Cold Drinks Standards

Session 2
Standards
for soft
drinks
Briefing
workshop
August 4,
2004
Centre for Science and Environment
Existing soft drink standards in

India
Exempted from industrial licensing under Industries
(Development and Regulation) Act, 1951
Mandatory regulation under The Fruit Products Order (FPO1955); regulated by Ministry of food processing
Soft drinks standards:
o Sweetened aerated water with no fruit juice or fruit pulp
or containing less than 10 per cent of fruit juice or fruit
pulp under Part II (D) of Fruit Products Order (FPO), 1955;
o Carbonated water as defined under item A 01.01 of
Appendix B of Prevention of Food Adulteration (PFA)
Rules, 1955;
o Carbonated Beverages defined under IS 2346-1992 of
Bureau of Indian Standards.
Existing soft drink standards
Standards for pesticide residues in

soft drinks
does not exist.
Rule 65 of PFA regulates pesticides in food.
But food is defined to exclude beverages.
Sub-section A.01-01 in appendix B defines the
standards of quality for non-alcoholic beverages.
But has nothing to say about pesticide residues.
PFA and FPO: The water used for manufacturing the
soft drink should be Potable. But has not defined
what is potable.
Difference in results: CSE lab vs.

Others
CSE Result: 11 - 70 times higher than
multiple residues standard of bottle water
CFRTI: 1.2 - 5.2 times higher
CFL: 1.6 - 5.2 times higher
CPCB: 3.1 7.2 times higher
Shriram Lab: 17 419 times higher
o Different batches
o Manufactured during different time period
o Tested in different labs
Differences in result: JPC verdict

In view of the fact that these labs did not
test identical samplesthe quantitative
results reported by them cannot be
compared.
The Committee however find that the CSE
findings are correct.
Are soft drinks safe?

What is safe? What government lab
found safe? CSE lab found unsafe?
Or Sriram lab unsafe????
The answer to this question will also
provide the answer for: what should
be the pesticide standards for soft
drinks.
Safety not about large numbers

Pesticides are deadly. Invisible exposure
over time, in small (tiny) doses leads to
chronic health effects.
Immunosuppressive effect triggers diseases
like cancer or asthma.
Persistent build up in our bodies lindane for
instance is a potent carcinogen.
Pesticide risk management is all about
managing and minimising tiny exposures.
Defining safety
Safety is all about meeting and
adhering to a given standard.
Safety is about managing the
poison-nutrition trade-off (we ingest
poison to get some nutrition..)
But this poison must be within safe
exposures. Therefore, safety
requires setting standards for the
food basket.
Politics of clubbing of soft drinks and

juices
Politics of regulations: widen the scope of the
regulation so that it is:
A. impractical and unfeasible;
B. impossible to implement;
C. lax and weak.
By clubbing all water based beverages into one
regulation that is exactly what happened. The
fruit juice, malt beverage clubbed together with
coke and pepsi.
Take heavy metal norms:

Companies already meet the stringent heavy metal
norms in their products (see Annexure 3).
But they want lax standards. Asking for Juice
standards set by CODEX.
Mercury (highly toxic):
In drinking water: 1 ppb
In juices: 1 ppm (1000 times higher)
Same issue in bacterial plate count:
In water based drinks: 100/250 ml
In barley and malt drinks: 5000/250 ml
How much should be allowed in soft drinks? Cannot
club significantly different ingredients.
Distinct category exists

Cannot regulate if significantly different ingredients
Indian regulations already have a distinct category for
soft drinks. Under:
Carbonated water as defined under item A 01.01 of Appendix B of PFA
Rules, 1955;
Sweetened aerated water with no fruit juice or fruit pulp or containing less
than 10 per cent of fruit juice or fruit pulp under Part II (D) of Fruit Products
Order (FPO), 1955;
Carbonated Beverages defined under IS 2346-1992 of Bureau of Indian
Standards.
Separate standard for other water based beverages:

fruit nectar, synthetic syrups, and fruit juices exist. Can
keep as separate categories.
Clubbing juices and soft drinks: a

masterstroke
The pesticide residue of juices will be different
to soft drinks. Juices are part of the essential
diet. They provide nutrition.
Cannot club juices with soft drinks.
Also we can only allow pesticide residue in
soft drinks, if we remove some essential food
item from our diet.
Can soft drink substitute milk?
Can soft drink substitute fruit juices?
2. Should we set standards for

final product
Pesticide
Heavy metals etc.
Soft Drinks
Cheese (even
under PFA)
Butter (even
under PFA)
Ice cream (even

under PFA)
Baby food
Globally no country has set pesticide standards for

soft drinks. WHY??
Actual exposures?
European Union (1996)
USA (1996)
Above MRL (1.4%)

