Tea is part of everyday life in India and an important agricultural and commercial product. Before reaching consumers, it may pass through growers, processors, traders, blending units, packaging businesses and retailers. Maintaining food safety throughout this journey requires responsible cultivation practices, reliable testing and clear supply-chain records.
The Food Safety and Standards Authority of India (FSSAI) has proposed Maximum Residue Limits for Acetamiprid and Imidacloprid in tea under the draft Food Safety and Standards (Contaminants, Toxins and Residues) Amendment Regulations, 2026. The announcement, communicated on 17 October 2026, is relevant to businesses involved in tea cultivation, processing, procurement, packaging and export. The limits remain proposals subject to finalisation. Businesses should distinguish the draft announcement from an operative legal requirement.
What Has FSSAI Proposed for Pesticide Residues in Tea?
Proposed limit for Acetamiprid
The draft amendment proposes a Maximum Residue Limit of 20 milligrams per kilogram for Acetamiprid in tea, equivalent to 20 parts per million. This figure concerns the concentration of pesticide residue measured in the specified commodity. It should not be interpreted as a recommended pesticide application rate. Agricultural application instructions and food residue limits serve different purposes. Growers must assess pesticide use against the relevant authorisations and agricultural requirements.
Proposed limit for Imidacloprid
For Imidacloprid, the draft proposes a Maximum Residue Limit of 50 milligrams per kilogram in tea, equivalent to 50 parts per million. The proposed figures are intended to establish defined benchmarks for monitoring and assessing residues. Businesses should follow the regulatory process and review the final amendment, including its scope and implementation provisions, before treating these values as applicable compliance limits.
What Is a Maximum Residue Limit?
Meaning of pesticide residue
Pesticide residue refers to substances that may remain in or on a commodity following pesticide use. Laboratory analysis helps identify and measure the substances covered by the relevant testing method. A cultivation record and a laboratory report provide different information. The cultivation record describes pesticide application, while the laboratory report describes the results obtained from a particular sample. A useful compliance system connects both types of evidence.
Purpose of an MRL
A Maximum Residue Limit, commonly called an MRL, is the maximum concentration of a pesticide residue legally permitted in or on a specified food or feed commodity under the relevant framework. It is generally expressed in milligrams per kilogram. MRLs provide measurable benchmarks for compliance assessment. Their development considers Good Agricultural Practice and supporting scientific assessments. They are not instructions to add pesticides to food or targets that businesses should aim to reach.
Why Is the Draft Status Important?
A draft does not automatically change existing requirements
Regulatory announcements may concern consultation drafts, final notifications or implementation dates. Each stage has a different legal significance. Businesses should therefore describe these figures as proposed limits until the amendment is finalised and becomes applicable. Existing requirements continue to need attention while the proposal moves through the regulatory process.
Businesses can prepare without assuming finalisation
The consultation stage gives businesses time to review their operational readiness. Procurement specifications, testing coverage and supplier documentation can be examined before a final amendment is issued. For example, a tea manufacturer can check whether its laboratory testing panel includes both pesticides. This is a practical preparation measure, even though the proposed values should not yet replace operative benchmarks.
Why Pesticide Residue Management Matters for the Tea Industry
Managing a supply chain involving several businesses
Tea may move through multiple organisations before being packaged for sale. Different suppliers may contribute material to a processing batch or blend, making identification and documentation important. If supplier references, production records and laboratory reports are disconnected, investigating an unexpected result becomes difficult. Businesses benefit from systems that allow material to be traced through procurement, processing and dispatch.
Connecting purchasing decisions with food safety evidence
Procurement teams should understand what evidence supports the acceptance of tea consignments. Quality teams should be able to explain the significance and limitations of the available test reports. This coordination helps prevent situations in which material is purchased using one specification but evaluated against another. Clear responsibility for approving suppliers and reviewing exceptions can improve consistency.
