A technical regulatory notice issued by India's Central Insecticides Board and Registration Committee (CIB&RC) in April 2026 has drawn sharp criticism from public health advocates and farmers' organizations, who warn that proposed relaxations in pesticide residue testing could compromise food safety and public health. The notice invites comments on recommendations from the Scientific Panel on Pesticide Residue (SPPR) under FSSAI, proposing the adoption of a "Crop Grouping" framework for setting Maximum Residue Limits (MRLs)—the legal ceiling on pesticide residues permitted on food crops.
The crop grouping approach, modelled on internationally recognised methodologies used by the OECD, US EPA, and EU, allows regulators to extrapolate MRLs from a single "representative" crop to an entire group of related crops without separately testing each of them. While intended to reduce costs and speed up approvals, the proposal has raised alarm over its potential impact in India's context. The notice suggests that only four of the required eight location data points must come from the representative crop, with the remaining four drawn from any member crop in the group. Additionally, the proposal permits a dose variation of up to 25 percent without requiring fresh residue data.
Public policy expert Dr. Narasimha Reddy Donthi, submitting comments on behalf of farmers and consumers through the Maharashtra Association of Pesticide Poisoned Persons, has articulated serious concerns in a detailed letter to the CIB&RC Secretary. "Our concern is that the proposed relaxations, as summarised in the notice, reduce the residue-trial data burden for MRL extrapolation without adequate accompanying safeguards for public health, farm-worker safety, and environmental protection," Dr. Donthi wrote. "We therefore urge CIB&RC to adopt stricter conditions than currently proposed, and to address the procedural gaps set out below before this document is finalised."
The concerns are grounded in India's agricultural realities. Government data shows that cropping patterns have become progressively skewed toward a handful of dominant crops, with cotton and sugarcane expanding significantly while rice-wheat monoculture dominates north-west India. This regional concentration means that pesticide application and dietary exposure concentrate on a small number of crops—something a "worst-case representative crop, tested once" model does not adequately address.
Recent monitoring data reveals that pesticide residue non-compliance is already significant. Under FSSAI's National Annual Surveillance Plan, 86,401 food samples tested in 2022-25 showed 2.8 percent exceeding MRLs. A separate study of over 12,800 vegetable samples found pesticide residues in 18.7 percent of samples, with 13.3 percent containing residues of pesticides not even approved for that use. Fruit samples showed residues in 21.7 percent of samples. These figures raise questions about what happens to compliance once pre-approval testing requirements are reduced.
Field practice in India frequently departs from tested protocols. States have been known to recommend pesticides never registered for a given crop, and smallholders often base their practices on informal advice rather than label instructions. Extrapolating lab-controlled trials to real-world conditions, the document argues, is a bigger leap in India than in systems with tighter compliance.
The human cost of pesticide regulation failures is already high. A global study estimated 6,600 farmer deaths per year in India from unintentional acute pesticide poisoning—around 60 percent of the global total. The 2017 Yavatmal tragedy, where farm workers spraying cotton fields fell fatally ill, highlighted gaps in registration, labelling, and enforcement. Dr. Donthi noted that "India's pesticide regulatory chain—registration, labelling, field practice, enforcement, residue monitoring—already has weak links. Adding a data-relaxation measure at the registration stage, without strengthening monitoring at the other end, widens rather than narrows the gap."
Dr. Donthi's letter makes several specific requests. It calls for a minimum of six out of eight data points to come from the representative crop, especially for staple foods and crops consumed by children. It demands transparent, verifiable "worst-case" criteria for selecting the representative crop and requires that trials be conducted across India's actual agro-climatic zones rather than relying on OECD reference data. The letter also seeks to tighten the 25 percent dose-variation tolerance and requires cumulative dietary exposure assessment across crop groups, particularly in monocropping-heavy regions.
For minor crops, spices, herbs, tea, and apple, the letter requests that the existing four-location-one-season requirement not be further diluted. It also asks that any relaxation be conditioned on mandatory post-marketing residue monitoring, with results made public, and that CIB&RC disclose its current monitoring capacity before reducing pre-approval requirements.
On procedural grounds, Dr. Donthi has requested an extension of the 15-day comment window to at least 60 days, publication of the full crop grouping document and SPPR's scientific rationale, public disclosure of meeting minutes, and a public hearing with stakeholder participation. The letter also asks that all comments received, along with CIB&RC's reasoned responses, be published before final adoption of the framework.
The Registration Committee, at its 468th meeting on 12 January 2026, did not approve the proposal outright but directed the Secretary to seek comments first. While crop grouping itself is not inherently problematic, the dispute centres on implementation rigour and whether India's specific conditions—deep monocropping, agro-climatic diversity, gaps between label and field practice, and thin post-market monitoring—are built into the framework or simply assumed away.
"We recognise that crop grouping is an internationally used methodology and that testing every crop individually is not always feasible," Dr. Donthi concluded. "However, given the scale of monocropping in Indian agriculture, the diversity of Indian agro-climatic zones and field-application practices, and the limits of current post-market residue surveillance, we are concerned that adopting this framework without the safeguards outlined above would function less as a scientifically validated efficiency measure and more as a means of reducing regulatory testing and accountability burdens, with the residual risk borne by farmers, farm workers, and consumers."
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