Within
MRL
(35.6)
Free from
residues
(63%)
Within
MRL
(67.2%)
Above MRL (4.8%)

Free from
residues
(28%)
India (1965-98)
Within
MRL
(39%)
Above MRL
(20%)
Free from
residues
(41%)
Source:
G S Dhaliwal &
Balwinder Singh,
2000: 208
Out side System works.

Check..enforce..penalize
US: 6,523 samples tested and 4% failed;

EU: 46,000 samples only 4% failed standards;
Canada: 44,000 samples only 2% failed standards.
Low MRL set. Strict enforcement. Regular surveillance.
Their governments say that pesticides are not a health
hazard because the exposure is low.
They do not regulate pesticides in

finished products like soft drinks,
because they have cleaned up their
contamination. We havent.
Honeyjam contaminated
Government report: 2001
Honey: out of 82 samples, 51 per cent
contaminated.
Jam67 per cent contaminated
Jellyall 12 samples contaminated..
Baby food (1999) all contaminated.
India has to set standards for processed food+
enforce standards for raw commodities.
How do we set standard for

final product?
Globally pesticide standard for
processed food are set by following 3
broad principle:
o Carry forward principle
o Multi-constituent principle
o No standard - no residue principle.
Carry-forward principle
Carry-forward the pesticide from raw
agricultural commodity to the finished
product.
Means that if under the PFA there is a
standard for Phorate in sugarcane, then
the standard for Phorate in sugar should
be similar to the sugarcane standard.
Conversely, if there is no standard for DDT
in sugarcane than no residue of DDT
should be found in sugar.
Multi-constituent principle
MRL of a finished Products with multiple
commodities = Sum of MRLs of various
commodities as proportionately present.
Soft Drinks constituents:
10% sugar+1% others+89 % water
(10% of sugar MRL) + (1% of other MRL) + (89% of water MRL)
Calculate norms for soft drinks as

finished product
No standard-no residue principle

Law states that:
If an MRL for a chemical is not listed in
the standard then there must be no
detectable residue of that agricultural
chemical in that food.
Therefore, if under the PFA no standard
for DDT in sugarcane is mentioned
then there must be no detectable
residue of DDT in sugar cane.
Pollution Monitoring Laboratory

Soft Drink =
89% water + 10% sugar + 1% [co 2+concentrate]
Let us take Packaged Drinking Water Standard [in ppb] >
Water
Sugar
CO2+concentrate
Final
Packaged
Drinking Water
PFA
PFA
Packaged
Drinking water
DDT
0.1
0.09
Lindane
0.1
0.09
Malathion
0.1
0.09
Chlorpyriphos
0.1
0.09
Pollution Monitoring Laboratory

Different standards for Soft Drinks derived from
different regulatory regimes [in ppb]
Indian
BIS
WHO
USEPA
Packaged
Drinking water
DDT
Absent [0]
0.9
0.09
Lindane
Absent [0]
0.27
0.18
0.09
Malathion
Absent [0]
810
0.09
Chlorpyriphos
Absent [0]
27
0.09

BIS (IS 10500)
Drinking water
WHO
USEPA
Packaged
Drinking water
DDT
Absent [0]
0.9
0.09
Lindane
Absent [0]
0.27
0.18
0.09
Malathion
Absent [0]
810
0.09
Chlorpyriphos
Absent [0]
27
0.09
100% of CFL/CFTRI/CSE/CPCB samples fail BIS

norm

Indian
BIS
WHO
USEPA
Packaged
Drinking water
DDT
Absent [0]
0.9
0.09
Lindane
Absent [0]
0.27
0.18
0.09
Malathion
Absent [0]
810
0.09
Chlorpyriphos
Absent [0]
27
0.09
100% of CFL/CFTRI results fail BIS norm

