Required Report - public distribution

**Date:** 08/05/2008

**GAIN Report Number:** PK8027

PK8028

**Pakistan**

**FAIRS Country Report**

**Annual**

**2008**

**Approved by:**

Margaret E. Thursland

![](media/image1.wmf)Agricultural Counselor

U.S. Embassy Islamabad

**Prepared by:**

Asmat Raza

Senior Agricultural Specialist

**Report Highlights:**

Sections Updated: Sections I, III, V, and VIII.

The Pakistan Pure Food Laws (PFL) of 1963 are the basis of the existing
trade-related food quality and safety legislative framework. They cover
104 food items falling into nine broad categories. These regulations
address purity issues in raw food and deal with subjects associated with
additives, food preservatives, food and synthetic colors, antioxidants,
and heavy metals. Pakistan adheres to the Harmonized Coding System for
classification of imported goods. Food labeling and packaging
requirements are enforced.

Includes PSD Changes: No

Includes Trade Matrix: No

Annual Report

Islamabad \[PK1\]

\[PK\]

Table of Contents

[Section I: Food Laws 3](#section-i-food-laws)

[Section II: Labeling Requirements 4](#section-ii-labeling-requirements)

[Section III: Packaging and Container Requirements
5](#section-iii-packaging-and-container-requirements)

[Section IV: Food Additive Regulations
6](#section-iv-food-additive-regulations)

[Section V: Pesticides and Other Contaminants
6](#section-v-pesticides-and-other-contaminants)

[Section VI: Other Regulations and Requirements
6](#section-vi-other-regulations-and-requirements)

[Section VII: Other Specific Standards
7](#section-vii-other-specific-standards)

[Section VIII: Copyright and/or Trademark Laws
8](#section-viii-copyright-andor-trademark-laws)

[Section IX: Import Procedures 8](#section-ix-import-procedures)

[Appendix I: Government Regulatory Agencies contacts
9](#appendix-i-government-regulatory-agencies-contacts)

[Appendix II: Government Regulatory Agencies contacts
9](#appendix-ii-government-regulatory-agencies-contacts)

# **Disclaimer:** This report was prepared by the Office of Agricultural Affairs of the USDA/Foreign Agricultural Service in Islamabad Pakistan for U.S. exporters of domestic food and agricultural products. While every possible care was taken in the preparation of this report, information provided may not be completely accurate either because policies have changed since its preparation, or because clear and consistent information about these policies was not available. It is highly recommended that U.S. exporters verify the full set of import requirements with their foreign customers, who are normally best equipped to research such matters with local authorities, before any goods are shipped. FINAL IMPORT APPROVAL OF ANY PRODUCT IS SUBJECT TO THE IMPORTING COUNTRY\'S RULES AND REGULATIONS AS INTERPRETED BY BORDER OFFICIALS AT THE TIME OF PRODUCT ENTRY.  

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# **Section I: Food Laws**

# In Pakistan, food imports are generally regulated by the Federal government and food standards are regulated by the Provincial governments. Food standards are maintained in light of the Pakistan Pure Food Laws (PFL) of 1963 and are administered by Provincial Health Departments. The PFL is the basis of the existing trade-related food quality and safety legislative framework. It covers 104 food items falling under nine broad categories: milk and milk products, edible oils and fat products, beverages, food grains and cereals, starchy food, spices and condiments, sweetening agents, fruits and vegetables and miscellaneous food products. These regulations address purity issues in raw food and deal with additives, food preservatives, food and synthetic colors, antioxidants, and heavy metals.

In general, Pakistan's federal food import regulations are based on the
premise that if a product is sold in the country of origin, Pakistani
standards are met as well. The federal government generally applies
Codex standards and guidelines in its regulation of imported food
products. U.S. Food and Drug Administration standards also are used for
certain products. A list of permissible food colors is updated every
year. For animal products, \"Halal\" certification (slaughtered in
accordance with Islamic law) is required.

The Customs Department and Plant Protection and Quarantine (PPQ) are the
two main agencies involved in regulating food imports. The Customs
Department's primary function is to ensure that imported foods meet
Pakistan's labeling and shelf-life requirements, are not on the list of
banned items and are assessed the appropriate import tariff. PPQ's
function is to ensure that bulk commodities and live animal shipments
meet phytosanitary requirements.

The federal government's primary concern regarding imported food is
shelf life. Federal import regulations require that imported food
products have at least 50 percent of original shelf life remaining at
time of importation. To ensure shelf life requirements are met, correct
labeling is of critical importance. Each retail pack must have the
production and expiration dates printed on the label. In addition to
shelf life and labeling, certain products are banned for religious
reasons. The importation of food products containing pork or pork
products is prohibited. Meat and dairy products may be imported if
certified to be \"Halal.\" Commercial import of alcoholic beverages or
products containing alcohol is also prohibited.

