
Loading...
Law Update
Quick note
Below is the official summary and the reference document preview. Use “Open PDF” for full screen view.
Tea manufacturers, processors and exporters in India have a new food safety proposal to pay attention to. The Food Safety and Standards Authority of India (FSSAI) has proposed Maximum Residue Limits (MRLs) for two pesticides, Acetamiprid and Imidacloprid, in tea.
According to the draft Food Safety and Standards (Contaminants, Toxins and Residues) Amendment Regulations, 2026, the recommended permissible limit for Acetamiprid is 20 mg/kg, and that of Imidacloprid is 50 mg/kg. The draft was gazetted in the Gazette of India on 16th October 2026, and a government notification was issued on 17th October 2026.
The proposal is relevant to tea growers, processing units, manufacturers, packers, exporters and food testing laboratories. It could affect how businesses monitor pesticide residues, check raw material quality and manage product compliance once the amendment is finalised.
Nevertheless, there is one key difference here: the revision of October 2026 is still a draft. The suggested norms do not become obligatory standards by default. Tea companies have to comply with existing norms of food safety until the final regulation is made.
| Particular | Details |
| Regulatory authority | Food Safety and Standards Authority of India (FSSAI) |
| Ministry | Ministry of Health and Family Welfare |
| Notification date | 15 October 2026 |
| Gazette publication | 16 October 2026 |
| PIB announcement | 17 October 2026 |
| Draft regulation | Food Safety and Standards (Contaminants, Toxins and Residues) Amendment Regulations, 2026 |
| Gazette notification reference | F. No. SS-T0SP02(NOTI)/1/2025-Standard-FSSAI |
| Gazette identifier | CG-DL-E-17102026-277222 |
| Legal provision | Regulation 2.3.1 of the 2011 Regulations |
| Pesticides covered | Acetamiprid and Imidacloprid |
| Proposed Acetamiprid MRL | 20 mg/kg (20 ppm) |
| Proposed Imidacloprid MRL | 50 mg/kg (50 ppm) |
| Consultation period | 60 days from the date Gazette copies are made available to the public |
| Regulatory status | Draft proposal, subject to finalisation |
The notification proposes inserting tea-specific entries against the existing pesticide entries in Regulation 2.3.1. It does not introduce a separate licensing system, new registration fee or universal laboratory-testing schedule for tea businesses.
The proposed amendment focuses on setting specific residue limits for two pesticides in tea.
FSSAI intends to amend the table under Regulation 2.3.1 of the Food Safety and Standards (Contaminants, Toxins and Residues) Regulations, 2011.
The draft proposes adding tea as a food commodity against two existing pesticide entries.
The proposed changes are:
This is the central regulatory change. The draft does not replace the entire pesticide residue framework or create a separate law exclusively for the tea industry.
The proposed entries would provide specific numerical standards that can be used for evaluating pesticide residues in tea after they are finalised and made applicable.
For manufacturers and exporters, the change is worth following because pesticide residue standards influence how food products are evaluated and whether they meet the requirements of the relevant market.
Food products can contain small amounts of pesticide residues resulting from agricultural activities. This is why food safety regulators establish limits for certain pesticides in specified food commodities.
In India, the Food Safety and Standards Act, 2006 provides the main legislative framework for food safety regulation. The Food Safety and Standards (Contaminants, Toxins and Residues) Regulations, 2011, together with subsequent amendments, establish relevant requirements for contaminants and residues in food.
The October 2026 proposal fits within this existing framework.
What Is a Maximum Residue Limit?
A Maximum Residue Limit, commonly called an MRL, is the maximum concentration of a pesticide residue legally permitted in a particular food commodity under an applicable regulation.
MRLs are expressed using measurement units such as milligrams per kilogram (mg/kg).
For example, a residue concentration of 20 mg/kg means that the measured sample contains 20 milligrams of the relevant residue per kilogram of food.
For mass-based concentrations: 1 mg/kg = 1 part per million (ppm).