75% of CFTRI and 58% of CFL results fail WHO norm

Indian
BIS
WHO
USEPA
Packaged
Drinking water
DDT
Absent [0]
0.9
0.09
Lindane
Absent [0]
0.27
0.18
0.09
Malathion
Absent [0]
810
0.09
Chlorpyriphos
Absent [0]
27
0.09
100% of CFL/CFTRI results fail BIS norm

75% of CFTRI and 58% of CFL results fail WHO norm
100% CSE and CPCB results fail WHO norm

Indian
BIS
WHO
USEPA
Packaged
Drinking water
DDT
Absent [0]
0.9
0.09
Lindane
Absent [0]
0.27
0.18
0.09
Malathion
Absent [0]
810
0.09
Chlorpyriphos
Absent [0]
27
0.09
100% of CFL/CFTRI/CSE/CPCB samples fail USEPA

norm

Indian
BIS
WHO
USEPA
Packaged
Drinking water
DDT
Absent [0]
0.9
0.09
Lindane
Absent [0]
0.27
0.18
0.09
Malathion
Absent [0]
810
0.09
Chlorpyriphos
Absent [0]
27
0.09
100% of all results fail USEPA norm
And obviously all results fail packaged drinking

water norms as well.
Soft drinks not safe

CSE said not safe because drinks
did not meet any set-derived
standards
Not only for the tests done by CSE
but also for tests done by CFL,
CFTRI, CPCB and Shriram lab,
Bangalore.
What should be the soft drink

standard?
If we use the global practice, then:
As per the PFA there are only 4 pesticides for
which standards exists for sugar cane and
therefore for sugar used in soft drinks:
Atrazin:
Carbofuran:
Phorate:
Simazine:
0.25 mg/kg
0.1 mg/kg
0.05 mg/kg
0.25 mg/kg
Ministry of health has already recommended that
water used in soft drink should meet BIS packaged
drinking water standard.
What should be the soft drink

standard?
Inputs
Amount
(gm)
BIS bottle water standard/ MRLs of sugar cane and hence

sugar under PFA (ppm)
Atrazine
Simazine
Carbofuran
Phorate
All other
pesticides
Water
890
0.0001
0.0001
0.0001
0.0001
0.0001
Sugar
100
0.25
0.25
0.1
0.05
Others
10
0.025
0.025
0.01
0.005
0.00009
Soft Drink
Standard
Soft drink standard using global

principle and existing Indian standards
1.
2.
3.
4.
5.
6.
Atrazin 0.025 mg/l

Simazine 0.025 mg/l
Carbofuran 0.01 mg/l
Phorate 0.005 mg/l
Other individual pesticides: 0.00009 mg/l
Total pesticide: 0.00045 mg/l
Note: The total pesticide standard does not
include the 4 pesticides listed above.
BUT THERE IS A PROBLEM?
Indian law is about final product

PFA regulates the quality of final product in
Appendix B (A.01.01).
PFA also says that contaminants (pesticides) from
raw material cannot be carried forward to the final
product.
Part XI A (Crop contaminants): defines pesticides
as contaminants.
Part XIII A (Carry over of food additives):
categorically states that contaminants cannot be
carried over from raw material to final product.
In other words, if there are contaminants in any raw
material (say sugar), manufacturers have to clean it
up in the final product.
Soft drink standards in light of the

PFA provisions
There cannot be any carry forward of

pesticides to soft drinks from agricultural
ingredients.
Therefore, soft drinks will have to meet the

existing packaged drinking water
standards.
o Individual pesticides: 0.0001 mg/l
o Total pesticide: 0.0005 mg/l
JPC recommendations on
pesticide standards:
Water used in the manufacture of soft drinks
must conform with bottle water norms.
Sugar is not the likely source of contamination.
Also soft drink manufacturers mentioned
before JPC that they have foolproof process
to select and treat sugar from contaminants.
Set final product standards. The reason that
others have not fixed should not dissuade our
law makers
Caffeine in soft drinks

Caffeine consumption linked with diseases and
disorders such as insomnia, nervousness, anxiety,
irritability, and deviations from the normal heart
rate.
World regulates caffeine in food for this reason.
Cannot compare caffeine in soft

drinks with tea and coffee
Globally caffeine in tea and coffee is never
compared with caffeine in soft drinks because of
the natural speciation of caffeine with tea and
coffee, as is the case of natural speciation of
metals and acids in fruits (iron is apple, citric acid
in lemon and oranges etc).
Caffeine is soft drinks is artificially added.
there are no standards for caffeine in tea and
coffee, but there are standards for caffeine in soft
drinks.
Caffeine in soft drinks