Responsible Crop Protection and Residue Control
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Following relevant agricultural requirements: Residue management begins during cultivation. Growers should review applicable pesticide authorisations, instructions and current crop-protection guidance when deciding how products are used. The existence of a proposed MRL does not independently authorise pesticide use on tea. Businesses must distinguish permission to use a crop-protection product from the residue standard applied to the resulting commodity.
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Maintaining application records: As a practical control, growers can maintain records identifying the product used, application date, field location, responsible person and relevant harvesting information. These records should be usable during an investigation. If a particular consignment produces an unexpected laboratory result, the business should be able to examine its cultivation history and identify areas requiring further review.
Implications for Tea Growers and Estates
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Reviewing field-level practices: Growers can use the proposed amendment as an opportunity to assess how crop-protection decisions are communicated and recorded. Instructions should be understood by the people carrying out applications. A review may identify gaps such as incomplete records, inconsistent product descriptions or difficulty connecting harvested material to a field. Addressing these weaknesses can improve traceability.
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Communicating with purchasers: Processors and buyers may request information about cultivation practices and supporting records. Providing consistent information can help purchasers assess their sourcing arrangements. Growers should avoid making broad assurances that cannot be supported. Clear explanations of the available records are more useful than general statements about product safety.
Implications for Tea Processors and Manufacturers
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Identifying incoming material: Processors should examine whether incoming tea remains identifiable during manufacturing. Where several suppliers contribute material to a production run, the business should understand how it would investigate a supplier-related concern. A practical exercise is to select one finished batch and trace it back through the records. This can reveal missing links before an actual problem arises.
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Defining acceptance and escalation procedures: Businesses can establish procedures identifying who reviews incoming documentation, who approves material and who handles exceptions. An unexpected result should trigger a structured assessment. The procedure should explain how relevant material is identified, what additional information is needed and who can decide the next step.
Implications for Packers and Brand Owners
Strengthening supplier specifications
Brand owners can review whether purchase specifications clearly describe their expectations. Relevant requirements may include agreed testing parameters, batch identification and the supporting information suppliers must provide. Specifications should distinguish existing legal requirements from proposed changes. Once final provisions become applicable, updates should be communicated through a controlled process.
Reviewing supplier assurances
A supplier declaration can form part of a documentation system, but its wording should be examined carefully. A broad statement of compliance may not explain what was tested or which consignment was assessed. Brand owners can request more specific information where appropriate and ensure that the available evidence matches their procurement decisions.
Laboratory Testing and Report Review
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Checking the scope of analysis: Businesses should confirm whether the laboratory can test the relevant substances in the specified tea sample. The testing panel, method and reporting capability should match the intended assessment. A report should not be treated as comprehensive merely because it is described as a pesticide residue report. Its actual coverage must be checked.
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Checking units and sample details: The reporting units should be understood before comparing results. Milligrams per kilogram and parts per million are equivalent by mass, but comparisons must still use the correct commodity and residue definition. Sample descriptions, dates and batch references should also be checked. These details help establish which material the report represents.
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Understanding the limits of a report: A laboratory report relates to the sample tested. A report from an earlier shipment should not automatically be assumed to represent every later delivery from the same supplier. Businesses should decide how testing fits into their broader supplier assessment and monitoring arrangements rather than relying on isolated documents.
Considerations for Tea Exporters
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Reviewing destination-market requirements: Exporters should assess residue requirements for each intended destination. Meeting an Indian requirement does not automatically establish compliance with every importing country’s rules. Buyer contracts may also include specifications that need separate attention. Export planning should therefore identify the destination and commercial requirements before testing and dispatch.
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Aligning testing with the transaction: The exporter can confirm the necessary analytical panel, reporting limits and documentary evidence for the particular shipment. This approach is more reliable than arranging a general test and later discovering that it does not cover the purchaser’s requirements.
Practical Steps Businesses Can Take Now
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Review procurement documents: Businesses can check whether procurement specifications accurately identify the product, applicable standards and agreed evidence. Draft proposals should be labelled clearly. Any future changes should be issued consistently so that suppliers, purchasing teams and quality personnel work from the same version.
