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SRO 237: Enforce it!

By Erum Noor Muzaffar
06 November, 2023

Staying healthy has never been so important as the need to remain in good health can have a positive effect on almost every aspect of our lives. Healthy living means maintaining a healthy lifestyle and introducing habits that improve your health. When we look after our physical health, we feel better, relaxed and be able to cope with stress.

SRO 237: Enforce it!

Staying healthy has never been so important as the need to remain in good health can have a positive effect on almost every aspect of our lives. Healthy living means maintaining a healthy lifestyle and introducing habits that improve your health. When we look after our physical health, we feel better, relaxed and be able to cope with stress.

Women and children’s health are critically important because if women are healthy, they have healthy babies, and healthy babies and children grow up to be healthy adults. In other words, the health of women and children is vital to creating a healthy world.

Staying healthy can be done in a variety of ways, including eating healthy food along with plenty of fruits and vegetables. People get the vitamins, minerals and nutrients they need to function and thrive from the foods they eat, so choosing foods that offer the most of those components helps improve quality of life. However, when buying food items, it is essential to carefully read the labels.

Many a time when we buy any food items, we end up buying those which have crossed their expiry date. These dates are important since they indicate how long food can be kept before it begins to deteriorate or may become unsafe to eat. Take note of dates that say use by or ‘exp’ – expiry date – they’re labelled that way for a reason. They’re not safe to eat beyond that date and definitely should be thrown out. Foodstuffs that have gone beyond expiration date may cause severe irritation and infections including physical discomfort such as stomach upset which might or might not be accompanied by vomiting. It is true that food contamination and bad bacteria can cause food poisoning too. It’s especially dangerous for people, especially women and children, with chronic illnesses, like diabetes or history of heart disease, and seniors, all who may have weaker immune systems that can fight off dangerous bacteria. Checking the expiry date is very important and; it saves you from buying products that are expired. It can also prevent you from putting your health at risk as a result of consuming expired products.

With a view to exercise healthy practices and to ban the smuggled or expired food items, the government of Pakistan through Federal Bureau of Revenue (FBR) enacted a Special Regulatory Order (SRO) 237 in February 2019. It bans the import of processed food products without labelling in local language and halal certification - making it mandatory for all importable food products to have halal certification and labelling in Urdu. Some of the salient features of SRO 237 are:

- The requirements apply to all food and beverage products.

- Labelling of nutritional values and usage instructions must appear in Urdu and English.

- Labelling must be printed directly on consumer packaging. Stickering, overprinting, stamping or scratching of labels in market is not permitted.

- Products must have two-thirds of the shelf-life remaining on the date of import or all food products imported from abroad should have 66 per cent of shelf life at the time of import.

- Products requiring halal certification must be issued by a member of either the International Halal Accreditation Forum (IHAF) or Standards Metrology Institute for Islamic Countries (SMIIC).

There is no doubt that government’s intention is clear and it wants people to buy healthy food, unfortunately, most traders and importers are involved in malpractice. The majority of the products, that are available on shelves for consumers, are not compliant to the requirements of SRO 237. So far, the government has not been able to effectively implemented SRO and curbing the menace of smuggling or illegal trade.

It is astonishing to note that Pakistan is losing US$ 2.63 Billion per year due to smuggling. Total value of smuggling-prone food items stands at US$ 9 billion which is equivalent to around 3 per cent of the Gross Domestic Product (GDP) of the country, according to 2022 research report published by Lahore Chamber of Commerce & Industry. Sadly, this parallel trade is causing losses to the national exchequer in billions as these products are neither duty paid, nor GST on retail level.

Food items being smuggled through grey channels lack compliance for local food regulations and violate the rules enumerated in SRO 237. They have design infringements, as they don’t follow local labelling guidelines and have anomalies in listing ingredients in foreign language and not in local language, incorrect or unauthenticated nutrition value, dubious halaal certification – all of which pose food safety risks for local consumers. There is also no certainty whether the expiry date listed is genuine, as these products lack traceability, have doubtful freshness or shelf life, since there is no local ownership and hence no registration with local food authority. Consumers are lacking clarity or trust on quality of products and may consume substandard items, counterfeit brands, with incorrect information of ingredients due to labelling anomalies, short shelf life, high probability of changed date of expiries or short expiry, lack of clarity on whether the product is genuinely halal compliant and certified. Food items are also imported through supply chain not suitable for food transportation, exposed to unsuitable temperatures and unhygienic conditions.

Food companies, trade bodies, industry associations, and leading local and multinationals having strong local footprint in the packaged food manufacturers, have repeatedly demanded the government, Federal Board of Revenue, Customs Directorate, and respective provincial food authorities and law enforcement agencies to clamp down on these grey channels to protect consumers, prioritise their health, save loss of revenue to the government exchequer and promote businesses through documented sector. While this issue was pertinent earlier in pockets of Balochistan and some parts of Karachi, those engaged in grey trade have expanded their outreach to retail stores in Islamabad, Lahore and other major cities.

Now, the government has finally decided to clamp down on grey trade by tightening the borders in order to enforce strict implementation of SRO 237 both at federal and provincial levels.

It is important to take some strict measures now as most local manufacturers’ businesses are severely impacted due to decline in sales and hence loss of revenue for the government in terms of indirect taxation. Since they are legitimate and registered businesses regulated by laws of Pakistan, they comply with all health, quality and labelling standards set by provincial food authorities bearing additional costs. Moreover, multinationals that have large local manufacturing footprint also introduce special category of brands to test market by importing their products from their foreign counterparts in other countries legally, ensure 100 per cent compliant to the local regulatory requirement of standards. These include labelling with ingredients in local language, ensuring that shelf life is up to local standards etc. However, due to porous borders, unhindered import channels, non-compliant products pave way to local retail markets, resulting in declining volumes, higher cost of compliances and eventually loss of duties for the government.

There is a major need for all federal and provincial food authorities including Punjab Food Authority; Sindh Food Authority and PSQCA, and provincial law enforcement to coordinate with interior ministries to mobilise their institutions such as border security forces, customs intelligence to conduct raids on borders and warehouses. FIA needs to enforce Intellectual Property Rights violation through rigorous prosecution on counterfeit products and it should be mandatory for provincial food authorities to raid retail sector to deter local retailers and wholesalers from stocking smuggled products.

All in all, for one’s own safety and health, one has to make sure that the product has an expiring date. Foods that have passed its expiry date have no nutritional value. Traders at times tend to rub off the label of the expiry date. If there is no expiry or manufacturing date, then you are better off not buying the product. Reading the product label can save one, especially women and children, from future health problems.


The write is a staff member