Globally caffeine only permitted in cola dinks (China,
Canada, Australia, South Africa, Holland, Spain etc.).
Allowed till 150 mg/l. Or caffeine-free versions sold.
PFA makes no such distinction. Allows 200 mg/l in all.
Result: In India, caffeine added even in non-cola drinks
like PepsiCos Mountain Dew.
Harmful for children, pregnant and lactating women.
Caffeine is addictive.
We cannot allow caffeine in non-cola.
Caffeine standard must be similar to global best
norms.
We also need clear warning labels if caffeine added.
Labels needed in regional languages.
JPC recommendations on caffeine

Lower limit from 200 ppm (200 mg/litre) to the
global best standard.
Ask for non-caffeinated versions of caffeinated
drinks
If above than standard, then label should have
health advisory:
The beverage is not recommended for:
Children
Pregnant or lactating women
Individuals sensitive to caffeine
Regulate pH (acidity)
Lower pH means high acidity in the body. Regulations
for pH do not exist in India. Only South Africa regulates
pH at 2.5.
Non-regulation of interest to companies because low
pH gives longer shelf-life. pH regulation needed.
Wate r
M ilk
Be er
Nimbu Pani
M ango Juice
Orange Juice
Apple Juice
Wine
Lime
Soft Drinks
Hydrochloric
Sulphuric Acid
0
10
12
14
What has happened after JPC: BIS

BIS has revised its existing soft drink standards and
released it for public comment till August 31.
BIS multi-stakeholder committee considered all issues.
Agreed on final product standards for pesticide
residues in soft drinks.
Committee discussed contamination through sugar
and agreed with JPC recommendations.
Followed the existing provisions of PFA that carry
forward is not allowed .
Agreed on: 0.0001 ppm (single pesticide)
0.0005 ppm (total pesticides)

Bought down caffeine from 200 to 145 mg/l and
regulated pH between 2.3 8.5.
What has happened after JPC:

Ministry of Health
Ministry of Health and Family Welfare issued
notification to the effect that the water to be
used in manufacturing soft drink should meet
packaged drinking water standard.
Has set-up a committee to look at final product
standard.
These standards will be mandatory.

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Session 2

Existing soft drink standards in

Existing soft drink standards

Centre for Science and Environment

Standards for pesticide residues in

Centre for Science and Environment

Difference in results: CSE lab vs.

Differences in result: JPC verdict

Centre for Science and Environment

Are soft drinks safe?

Safety not about large numbers

Politics of clubbing of soft drinks and

Take heavy metal norms:

Distinct category exists

Separate standard for other water based beverages:

Clubbing juices and soft drinks: a

2. Should we set standards for

Heavy metals etc.

Ice cream (even

Globally no country has set pesticide standards for

Above MRL (1.4%)

Above MRL (4.8%)

Centre for Science and Environment

Out side System works.

US: 6,523 samples tested and 4% failed;

They do not regulate pesticides in

How do we set standard for

Centre for Science and Environment

(10% of sugar MRL) + (1% of other MRL) + (89% of water MRL)

Calculate norms for soft drinks as

No standard-no residue principle

Pollution Monitoring Laboratory

Centre for Science and Environment

Pollution Monitoring Laboratory

Centre for Science and Environment

Are soft drinks safe?

100% of CFL/CFTRI/CSE/CPCB samples fail BIS

Are soft drinks safe?

100% of CFL/CFTRI results fail BIS norm

Are soft drinks safe?

100% of CFL/CFTRI results fail BIS norm

Are soft drinks safe?

100% of CFL/CFTRI/CSE/CPCB samples fail USEPA

Are soft drinks safe?

100% of all results fail USEPA norm

And obviously all results fail packaged drinking

Soft drinks not safe

Centre for Science and Environment

What should be the soft drink

What should be the soft drink

BIS bottle water standard/ MRLs of sugar cane and hence

Centre for Science and Environment

Soft drink standard using global

Atrazin 0.025 mg/l

Indian law is about final product

Soft drink standards in light of the

There cannot be any carry forward of

Therefore, soft drinks will have to meet the

Centre for Science and Environment

Centre for Science and Environment

Caffeine in soft drinks

Centre for Science and Environment

Cannot compare caffeine in soft

Caffeine in soft drinks