Pakistan controls certain imports through a \"negative list.\" The
negative list is comprised of (a) items banned for reasons of religion,
security or luxury consumption; (b) capital and consumer goods banned to
protect a domestic industry; and (c) intermediate goods used to produce
protected goods. Pakistan also maintains a \"restricted list\" of items
that may be imported only by certain parties (i.e., the government or
other specified users) or under certain arrangements (such as imports
against credit).

Other than above, there are no federal restrictions on the importation
of consumer foods. U.S. exporters have had problems with requirements
due to the use of bar-code labels that do not have [printed]{.underline}
dates of manufacture and expiration. As a result, U.S. suppliers using
bar-coded labels alone will incur the extra cost of printing new labels
or of affixing stickers with the printed production and expiration dates
on each retail pack.

Since Pakistani consumers have confidence in the quality of foods
imported in the manufacturers' packaging, most foods are imported in
consumer-ready packaging. Refined vegetable oil is the one exception and
is generally imported in bulk and re-packed locally.

At the time of import, the Federal Customs Department checks the PFL
standards to determine whether an imported item qualifies. If the item
is not defined in the PFL standards, the Pakistan Standard Institute
(PSI) will be consulted. PSI standards are revised every five years. To
ensure that an imported product meets Provincial health requirements,
the exporter and/or his agent should contact Provincial Health
Departments to verify that the product meets the requirements of the
Pure Food Laws and the Pakistan Standard Institute.

There is no system to effectively enforce food laws at the wholesale or
retail level. Under certain circumstances, District Administrators, in
cooperation with the Provincial Food Department, may inspect outlets and
based on their finding may ban the sale of a product.

# **Section II: Labeling Requirements**

**General** **Requirements**

1\. Imported food products, including ingredients, must have at least 50
percent of their original shelf life remaining at the time of
importation - calculated from the date of filing the \"Import General
Manifest\" (IGM) in accordance with the Customs Act of 1969. English and
Urdu are the required labeling languages.

2\. Packages or containers must also indicate:

a\. The date of manufacture and date of expiration,

b\. That the contents are free from pork and pork products,

> c\. That the contents are fit for human consumption and that any
> animal product was obtained from an animal slaughtered according to
> 'Halal' requirements,

d\. That imports of edible oils be on the basis of landed weight and
landed quality, and

> e\. That packing may not contain any word or inscription of a
> religious connotation or any obscene picture that may offend the
> religious feeling of any sect, class or group in Pakistan.

3\. The production and expiration dates must be printed in English,
using either words and/or numbers.

4\. Standard U.S. bar-code labels alone are generally not acceptable as
they lack [printed]{.underline} production and expiration dates, as
required by law.

5\. Stickers, which contain the required printed dates of manufacture
and expiration, should be affixed to the standard U.S. labels prior to
shipment.

6\. Products for institutional sale are governed by the same regulations
as products for direct retail sale. However, certain institutions may
request additional information on the label to identify it as their
product.

7\. Samples are governed by the same regulations as products for direct
retail sale.

8\. The coded \"best before use date\" is not considered to be an
acceptable expiration date. In the past, several cargoes containing
items without printed production and/or expiration dates were held by
Customs until stickers with production and expiration dates certified by
the Pakistani High Commission in the United States could be affixed to
each individual item.

9\. Pakistan does not have any special or additional requirements based
on the country of origin for any food product. In the event there is a
worldwide alert for a product from a particular origin, Pakistan will
notify the appropriate country and trade organizations of any changes in
its import requirements.

10\. Authorities are very strict regarding label requirements and do not
grant exceptions. Instead, they are authorized to reject or to destroy
any cargo with improper labels.

**Requirements Specific to Nutritional Labeling**

Pakistan does not require nutritional content to be listed on product
labels but generally accepts U.S. Food and Drug Administration (FDA)
regulations as guidelines. The Pakistan Standards Institution regularly
updates its guidelines, based on Codex and FDA revisions.

1\. Nutritional labels are not required but can be included at the
option of the supplier.

2\. The standard U.S. nutritional fact panel is acceptable, if it
conforms to FDA regulations.

3\. There are no regulatory restrictions on the importation of products
with nutrient or nutritional claims. Pakistani authorities consider
claims largely as promotional tools and thus far do not require them to
be based on scientific evidence.

4\. There are no regulatory restrictions on the importation of products
with implied claims. Here again, authorities consider these claims to be
promotional tools and do not require them to be verified by scientific
evidence.

