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ADVOCACY @ RAI – Retailers Association of India (RAI)

ADVOCACY @ RAI

In its role as being created “for the industry, by the Industry”, RAI’s advocacy team regularly represents members concerns to government authorities. STORAI profiles and updates on key ongoing advocacy initiatives.

Election Manifesto 2014

01RAI has submitted Election Manifesto to major political parties. RAI proposed that in order to put India back on track of high and sustainable growth, priority attention should be given to sectors and issues where initiatives can be taken without the requirement of major investments and time lag before the results are visible .This should be done without neglecting the medium and long term measures to realize the full potential of the Indian entrepreneurship and its economy. Hence, due attention must be given to the internal trade and retail sector keeping in mind the following objectives:

  • To bring the farmer, and the consumer closer so as to make available to the common man his daily necessities at a reasonable price and ensuring remunerative returns to farmers.
  • To make SMEs more internationally competitive by smoothening internal trade and movement of goods by reviewing and removing all obsolete and redundant statutory rules and procedures.
  • Seamless movement of goods and services across the country.
  • To facilitate creation of job opportunities for the youth, particularly the women, by necessary skill formation in all parts of the country and by evolving a suitable Public Private Partnership (PPP) model.

For achieving the above stated benefits and to have a planned and focused growth plan, we have submitted pointers for a draft National Retail Policy.

Plastic Carry Bags Advocacy

02In line with the Government notification, RAI had started an initiative amongst its members to charge customers for the plastic carry bags. This initiative started in Mumbai from 1st July 2011 and is now an all India in scope.

Polluter –Pay-Principle is working.  The biggest negative impact of usage of plastic carry bags had been its indiscriminate disposal – leading to environmental harm. Media reports suggest that some of the impact of 26/7 Mumbai floods was due to plastic covers clogging the Mithi River. The initiative of charging customers for the plastic carry bags has helped reduce environmental load. As per available data, consumption of plastic bags by retailers has dropped by over 60%.

Green Retail Project

03RAI along with CII – ITC Center of Excellence for Sustainable Development and other technical partners is working on the Green Retail Project project to incorporate sustainable best practices across the value chain from store level operations to suppliers, logistics and consumers thereby increasing resource efficiency. Such optimization aims to bring down operation cost while helping the environment.

The project is in the pilot stage and working with four retailers in the food and beverage sector. Currently, project partners are visiting the stores of pilot retailers and collecting data such as energy consumption, water usage and waste generation for baseline assessment.

(For more: www.switch-greenretail.in)

Packaged commodities rules

04RAI represented to the Legal Metrology Department that since the responsibility of labelling is of the manufacturer/packer, it is not right to penalize a retailer with similar penalties as applicable to the manufacturer. The retailer’s role is to stock and to make goods visible and available to consumers. Moreover, modern retailers stock thousands of SKU units making it practically impossible to check for compliance in each and every product.

RAI recommended that State should adopt a practical approach towards the implementation of the act and should exclude these items from the ambit of the Legal Metrology Act as these commodities are not packed.

The Legal Metrology Act lays down that the compounding fee shall not be more than the maximum amount of fine for the relevant violation / deviation. We recommended that compounding fee for different deviations should be administratively laid down for staff of the Department, so that there is no arbitrariness in this matter.

Treatment of Household insecticides

05RAI had represented to the Insecticide board that household insecticides are very different compared to other commercial and industrial insecticides and are not as harmful to humans unless used incorrectly and do not pose the same health threats.

Hence, they should be differently treated by easing the severe punishment on non-compliance.

RAI representatives met Shri Avinash K. Srivastava (Additional Secretary, Ministry of Agriculture), Shri Utpal Kumar Singh (Joint Secretary, Ministry of Agriculture) and Mrs. Vandana Jain (Director-PP, Ministry of Agriculture).  Ministry of Agriculture officials suggested us to submit a representation giving specific examples wherein retailers were penalized with regards to the issues raised. We are in process of collecting this information and compiling it.

Food Safety Rules

06The Food Safety & Standards Act 2006 and Regulations 2011 had certain anomalies and RAI submitted a representation to FSSAI to get better clarity in the provisions of the Act.

The Act stated that if a retailer operates in two or more states, it needs to obtain a central license and the local license from the place where it operates. Retailers operate in numerous states and it is a tedious job to obtain multiple licenses. RAI recommended that there should be a Central registration number and specific state licenses should be issued under this registration number which simplifies the procedure.

The rules also state that food products should be bought only from registered vendors. But retailers procure from many vendors and majority of them are SMEs and scattered. It is impractical to expect such SMEs to comply with the licensing requirements. Moreover, for SMEs in many of the states, the nominated local authorities do not have the license / registration process in place yet. Hence, we recommended that an `applied for’ receipt / acknowledgement should suffice and be considered by FSSAI.

The FSSA regulations require the Food Business Operators (FBOs) to file annual returns in respect of each class of food products handled by them within 31st May, of every year for the period April 1st to March 31st. RAI represented that as there are thousands of food SKUs being sold by retail stores from a huge number of outlets all across the country, only the manufacturers/packers should be made liable to file returns.

FSSAI confirmed that the rule to file returns by May 31st of every year is applicable only to manufacturers/packers.

We are awaiting a written confirmation in this regard.

Store Opening: License to operate stores 365 days a year

07RAI submits representations to various state governments where the members faced major challenges in getting license for operating stores 365 days a year.

The Madhya Pradesh government agreed to our request and issued a notification that RAI members can open their stores 365 days in a year.

The Maharashtra government also simplified the procedure for 365 days licenses post our representation.

In the new procedure to obtain 365 days working license in Maharashtra, the application for 365 days permission shall directly submit to Labour Secretary. The new procedure eliminates the requirement to route the application through Labour Commissioner or Brihanmumbai Municipal Corporation (BMC). Also, Inspection is not required and licenses can be issued on the basis of self declaration made by the retailers.

We have submitted representations to others state governments like Andhra Pradesh and Assam and await their response.

Retail Policy for the state of Maharashtra:

08The Government of Maharashtra has directed RAI to help the Government to draft a retail policy for the state of Maharashtra. The policy will be based on concerns/problems faced by the retailers and the probable solutions. The detailed recommendations were submitted to the Principal Secretary of Industries, Maharashtra – Shri. Apurva Chandra for the following matters:

  • Issues relating to opening stores 365 days a year
  • Need to make packaged commodities rules more pragmatic in implementation
  • Issues related to low stocking limits of essential commodities
  • Open access to electricity
  • Policy for urban development & zoning of retail sector

Over the past few months we had various meetings with the government including Shri. Prithviraj Chauhan, Chief Minister, Maharashtra, Shri. Ashish Kumar Singh, Principal Secretary, Chief Minister’s Office and Shri. Apurva Chandra, Principal Secretary, Industries, Maharashtra and received positive results from the meetings.


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