An MRL is not a recommended pesticide application rate. It is also not a simple dividing line between food that is harmless and food that is poisonous.
Residue limits are established through scientific and regulatory assessments that consider pesticide residue information, dietary exposure and other relevant factors.
Why Are Pesticide Residue Standards Necessary?
Tea passes through several stages before it reaches consumers, beginning with cultivation and continuing through processing, manufacturing, packaging and distribution.
Pesticides used during cultivation may leave residues in harvested agricultural material.
Clear regulatory standards help businesses and enforcement authorities assess whether the relevant concentrations are within legally prescribed limits.
These standards also provide a common reference for laboratories, suppliers and food businesses when evaluating product conformity.
Does an MRL Allow Farmers to Use a Pesticide?
No. A prescribed residue limit does not automatically authorise pesticide use on a particular crop.
Growers must follow the applicable pesticide registration, approval and use restrictions.
A pesticide may have an MRL for a food commodity without that limit serving as permission for unrestricted application.
Tea businesses should therefore treat pesticide-use authorisation and food-residue compliance as related but separate regulatory matters.
The government has explained that the proposed limits reflect an effort to balance consumer protection with the practical requirements of agriculture.
Tea growers need effective methods to protect crops from pests. At the same time, food safety standards must consider potential consumer exposure to pesticide residues.
The proposed MRLs seek to bring greater clarity to how the two identified residues are monitored in tea.
Consumer Safety and Product Quality
Tea is consumed regularly by a large number of people. Clear food safety standards are therefore relevant to public confidence in the product.
FSSAI's proposal seeks to provide specific benchmarks for Acetamiprid and Imidacloprid instead of leaving businesses to interpret the regulatory position without these proposed tea entries.
Once finalised, the standards could support more consistent assessment of residue concentrations.
Scientific Review of Pesticide Residues
According to the government, the proposed values were developed with reference to scientific assessments and relevant international practices.
Pesticide residue regulation requires consideration of more than the presence of a chemical alone.
The assessment may involve the amount detected in food, expected dietary exposure, the available residue data and other relevant safety considerations.
Practical Requirements of Tea Cultivation
Pest management remains an important part of agricultural production.
Without appropriate controls, pests can damage crops and reduce agricultural productivity.
The regulatory objective is therefore not simply to eliminate every crop-protection measure. It is to establish standards that protect consumers while recognising the need for responsible and authorised pesticide use.
Earlier Pesticide Regulation Measures
The October 2026 proposal follows earlier changes to pesticide residue regulations.
The government has referred to its 2024 regulatory review and earlier measures involving the delisting of 13 pesticides identified as having higher toxicity.
Those developments form part of the broader regulatory background. They are not additional prohibitions newly introduced by the October 2026 draft.
The draft identifies two pesticides and proposes specific residue limits for each.
The two limits are different because residue standards are established for particular pesticides and commodities.
| Pesticide | Proposed limit | Equivalent concentration | Current status of the proposed entry |
| Acetamiprid | 20 mg/kg | 20 ppm | Draft |
| Imidacloprid | 50 mg/kg | 50 ppm | Draft |
Businesses should not assume that the same limit applies to all pesticides used in tea cultivation.
Acetamiprid Residue Limit in Tea: Proposed 20 mg/kg
Acetamiprid belongs to a group of insecticides known as neonicotinoids.
It is used for controlling certain insect pests, subject to the relevant product and crop-use authorisations.
FSSAI has proposed an Acetamiprid MRL of 20 mg/kg in tea.
For tea businesses, this proposed figure is relevant when reviewing future testing specifications and discussing residue management with suppliers.
However, the value remains subject to the outcome of the amendment process.
Manufacturers should not automatically treat it as the existing legally enforceable limit merely because the draft has been published.
Imidacloprid Residue Limit in Tea: Proposed 50 mg/kg
Imidacloprid is another neonicotinoid insecticide associated with the control of certain agricultural pests.
Under the October 2026 draft, FSSAI proposes an MRL of 50 mg/kg for Imidacloprid in tea.
