Treasurer Shri Jitendra Gami
at Patidar Business Summit - Ahmedabad
Bio Stimulant policy - SFIA Point of view
Date – November
30,2019
To,
Hon’ble
A. Neeraja,
The Joint Secretary (INM),
Dept. of Agril., Co-Op. & Farmers
Wlfare,
Ministry of Agriculture & Farmer’s
Welfare,
Room No.299-C, Krishi Bhavan,
New Delhi, India-110001.
Ref – SFIA/006/Nov 19
Subject
: Amendment in the Fertiliser (
Control) Order,1985 for inclusion of Bio-Stimulant.
Respected Sir/Madam,
On behalf of Soluble
Fertilizer Industry Association, India, the undersigned
welcomes the move to notify Plant Growth regulators/Promoters and Bio
Stimulants under Fertilizer control order by inserting a new provision and
adding a whole new category.
We are of firm believe that such amendments shall
formalize variety of new agri inputs already been sold and used in various
forms and names. However, we believe
that certain provisions of the proposed amendment are not favourable to large
number of self-employed Agri entrepreneurs, SSIs engaged in the business of
producing and marketing of variety of combination of stimulants.
As per our understanding. unlike soluble
fertilizers, bio stimulants products available
in the market can be divided into two major categories – the straight
stimulants such as
1. Humic acid, fulvic acid, sea weed, amino acid etc
termed as (refered herein as “straight Inputs”) &
2. Combination of all these.
Category 2 constitute of about 70% of the market
wherein various SSIs sell mixtures in both liquid and solid forms.
As for the process described in the draft, we are of
the opinion that,
3(i) Its not clear from
the proposal that how and why the central government will specify the name of
the active ingredients and its manufacturer /importer.
3(ii) We are skeptical Whether such broad categories
can be maintained through available infrastructure of fertilizer laboratories.
A simplified way could be listing all straight ingredients through one time
process as its done in the case of soluble and other fertilizers. An
association can collectively pull resources to fulfill requirement of the ICAR
and CFC through data validation and get those basic “Straight
Inputs” listed instead of every individual go through the process.
3 (iii) Instead of
restricting manufacturing of all stimulants, provisions of SO 2900, 24-10, 2015
can be helpful in allowing companies to make their own combinations from listed
“Straight Inputs”, claim on label and
get samples tested through the normal process of market sample collection of
state departments.
3 (iv) As mentioned in
para 5 above, for the small companies, getting every combination notified
through state or central department seems practically impossible due to cost
involved.
3 (iv) a to c are the similar to
prescribed procedures for a pesticide/insecticide/fungicide as followed by CIB
and the same should not be adopted in FCO. Simpler provisions already present
in FCO can cover and regulate this product category without adding much cost to
both manufacturer/importer and to the testing laboratory. Given the fact 95% of
state Fertilizer labs not audited by NABL the possibility of fare sample testing
is almost impossible.
3 (iv) d to e, (v), (vi) is very much needed
to control heavy metal contamination of soil as well as crop. So, we agree with
you on this provision limiting the heavy metal content.
4 (ab) is an important
clause and must be implemented with appropriate limits.
5 CFC for Bio stimulant must include at least 2
members from 2 national level association so that ground reports from the
actual stake holders become the most important ingredient of all decision
making.
For rest of proposed clause of draft notification,
present provisions of FCO can be adopted or may suitably be modified to make it
more efficient and accurate.
We are of the opinion that the process followed,
while listing the first Water Soluble Fertilizer 19-19-19, way back in 2002, can
be a guiding manual for introducing a few primary bio stimulants so that the
category is created and later many other stimulants can be added in near
future, through the process of registration of fertilizers as guided in FCO
1985.
In view of the above, you are kindly requested to
devise the new insertion in and around SO 2900, 24-10-2015 to make it more
affordable and accessible to micro, small and medium industries and also easily
executable for state departments.
Looking forward to your kind co-operation.
Thanking you,
Yours Truly,
Rajib Chakraborty
National President
Soluble Fertilizer Industry Association
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