Bangalore, Delhi and Mumbai and these samples were sent for testing to an independent accredited laboratory, where after testing it was found that the tea samples contained pesticides.

It stated that a total of 34 pesticides were found, among which some of the pesticides were illegal and unapproved by the Indian government. The samples collected were well-known brands produced by Hindustan Unilever Ltd, Tata Global Beverages Ltd, Wagh Bakri Tea, Goodricke Tea, Twinings, Golden Tips, Kho-cha and Girnar. The report becomes very relevant in the light of the fact that India is the second-largest producer, fourth-largest exporter and one of the largest consumers of tea in the world. The countries and regions which are importing tea in notable amounts from India include USA, the European Union, Russia, and Canada.

However, through this article, I wish to clear some of the observations made by Greenpeace in its report. First, the report has based its findings on the basis of selective evidences and has very conveniently ignored some very glaring pieces of evidence. Second, the conclusion of the report that Indian tea is not fit for consumption is totally wrong. Third, Greenpeace, taking advantage of the messy Indian regulatory mechanism, has done substantial damage to the reputation of Indian tea.

The report states that only seven pesticides are allowed to be used in India, whereas the number of pesticides found in samples taken are around 34, meaning thereby the pesticides were used illegally. However, the interesting conclusion drawn by the report is that the tea is rendered unfit for human consumption due to this unauthorised use of pesticides. I wish to point out that in India, unauthorised use of pesticides cannot be the basis of conclusion that the tea is full of pesticides and is not fit for human consumption. Though this might sound incorrect prima facie, Greenpeace report took advantage of this fact.

In order to understand the full scenario, one needs to know about the permissibility on usage of the pesticides and the different Maximum Residual Limit (MRLs) prescribed by different organisations and countries. For the purpose of this report, we would refer to four sources: World Health Organisation (WHO); MRLs prescribed by Codex Alimentarius Commission; EU-MRLs; and Indian regulatory mechanism.

The report has referred to many pesticides being classified highly hazardous by WHO giving an impression that such pesticides are not allowed to be used at all, for example, Monocrotophos. First of all, the author would like to clarify that classification of a particular pesticide by WHO does not ipso facto mean that the pesticide is banned or not allowed to be used. For example, the readers would be surprised to know that monocrotophos is allowed to be used in EU. The report at one place states also that in 10 out of 27 samples, the amount of monocrotophos was well within the limit prescribed under EU-MRLs. Similarly, few other pesticides which have been depicted to be totally banned giving reference to WHO are allowed to be used in EU and are even allowed by Codex (international organisation working under the aegis of WHO and FAO) and the amount traced has been found to be well within the prescribed limit. In the light of the discussion above, it is submitted that the Greenpeace report does not give the clear picture of the situation.

MRLs prescribed by Codex Alimentarius Commission

Codex Alimentarius Commission was formed by the joint effort of the WHO and the Food and Agriculture Organisation of the United Nations (FAO). Codex is the body responsible for implementing the Joint FAO/WHO Food Standards Programme. The job of Codex is to set standards for food, additives, best hygiene practices, MRLs for pesticides and so on. The Codex standards are based on the best available science assisted by independent international risk assessment bodies or ad-hoc consultations organised by FAO and WHO. Reference made to the Codex food safety standards in the World Trade Organisations’ Agreement on Sanitary and Phytosanitary measures (SPS Agreement) means that Codex has far reaching implications for resolving trade disputes.  WTO members that wish to apply stricter food safety measures than those set by Codex may be required to justify these measures scientifically. Codex members cover 99% of the world’s population.

Codex Alimentarius Commission has formed a separate committee for prescribing MRLs for pesticides which is known as Codex Committee on Pesticide Residues (CCPR). The Committee has prescribed MRLs for many pesticides vis-à-vis food products and majority of the pesticides mentioned by the Greenpeace in its report have been allowed to be used in tea under Codex and the MRLs prescribed are much higher than what was found in the samples. For example, Thiamethoxam, for which the MRL prescribed is 20 mg/kg, whereas in the samples taken it was found in the range of 0.40-0.34 mg/kg, which was much below the prescribed limit. Similarly, for Cypermethrin, the MRL prescribed by the Codex is 15 mg/kg whereas the amount traced in the sample is in the range of 0.01 – 3.20 mg/kg.[;jsessionid=8A308DFC8C0A31F9DD6A2044C646EF03

] This goes on to show that the pesticides residue in Indian tea is much below the prescribed international standard. Yet, giving reference to Indian regulatory lapses, Greenpeace concluded that Indian tea is full of pesticides and not fit for consumption. However, the most surprising aspect of the report is that Greenpeace being an international organisation has not even mentioned the Codex standards in the report.


    The Greenpeace report has taken EU-MRLs as reference point as it provides for the most comprehensive listing of MRLs for pesticides. It might have also taken it for the reason that the EU is one of the largest importers of Indian tea and thus would have maximum effect on Indian exporters. However, what Greenpeace has not highlighted here is the fact that many of the pesticides which have been allowed in India are allowed to be used in the EU.

In fact, under EU-MRLs, it is specifically provided to be used for tea. The impression which the report gave was that Indian tea contained illegal pesticides and that too in excess quantity. When a matter is of such a high importance and has livelihood of so many people at stake, Greenpeace should have specifically highlighted the fact that though these pesticide ingredients are illegal in India, they are allowed to be used by Codex Alimentarius Commission and EU. Thereafter, they could have discussed the excess quantity which once again is debatable especially in the light of the fact that MRLs prescribed by the Codex Alimentarius Commission are much higher than what is prescribed under EU-MRLs. Countries do at times prescribe or set lower MRLs so as to discourage import and that is the reason why Codex says that any country prescribing lower limits has to support it by sufficient scientific reasons.
Indian regulatory mechanism
The report has highlighted on page 20 that regulation of pesticides in India is very complicated and confusing. There is no coherence between different organs of the government dealing with the issue and perhaps this explains the presence of unregistered pesticides in India. This shows that Greenpeace was very much aware of the fact as to why unauthorised pesticides were found in the samples taken, still, they reported the whole story in a way that it appeared that the presence of unauthorised pesticides rendered the tea manufactured totally unfit for consumption. In fact, almost all the pesticides reported to have been found in the samples are allowed either under prescribed EU-MRLs or by Codex Alimentarius Commission. The point the author is trying to make here is that the report published by Greenpeace was not about the regulatory mess in India related to insecticides/pesticides and had that been the case, the Government of India would have been grateful to Greenpeace. The report was about the unhealthiness of the Indian tea and while reporting on it, Greenpeace failed to come out with a balanced view and ended up showing Indian tea in bad light.

The aforementioned discussion shows that the Greenpeace report has missed out many important aspects about the MRLs of pesticides. Taking advantage of the fact that Indian regulatory mechanism is in mess, it has shown Indian tea in bad light. It is not surprising that neither the Tea Board nor the affected companies have so far criticised the report because in doing so they might find themselves in uncomfortable situation under the Insecticides Act or under Food Safety and Standards Act and Regulations made thereunder.

Further, one would have understood such irresponsible reporting, had it been done by some local NGO which did not have global exposure. It was certainly not expected from a reputed organisation like Greenpeace. However, the most surprising aspect of the whole story is the silence of Food Safety and Standards Authority of India (FSSAI), which is the authorised body to deal with such issues. I sincerely hope that it comes out with some statement in this regard.
        (The author is an advocate specialising in food safety laws)
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