5\. Authorities generally have no objection to the importation of
products with specific health claims. However, if a product claims to be
a source of vitamins or minerals, it must be registered with the
Ministry of Health prior to arrival, jointly in the name of importer and
manufacturer.

# **Section III: Packaging and Container Requirements**

There are no special packaging or container size requirements or
preferences. Pakistan generally follows Codex rules for packaging
requirements. If packaging material is acceptable in the exporting
country, it is acceptable in Pakistan. Pakistan does not have any
packaging requirements related to environmental concerns, such as waste
disposal or recycling.

The following information must be placed in a durable and legible manner
on all packages in the consignment or container:

\-- The name of the product,

\-- The name and address of the manufacturer;

\-- The net contents,

\-- The date of manufacture and date of expiration,

\-- The percentage of dye contents, and

\-- The normal storage stability.

# **Section IV: Food Additive Regulations**

Pakistan generally follows Codex rules for food additives and
preservatives. The Ministry of Commerce updates its list of importable
food additives based on guidance received from Codex. U.S. exporters may
obtain the list of importable additives from the Ministry of Commerce
through the FAS/Islamabad office. These lists are in English and are
updated annually. Pakistan also follows Codex standards regarding
vitamins in food products.

The Ministry of Commerce regulates the importation of food coloring.
These regulations are reviewed and updated annually. The importation of
food coloring or foods containing artificial colors is subject to the
following conditions:

a)  The importer must obtain a certificate from the concerned agency of
    the government of the exporting country. The certificate shall
    accompany each consignment and shall state that the food
    additives/colors are in use in the country of origin at the time of
    shipment or are registered for use in that country.

b)  The exporter's invoice must show the percentage of dye content in
    the product.

# **Section V: Pesticides and Other Contaminants**

Pakistan generally follows Codex rules and guidelines on maximum
residual limits (MRLs) of pesticides and other contaminations in
foodstuff. Customs officials enforce these rules according to
Codex-defined limits for imported foods. However, Pakistan does not have
a system to enforce the MRLs of pesticides and other contaminants in
domestically produced foods.

Occasionally, authorities enact special requirements as occurred
following the dioxin problem in Belgium in 1999 when Pakistan required a
dioxin-free certificate on products originating from Belgium. The
Ministry of Food, Agriculture and Livestock (MINFAL) regulates the
registration of pesticides. All pesticides must be registered by filing
an application with MINFAL. U.S. exporters may obtain information
regarding pesticides approved by MINFAL through the FAS/Islamabad
office.

# **Section VI: Other Regulations and Requirements** 

The importer shall ensure that:

1)  Importation is in accordance with regulations and the item(s) are
    not on the negative list.

2)  The terms and conditions of importation are specified in the letter
    of credit.

3)  Imports of plants and animals have the necessary approval of the
    Ministry of Food and Agriculture.

4)  Imports of livestock genetics have the necessary clearance of the
    Livestock Division of the Ministry of Food and Agriculture.

**Registration:** There is no requirement to register most consumer
foods. However, laboratory testing may be required for food products
containing medicines. Bulk vegetable oils are the only products subject
to random testing to ensure fitness for human consumption at time of
arrival.

If registration is required, the importer must file an application with
the Ministry of Health. The importer also must attach a letter from the
manufacturer stating that he is the manufacturer's sole agent. This
letter is required because the product will be registered jointly in the
name of both the manufacturer and the importer for an initial period of
one year, which is extendable. The importer also must submit: a
registration fee, a sample of the product in the various packaging to be
marketed, a complete product history and other required papers.
Registration can take from 3 months to a year to complete.

**Samples:** Product samples can be shipped via express mail or parcel
post. If a sample meets labeling and other requirements, it will be
released after the applicable tariffs and taxes are paid. Free samples
are assessed duty based on freight costs. Specific requirements for
sample shipments may be obtained from the Ministry of Commerce.

**Specific Documentation and Certification Requirements:** The exporter
must provide a certificate of origin for all shipments. For animal
products, the exporter also must certify that the product is \"Halal."
Pakistan may require other specific certificates based on worldwide
alerts or other emergency situations. In such instances, the Government
of Pakistan will alert the appropriate countries and trade organizations
of these requirements. Exporters should verify with their importers that
all required certificates for customs and quarantine clearance have been
obtained prior to shipment.

