Confederation of All India Traders
(An Apex Body of Trade Federation, Association & Non-Corporate Sector of India)
925/1, Naiwala, Karol Bagh, New Delhi-110005,
Phone: +91-11-45032664, Telefax +91-11-45032665
E-mail: firstname.lastname@example.org Website: www.cait.in
Ref. No.: 3241/01/50
07th July, 2021
Shri Piyush Goyal
Hon’ble Minister for Commerce & Industry,
New Delhi – 110001
Dear Shri Piyush Goyal Ji.
Sub : Government Notification of 2nd July for Imposing Stock Limit on Pulses
We crave leave to invite your kind attention toward & Notification, issued by Ministry of Consumer Affairs imposing a condition of stock limit of Pulses of 200 M/T for the Wholesalers and 5 M/T for the Retail Traders engaged in the basins of the pulses.
Relevant Notification: Stock Limits and Movement Restrictions on Specified Foodstuffs (Amendment) Order, 2021
The above said notification is discriminatory and stands against the normal business practices of pulses trade in the Country. It is registered that while issuing the notification, no consultation was held by the concerned officials with the stakeholder. While requesting your good self for withdrawal of the said notification, we rely on the following points:
1. There are about 5 lakh traders conducting business in food grains across the Country and providing employment to more than 23 lakh people mainly to uneducated class which is required for loading and unloading of the goods. About 5 lakh people also derive their livelihood indirectly from the food gam trade.
2. There is a annual production of about 256 lakh tonnes of pulses in the Country and about 2o lakh Tonnes of pulses are imported every year from different Commies.
3. In September,2020 the Government ha announced that Essential Commodity Act or stock limit will be enforced only when the price of the pulses will be either 50% higher than the MSP or there is an emergency situation in the Country.
4. Through a notification in 2017 it was made mandatory that stock limit of 6 types of pulses, ”Masoor Chana, Tur, Urad, Moong and Kabli Chana will be uploaded on the portal of the Government which is being duly complied by the traders.
5. The pertinent matter is that a notification was issued by the Ministry of Consumer Affairs on 2nd July, 2021 stating that the wholesalers can stock upto 200 M/T of pulses and out of which one type of pulse can be stocked upto 100 M /T whereas for other pulses the work should not accede to 100 M/T compromising of rest of the pulses for maintaining sufficient supply and pulses.
6. It was further prescribed that the Millier will have to liquidate their stock within 45 days from the dated custom clearance for the goods received after 15th May, else they will have to abide by the stock limit prescribed for the wholesalers. However, prior to 15th May, 2021 there was no such limit on the Millers. There are more than 50 thousand millers across the Country Who are engaged in processing and finishing activities of pulses. Generally, a Miller keeps a stock ranging from 3 thousand to 5 thousand M/Ts of raw pulses.
The above notification is arbitrary, illogical and runs contrary to the normal business practices of the pulses trade in the Country. It is an admitted fact that the entire food grain business in the Country including pulses runs on huge quantity basis in order to feed 138 crore people of the Country. Any imposition of irrational stock limit will prove to be counter productive and will encourage ”Inspector Raj” in the Country and will restrict the smooth movement of goods from one State to another state which is not the intention of the Government. Therefore, we are bothering you for taking immediate steps to redress the grievances of the traders. Accordingly we submit as under:
a. The above said notification prescribing stock limit may be withdrawn with immediate effect. The stock limit of 200 M/T was fixed in 1955 when the population tithe Country was only 25 crore. For the present population, this limit is quite irrational and unjustified. If Government wants to impose the stock limit, then the same should in proportion to existing population and we propose that a stock limit of 2000 M/T for the wholesalers may be imposed and that too without specifying and stock limit for any particular pulses.
b. Since Import of pulses is done on huge quantity basis, no stock limit should be prescribed for importers or Millers.
c. The updation of stock limit on the portal was restricted to only 6 types of pulses which are under MSP category. However, the current notification of 2nd July vide clause 2 (i) prescribes updation of ”all pulses put together except Moons”. It is requested that clause 2(i) of the said notification may be withdrawn and earlier status of updation should be maintained.
The business community of the Country looks upon you as Champion of the issues of traders and with your various orders taken in the past, the traders of India have find much ease of doing business in the Country.
Therefore, we shall be grateful if you kindly withdraw the imposed stock limit on the pulses and other saiggested steps may be taken to provide ample business opportunities for the trade to flourish,
Thank You With load regards
National Secretary General
Confederation of All India Traders