The Ministry of Health and Family Welfare states that the proposed value has been formulated with reference to international Codex standards.
If the amendment is finalised, the adopted value will need to be considered alongside other applicable food safety requirements.
For now, businesses can use the proposal to understand the direction of the regulatory review and evaluate whether their existing quality-control arrangements require attention.
Difference Between Pesticide Residue Limits and Pesticide Application Rates
One point that businesses should understand is that residue concentration and pesticide application quantity are not the same thing.
An MRL measures the concentration of pesticide residue in a food commodity.
An application rate refers to the amount of pesticide product used during agricultural operations.
The proposed figures of 20 mg/kg and 50 mg/kg do not tell growers how much Acetamiprid or Imidacloprid they may apply to tea plants.
Pesticide application must follow the relevant authorisations and instructions independently of these proposed residue limits.
International residue standards are relevant to India because tea is traded across several markets.
Different importing countries may apply different rules to the same pesticide and food commodity.
The PIB announcement dated 17 October 2026 provides a comparison for Acetamiprid in tea.
| Country | Acetamiprid MRL cited by PIB |
| India | 20 ppm (proposed) |
| Japan | 30 ppm |
| United States | 50 ppm |
The proposed Indian value is numerically lower than the corresponding limits reported for Japan and the United States.
However, comparing these figures alone does not prove that one country's entire food safety system is stricter than another's.
Regulatory systems may differ in their commodity descriptions, residue definitions, testing methods and enforcement rules.
The proposed Indian limit for Imidacloprid also takes international Codex standards into account.
What Does This Mean for Indian Tea Exporters?
Exporters should not assume that compliance with Indian pesticide residue standards automatically means compliance with the standards of another country.
Before exporting tea, businesses should identify the requirements applicable to their destination market.
This may involve checking the relevant pesticide MRLs, buyer specifications, testing expectations and import conditions.
For exporters serving several markets, maintaining clear product specifications for each destination may help avoid confusion.
Importantly, the October 2026 FSSAI draft does not replace any foreign country's independent import or food safety requirements.
The proposed standards are relevant across the tea supply chain, although different stakeholders may need to respond in different ways.
1. Tea Growers and Plantation Operators
Pesticide residues originate from agricultural practices, making cultivation an important stage in residue management.
Tea growers should understand the pesticides authorised for use on their crops and the conditions attached to those products.
They can also examine whether their existing practices and records support responsible pesticide management.
The proposed amendment does not itself introduce new pesticide application instructions for growers.
2. Tea Processing Units
Tea processors receive agricultural material that may have been treated with crop-protection products.
They may need to understand the quality of incoming tea and whether supplier practices align with applicable safety expectations.
Where relevant, processors can review available residue test reports and communicate with suppliers about the proposed standards.
3. Tea Manufacturers
Manufacturers are concerned with the conformity of products that they process or place on the market.
If an applicable residue standard is not met, manufacturers may need to examine product quality, traceability and supplier information.
The proposed amendment gives manufacturers a reason to review how Acetamiprid and Imidacloprid are addressed in their existing quality systems.
It does not automatically require them to submit a new FSSAI licence application.
4. Tea Packers and Distributors
Packers and distributors may not use pesticides or directly control cultivation practices, but they still have an interest in obtaining suitable products from suppliers.
Supplier information, batch identification and product-quality documentation can help these businesses understand the origin and conformity of the tea they handle.
Their exact legal obligations depend on their activities and the applicable food safety regulations.
5. Tea Exporters
Exporters may need to satisfy both Indian requirements and the product standards of the importing country.
They should check whether the applicable pesticide limits differ across destinations.
Export documentation, laboratory testing and buyer requirements may also be relevant, depending on the market and transaction.
6. Food Testing Laboratories
Laboratories involved in pesticide residue testing need suitable analytical methods and accurate reporting.
The proposed values may be relevant when laboratories and their clients review the scope of residue testing programmes.
The draft does not, by itself, prescribe a new mandatory test for every tea shipment or every tea manufacturer.