# **Section VII: Other Specific Standards**

Pakistan generally follows European standards for weights and
measurements. U.S. weights and measures are acceptable. Other standards
applied by product include:

1.  Codex rules to regulate importation of vitamin-enriched products.

2.  Food products containing a genetically enhanced component (GMO) are
    not restricted.

3.  Fresh or frozen seafood may be imported in consumer packs or in
    bulk, provided the sale of the same product is permitted in the
    country of origin

4.  Live animals must provide a quarantine certificate from the relevant
    authority in the country of origin, which contains all the
    information required for quarantine clearance

5.  Alcoholic beverages may not be imported for commercial sale.
    Importation of alcohol for other than commercial sale requires
    approval of the Ministry of Commerce.

6.  Organic foods and health foods are not regulated. However, exporters
    may use FDA and Codex rules as a general guideline.

7.  Product samples and free samples must follow the same regulations as
    commercially imported items.

# **Section VIII: Copyright and/or Trademark Laws**

Trademarks and brand names are protected under domestic laws and are
registered through the Intellectual Property Organization. Pakistan is
committed to World Trade Organization (WTO) agreements and is moving to
comply with WTO agreements on intellectual property rights, trademarks
and patent rights. Pakistan has enacted laws and is in the process of
formulating the subordinate legislation to enforce these laws. Pakistan
is also a member of the Universal Copyright and Bern Conventions.

Pakistan has addressed Intellectual Property Rights by forming an
independent body, the Intellectual Property Organization - Pakistan
(IPOP). This agency has streamlined access to the organization by having
one point of entry. In the past, the Ministry of Commerce managed "trade
marks," the Ministry of Education managed "copyrights" and the Ministry
of Industries was responsible for "patents." A copyright on a registered
design is initially granted for five years extendable for another ten
years. Patents are granted for up to 16 years from the date of
application and may generally be extended for another five-year period
and, under some circumstances, for an additional five years. Legal
remedies, such as injunctions, are available in cases of patent
infringement. Trademarks are registered for seven years from the date of
application and the registration may be renewed for an additional
fifteen years.

There is no statute of limitations on trademarks and brand name
registrations. The importer of a food product, in coordination with the
manufacturer, may register the trademark(s) and brand(s).

#  

# **Section IX: Import Procedures**

All importers must register with the Export Promotion Bureau and are
required to be registered as an importer under the Registration
(Importers and Exporters) Order of 1993.

a.  Customs officials and Plant Protection and Quarantine officials must
    inspect imported products, to ensure they conform to labeling and
    other import requirements. Imports of live animals or plants require
    necessary certification from the country of origin. After Customs
    and PPQ issue their respective clearance reports, the goods are
    released on payment of import duty.

b.  English is the official language. All agencies will accept documents
    in English and will respond in English. Thus, there is no need to
    translate documents to Urdu or other local languages to expedite
    procedures.

c.  Goods generally can be cleared through Customs in less than a week,
    if all papers are in order.

d.  The system allows for appeal (at multiple levels) in case of a
    dispute.

# **Appendix I: Government Regulatory Agencies Contacts**

Secretary

Ministry of Food and Agriculture

Government of Pakistan

Pak. Secretariat, Block \"B\" Tel \# (92-51) 920-3307

Islamabad, Pakistan Fax \# (92-51) 922-1246

Secretary

Ministry of Commerce

Government of Pakistan

Pak. Secretariat, Block \"A\" Tel \# (92-51) 920-1816

Islamabad, Pakistan Fax \# (92-51) 920-3104

Secretary

Ministry of Industries

Government of Pakistan

Pak. Secretariat, Block \"A\" Tel \# (92-51) 921-1709

Islamabad, Pakistan

Secretary

Ministry of Finance

Government of Pakistan

Pak. Secretariat, Block \"Q\" Tel \# (92-51) 922-4956

Islamabad, Pakistan Fax \# (92-51) 921-8062

# **Appendix II: Government Regulatory Agencies Contacts**

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Chairman

Central Board of Revenue

CBR House Tel \# (92-51) 920-1938

Islamabad, Pakistan Fax \# (92-51) 920-5308

<chairman@cbr.gov.pk>

Collector of Customs

Pakistan Custom House Tel \# (92-21) 921-4170

Karachi, Pakistan Fax \# (92-21) 921-4134

Chairman

Export Promotion Bureau

Finance and Trade Center Tel \# (92-21) 920-6462

Shara-e- Faisal, Karachi, Pakistan Fax \# (92-21) 920-6461

<chairmanepb@yahoo.com>

Pakistan Standard Institute

Food and Agricultural Division Tel \# (92-21) 920-5997

Karachi, Pakistan Fax \# (92-21) 920-5928

Governor/Director

State Bank of Pakistan

Central Directorate

I.I. Chundrigar Road Tel \# (92-21) 921-244-748

Karachi, Pakistan

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