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Organise traceability records: Supplier details, purchase documents, production references and test reports should be easy to retrieve. The system should work even when the employee who normally handles it is unavailable. Where material is blended, the records should identify the contributing sources and relevant quantities.
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Assign regulatory monitoring responsibilities: A designated person or team should monitor developments and communicate verified changes internally. The monitoring record should distinguish a proposal from a final amendment and identify any implementation date. This reduces the risk of different departments acting on incomplete or outdated information.
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Consider stakeholder representations: Businesses wishing to submit comments should examine the actual draft notification for the consultation period and submission instructions. Representations are more useful when they identify a specific provision and explain the issue using relevant technical evidence or operational experience.
What Does the Proposal Mean for Consumers?
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Avoiding broad assumptions: The announcement concerns proposed residue benchmarks. It does not establish that every tea product contains either pesticide or that every product presents a safety concern. Claims about individual products should be based on relevant evidence. A regulatory proposal alone cannot establish the condition of a particular packet or consignment.
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Understanding compliance and risk assessment: Residue compliance and health risk assessment are connected but distinct matters. Scientific assessment considers exposure and other relevant factors. Businesses should communicate carefully and avoid using a single figure to make unsupported claims about safety or harm.
Conclusion
FSSAI’s proposed residue limits for Acetamiprid and Imidacloprid in tea highlight the importance of responsible cultivation, relevant testing and reliable supply-chain records. Businesses should track the proposal through to finalisation and review the final provisions before changing their legal compliance benchmarks.
The draft stage offers an opportunity to improve preparedness. Clear supplier specifications, traceable batches, organised reports and defined responsibilities can help growers, processors, brands and exporters respond effectively when applicable requirements change.
Need Help with Tea Export Registration or Food Safety Compliance?
Planning to manufacture, package or export tea from India? Compliance Calendar LLP can help you understand the requirements for Tea Board Registration, IEC Registration, FSSAI Registration and other applicable export compliances. Our team can guide you through registration requirements, assist with documentation and help you understand regulatory updates relevant to your business.
Whether you are starting a tea business or expanding into international markets, we can help you identify the registrations and compliance requirements applicable to your activities.
Get in touch with Compliance Calendar LLP today!
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Frequently Asked Questions (FAQ’s)
Q1. What residue limits has FSSAI proposed for tea?
Ans. The draft proposes 20 mg/kg for Acetamiprid and 50 mg/kg for Imidacloprid in tea. These figures remain subject to finalisation.
Q2. Are mg/kg and ppm equivalent?
Ans. Yes. One milligram per kilogram is equivalent to one part per million by mass.
Q3. Does an MRL prescribe how much pesticide farmers should spray?
Ans. No. An MRL concerns residue concentration in the specified commodity. Pesticide application must follow the relevant authorisations and instructions.
Q4. Should businesses immediately adopt the proposed limits as law?
Ans. No. Businesses should continue following applicable requirements and monitor the final amendment and its implementation provisions.
Q5. What preparation can businesses undertake now?
Ans. They can review supplier specifications, traceability records, testing coverage and responsibility for monitoring regulatory updates. These are preparation measures rather than new obligations created by the draft.
Q6. Does compliance with Indian requirements automatically satisfy export requirements?
Ans. No. Exporters should separately examine destination-market rules and contractual buyer specifications.
Q7. Does the announcement mean all tea is unsafe?
Ans. No. The proposal establishes neither the residue content nor the safety status of every tea product. Product-specific conclusions require relevant evidence.
Q8. What are FSSAI’s proposed pesticide residue limits for tea in 2026?
Ans. FSSAI has proposed limits of 20 mg/kg for Acetamiprid and 50 mg/kg for Imidacloprid in tea, subject to finalisation.
Q9. Are the proposed tea residue limits already applicable?
Ans. No. These limits form part of a draft amendment. Businesses should continue following existing applicable requirements until the final provisions take effect.
Q10. How can tea businesses prepare for the proposed changes?
Ans. Businesses can review supplier records, batch traceability and laboratory testing coverage while monitoring the final notification and its implementation requirements.
Article last updated on : 19 Oct 2026.