The draft may influence business decisions even before it becomes legally operative.
Manufacturers and exporters can use the proposal to review their existing arrangements and identify areas that may require attention if the amendment is finalised.
Raw Material Procurement
Tea manufacturers often purchase raw material from growers, plantations or other suppliers.
Where pesticide residues are relevant to product conformity, supplier selection and quality checks become important.
Businesses may review the information they receive about agricultural practices, product quality and previous test results.
Any additional supplier controls should reflect the applicable legal requirements and the business's own quality risks.
Quality Control and Laboratory Testing
Manufacturers already using pesticide residue testing can examine whether their testing arrangements cover the substances relevant to the proposed amendment.
This may involve checking the scope of testing, analytical methods and how results are reported.
The proposed values should not be substituted for existing legally enforceable standards until the final regulatory position is established.
Product Traceability
When a quality concern arises, businesses benefit from being able to identify the source of the affected material.
Batch identification and suitable supplier records can help with this process.
Traceability arrangements should be appropriate to the business and meet any relevant existing statutory requirements.
Export Specifications
Indian tea exporters may need to review how their internal quality specifications relate to the requirements of foreign buyers.
An importer may require compliance with a destination country's residue standards or additional contractual specifications.
Exporters should distinguish these commercial requirements from the standards introduced under Indian law.
Possible Financial and Operational Implications
If the proposed limits become enforceable, some businesses may choose or need to revise their quality-control arrangements.
Depending on their existing systems, this could involve additional testing, supplier communication or internal reviews.
The draft does not announce a specific new government testing fee or prescribe a fixed compliance cost for tea businesses.
These potential expenses should therefore be described as business considerations rather than statutory charges introduced by the amendment.
Testing helps establish whether particular pesticide residues are present in a tea sample and at what concentration.
For manufacturers, exporters and processors, test results can support product-quality decisions and assessment against applicable residue limits.
The usefulness of a report depends on whether the sample was collected correctly, the appropriate substances were analysed, and the results were interpreted against the correct standards.
How Is Pesticide Residue Testing Conducted?
Pesticide residue analysis generally begins with selecting and collecting a representative tea sample.
The laboratory prepares the sample and uses a suitable analytical method to measure the residues being examined.
Techniques such as liquid chromatography coupled with mass spectrometry may be used for certain pesticides.
The results are commonly expressed in mg/kg.
The laboratory may then report whether the measured concentration meets the relevant specification or provide data for the client to assess.
The correct method and interpretation depend on the substance, food matrix, applicable residue definition and testing requirements.
Why Is Proper Sampling Important?
A test result represents the sample that was analysed.
If a sample is not representative of the relevant batch or material, it may not provide a reliable picture of the product as a whole.
Businesses arranging testing should therefore understand the purpose of the test and the appropriate sampling procedure.
Sampling requirements may depend on the relevant regulatory or commercial framework.
What Should Businesses Check in a Pesticide Residue Test Report?
A useful report may contain the following information:
These are useful items for understanding a testing report, not a new compulsory documentation list introduced by the October 2026 draft.
Is Pesticide Residue Testing Mandatory for Every Tea Manufacturer?
The draft announcement does not impose a new universal testing frequency on every tea manufacturer.
Whether testing is legally required, and under what circumstances, must be determined from the applicable existing rules, the business's activities and any relevant regulatory directions.
Testing may also be undertaken for commercial quality assurance or to satisfy buyer requirements.
Businesses should not confuse recommended internal testing with a new statutory obligation.
Pesticide residue standards are only one part of the regulatory framework affecting tea businesses.
Manufacturers, processors, packers and other food business operators may also need appropriate FSSAI registration or licensing, depending on their activities and eligibility.
The above-mentioned conditions are not dependent on the pesticide residue notification proposed in October 2026.
FSSAI Registration for Tea Businesses
All food business operators within the ambit of the Food Safety and Standards Act, including those subject to licensing regulations, must have the requisite FSSAI registration or license.
The correct category depends on the nature and scale of the business and other prescribed conditions.
