Shri Pawan Kumar Agarwal,
Chief Executive Officer,
FSSAI, New Delhi.
August 26, 2019
Subject: Proposal on Minimum Total Dissolved Solids (TDS) for Packaged Drinking Water (Food Product Category 2.10.8) and Removal of minimum limits of Calcium (Ca) and Magnesium (Mg).
The Indian Beverage Association has represented on May 26 and December 27, 2018 in respect of FSSAI’s draft proposal of minimum dosage of Calcium (Ca) and Magnesium (Mg) in Packaged Drinking Water as contained in the Notification dated November 16, 2018 for certain Regulations to further amend the FSS (Food Products Standards and Food Additives) Regulations, 2011.The Association has requested for removal of the proposed minimum limits. The scientific & practical reasons for the same are contained in the document called ‘Summary of Comments’ enclosed with this communication.
At this stage we are submitting for urgent consideration a proactive proposal to have Minimum levels of Total Dissolved Solids (TDS) for Packaged Drinking Water as mentioned below; this proposal is practical for the industry to comply with taking into account current investments and processes at manufacturing locations:
“In sub-regulation 2.10.8, in Table 2, in column (2) and (3), for serial no. 5, the following shall be substituted, namely:-
Total dissolved solids, mg/l, Range Max
30 to 500
“Provided the requirement of minimum TDS, as given in sub regulation 2.10.8, Table 2, at Serial No. 5, should not be applicable for Packaged Drinking Water used as an ingredient for manufacturing other food category such as Carbonated Water, Non- Carbonated Water Based Beverages, Caffeinated Beverages etc.”
It is requested that this proposal may kindly be examined and considered for adoption. It is requested also that, if deemed necessary, an opportunity may kindly be accorded to IBA to appear and elaborate on this proposal.