The New Indian MRL Consultation Makes Multi-Destination Batch Allocation More Important

Limits and risk

This is an operational analysis prompted by the consultation. It does not establish a new legal requirement or determine whether a particular batch complies.

What changed

The October FSSAI consultation concerns two named pesticide limits in tea and remains subject to finalisation and stakeholder review.

HOUTU TEA market reading

A supplier serving several destinations needs to know which batch can satisfy which order. HOUTU TEA's practical reading is that regulatory change increases the value of a clear batch-allocation process. A certificate suitable for one customer may not answer the requirements of another, even when the tea has the same grade name and was manufactured at the same factory.

Procurement decision

Build an order matrix linking the destination, buyer specification, sampled lot and approved laboratory scope. Keep retested or repacked lots traceable to the final shipment. Confirm that a proposed substitution has the same documentary coverage before moving it into another customer's order. Purchasing and quality teams should use the same approved version of the specification, with changes recorded rather than passed informally.

Buyer action checklist

• Map batches to destinations
• Version-control specifications
• Check substitutions before allocation
• Link final packs to test records

Illustrative order scenario - not an actual transaction

A factory allocating one production run across two customers could verify each order against its own approved limits. If one lot lacks the required analysis, it would remain unallocated until the evidence is complete.