Businesses starting tea-related operations should assess their eligibility before applying.
Professional FSSAI licence registration services may assist with identifying the appropriate category and preparing the relevant application.
FSSAI State Licence for Tea Manufacturers
Certain food businesses qualify for an FSSAI State Licence under the applicable licensing criteria.
Eligibility must be determined using the current rules, including the relevant business activity, capacity, scale and other conditions.
Tea manufacturers should not assume that annual turnover alone determines the correct licence for every operation.
FSSAI Central Licence for Tea Businesses
A Central FSSAI Licence is required for specified categories of food businesses under the applicable licensing regulations.
Some operations may qualify or require Central licensing because of their activity, size or regulatory category.
Tea businesses considering import, export, manufacturing or wider distribution activities should verify which licensing provisions apply.
Does the 2026 Draft Require a New FSSAI Licence?
No separate FSSAI licence is introduced by the pesticide residue draft.
The proposal concerns the addition of specified pesticide residue limits for tea within the existing contaminants, toxins and residues regulations.
Businesses should therefore continue managing their existing licensing obligations while monitoring the proposed product standards.
An FSSAI licence should not be treated as proof that every batch of tea meets all applicable pesticide residue limits.
Food businesses are responsible for meeting the food safety standards applicable to their products.
Where a legally enforceable pesticide residue limit is exceeded, the issue may require investigation and appropriate action under the relevant law.
The specific regulatory consequences depend on the applicable provisions and circumstances.
Product Non-Conformity
A tea product that fails an applicable residue standard may require further assessment.
The business may need to review the test results, investigate the affected material and determine the necessary response.
Supplier and Raw Material Concerns
If residue problems are connected to incoming tea, the manufacturer or processor may need to examine supplier practices and sourcing records.
Maintaining clear supplier information can support this process.
Export-Market Difficulties
An exporter may face difficulties if tea does not meet the pesticide residue standards of the destination country.
Commercial and Reputational Impact
Food safety concerns can also affect buyer confidence and business relationships.
A consistent approach to product quality and supplier management may help businesses identify concerns before products move further through the supply chain.
Important: The October 2026 draft does not constitute new sanctions for exceeding the proposed 20 mg/kg and 50 mg/kg figures. A sanction must be based on a legal obligation.
The notice is dated October 15, 2026, and published in the Gazette of India on October 16, 2026. It goes on to say that the draft regulations will be considered 60 days after the date when copies of the concerned gazette are made available to the public.
It also invites objections and suggestions from interested stakeholders.
This is a consultation provision, not a confirmed enforcement date for the proposed MRLs.
How Can Stakeholders Submit Comments?
According to the text of the draft notification, objections or suggestions may be sent through email & the email ID is regulation@fssai.gov.in.
Stakeholders should verify the consultation instructions and available submission period against the official Gazette before submitting comments.
What Should Stakeholders Include in Their Comments?
Tea growers, manufacturers, processors, exporters and relevant industry bodies may wish to submit information connected to the proposed values.
Useful comments may address scientific residue data, agricultural practices, analytical testing considerations or practical implementation issues.
Comments should be clear and supported by relevant information rather than general objections without evidence.
When Will the New Limits Become Mandatory?
As of 19 October 2026, the reviewed material establishes the draft proposal but does not establish a final commencement date.
The regulatory process must be completed, and businesses must examine the final legal instrument to determine when any adopted limits become applicable.
A 60-day consultation provision should not be mistaken for a 60-day compliance deadline.
Tea businesses can begin with a simple review of their existing practices. This does not mean that they must immediately introduce a new compliance system.
Review the Applicable Food Safety Standards
Identify which pesticide residue standards currently apply to the tea being manufactured or supplied.
Use the appropriate legal provisions rather than relying only on summaries of the proposed amendment.
Examine Supplier Practices
In cases where necessary, review the authorized use of pesticides and their residue control practices with farmers and/or raw material suppliers. This might assist companies in determining whether their current quality standards cover the identified substances.
Review Available Testing Reports
Businesses with existing testing arrangements can examine whether Acetamiprid and Imidacloprid are included in the substances analysed.
They can also check whether laboratory results are reported in suitable units and can be interpreted against the correct standards.
Maintain Appropriate Records
Supplier information, batch details and available laboratory reports can support quality-control decisions.
Businesses should preserve any records required by applicable law and consider additional internal documentation based on their own operational needs.
Check Requirements for Export Markets
Exporters need to establish the limits on residues and the tests required in their destination countries. They also need to look at any contractual agreements made with foreign buyers.
Follow the Final Notification
The next important regulatory event will be the finalisation of the draft, if adopted.
Businesses should check the final text for the adopted values, commencement date and any applicable conditions before changing procedures solely because of this amendment.
The purpose of pesticide residue regulation is to establish measurable standards for food products.
For tea, this involves considering agricultural practices, pesticide residue data and consumer exposure.
The October 2026 proposal seeks to provide clearer regulatory values for two identified pesticides.
The Ministry of Health and Family Welfare has also stated that India's average pesticide use is less than 0.5 kg per hectare, compared with an estimated global average of 2.38 kg per hectare.
This gives context to pesticide use in Indian agriculture. However, national pesticide-use averages do not establish whether any particular tea product complies with a residue standard.
Product conformity must be assessed using the applicable requirements and reliable product information.
The proposed limits are therefore best understood as one part of the broader food safety and agricultural regulatory framework.
The next stage involves consideration of the draft through the applicable regulatory process.
Stakeholder objections and suggestions received within the prescribed period may be examined by FSSAI.
The regulator may then proceed with the amendment in accordance with the relevant legal requirements.
The final text may confirm the proposed limits or contain changes.
For manufacturers and exporters, the most important details to check will be:
Until that time, the tea industry should refrain from considering the draft as a new requirement.
Tea manufacturers, processors, packers and other food business operators often need help identifying the correct licensing requirements for their operations.
Corpseed offers FSSAI registration and licensing services that may assist eligible businesses with their applicable applications and documentation. Relevant services include the following:
1. FSSAI Licence Registration
Businesses establishing food operations may need help understanding which registration or licensing category applies.
Corpseed assists with FSSAI licence registration and the related application process.
2. FSSAI Central Licence Assistance
Businesses that fall within the Central Licence criteria may require assistance with their application and supporting documentation.
Corpseed provides FSSAI Central Licence services for eligible food business operators.
3. FSSAI State Licence Assistance
Tea businesses that qualify for State licensing may seek help with the relevant application process.
The appropriate category must be identified using the applicable regulations.
4. FSSAI Licence Renewal
Existing food business operators should also track the validity of their licences and complete renewal requirements as applicable.
Corpseed assists with FSSAI licence renewal procedures.
These services relate to registration and licensing. Businesses should separately assess the technical pesticide residue standards, testing requirements and product-quality responsibilities applicable to their products.
Need FSSAI Compliance Services for Your Tea Business?
Whether you are planning a tea manufacturing unit, applying for an FSSAI licence or reviewing your existing licensing obligations, understanding the correct regulatory requirements can help avoid application mistakes and unnecessary delays.
Connect with Corpseed for assistance with FSSAI registration, licensing and related compliance procedures.
FSSAI has proposed tea-specific Maximum Residue Limits of 20 mg/kg for Acetamiprid and 50 mg/kg for Imidacloprid under its October 2026 draft amendment.
The proposal would add entries to the existing pesticide residue table under Regulation 2.3.1 of the Food Safety and Standards (Contaminants, Toxins and Residues) Regulations, 2011.
The draft is relevant to tea growers, manufacturers, processors, exporters and testing laboratories, particularly where pesticide residue monitoring forms part of existing quality-control activities.
However, the proposed limits are not automatically enforceable simply because the draft has been published.
Tea businesses should continue complying with the currently applicable requirements, review their existing practices where necessary and monitor the final FSSAI notification.
Document Preview
Embedded reference document
Related
Explore more updates from the same department.