India is tightening the rules for pork import, and the change is more consequential than a new veterinary certificate might suggest. A draft certificate prepared by the Department of Animal Husbandry and Dairying in February 2026 replaces broad disease declarations with requirements linked to specific provisions of the World Organisation for Animal Health’s Terrestrial Animal Health Code. It also introduces defined waiting periods and a separate set of food-safety attestations.
The change signals a move to risk-based drafting and leaves India better placed under the WTO’s Agreement on Sanitary and Phytosanitary Measures (SPS Agreement). But it also raises a harder question: does India apply to itself what it demands of exporters? On that count, the draft stands on less firm ground.
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Pork import rules offer a layered system
Sanitary certification in India is not a single act. Responsibility is divided by product; the Food Safety and Standards Authority of India (FSSAI) for food, the Department of Animal Husbandry and Dairying (DAHD) for livestock and livestock products, the Directorate of Plant Protection, Quarantine and Storage for plants, and the Export Inspection Council for exports.
For imported food, Section 25 of the Food Safety and Standards Act, 2006 requires a health certificate from the exporting country’s competent authority, followed by FSSAI inspection, sampling and verification.
Animal health rests on the Livestock Importation Act, 1898, whose Sections 3 and 4 let the Centre regulate imports and make them conditional on certification. DAHD issues a Sanitary Import Permit after assessing the exporting country’s disease status, writes the conditions into the certificate, and verifies compliance at a quarantine station.
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From broad declarations to named articles
The certificate for the year 2022 placed several diseases under one declaration, complicating the verification of each disease. As per the current draft, important diseases will have separate clauses that directly connect them with the WOAH Code. Foot and Mouth Disease is associated with Chapter 8.8, Articles 8.8.13 to 8.8.16; African Swine Fever is associated with Articles 15.1.28 to 15.1.30, as well as Aujeszky’s Disease with Chapter 8.2. Trichinella’s connection is to Article 8.18.5 with only two alternatives instead of three unlike Taenia solium that is linked to Articles 1.4.6 and 15.4.6.
Two diseases are mentioned here for the first time. Classical Swine Fever (CSF) is mentioned as a separate disease and Porcine Epidemic Diarrhoea disease is added to the list. Another point of significance is that anthrax is separated along with 20 days and 14 days in place of the original three-month freedom period, whereas enterovirus encephalomyelitis, transmissible gastroenteritis, tuberculosis, and porcine brucellosis will be mentioned together.
The certificate also contains content related to the other diseases. Apart from monitoring antimicrobial usage (WOAH Chapter 6.9), and biosecurity of Salmonella and Campylobacter (Chapter 6.14), the area of cross-species contamination will exclude tissues of bovine, ovine, caprine, and poultry animals.
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A food safety layer in the same document
The draft adds a Food Safety Attestation absent from the 2022 version, with seven requirements. The product must come from a facility approved, registered or licensed by the competent authority and conform to the Food Product Standards and Food Additives Regulations, 2011. It must meet the microbiological criteria in Appendix B, keep residues of drugs, antibiotics, mycotoxins, pesticides and heavy metals within limits under the Contaminants, Toxins and Residues Regulations, 2011, and use only additives listed in Appendix A. The establishment must be officially inspected and run a HACCP-based food safety management system, and the product must comply with the processes in paragraph 2.5.2 of the 2011 Regulations.
The effect is to consolidate animal health and food safety certification in one instrument, cutting the documentary fragmentation exporters would otherwise face.
A stronger hand under the SPS Agreement
Each change maps onto a specific SPS obligation. Disease-specific conditions built on an assessed risk profile answer the Article 2.2 and Article 5 inquiry that has decided most SPS disputes. Anchoring conditions to specific WOAH articles gives India the benefit of the Article 3.2 presumption, so it does not have to prove each condition afresh.
Reliance on the exporting authority’s certificate, with independent verification at the border, gives effect to Article 4 on equivalence without blind acceptance. Recognition of zones and compartments meets Article 6 ,Notification to the WTO discharges Article 7 and Annex B, and the staged process of review, inspection, testing and surveillance is what Annex C contemplates.
Where the draft is exposed
The weak point is Article 2.3. It bars arbitrary or unjustifiable discrimination between Members where identical or similar conditions prevail, including between a Member’s own territory and that of others. It folds national treatment and most-favoured-nation treatment into one obligation, but the comparison is epidemiological, not commercial. India may impose conditions on imports that it does not impose at home if the difference tracks a genuine difference in risk, but not where conditions are the same.
India has been here before. In India – Agricultural Products (DS430), it barred imports from countries reporting low-pathogenic avian influenza while treating the disease far more mildly at home. The panel and Appellate Body found violations of Article 2.3, among others. The failing was not the high level of protection but India’s inability to show that its own conditions differed from those of exporters.
The CSF clause is the sharpest parallel. On the available epidemiological picture, CSF is present in India, yet the draft asks exporting countries to certify freedom or equivalent conditions. India can defend this, since imported and domestic pork sit differently in the risk chain, but the defence needs a documented risk assessment, not assertion.
The food safety attestations raise a related question. Imported pork must come from approved, inspected, HACCP-run establishments, while a significant share of domestic pig slaughter takes place at unregistered or municipal facilities that meet none of these criteria. Two positions are credible. One holds that Article 2.3 compares sanitary conditions, not regulatory stringency, so a Member phasing in domestic infrastructure need not delay import requirements. The other holds that Annex C(1)(a), which requires procedures no less favourable for imports than for like domestic products, sits uneasily with such a gap.
A national treatment complaint does not ask whether a measure conforms to an international standard. It asks whether India applies to itself what it demands of others.
Capacity and scale
Certification is a claim about laboratories and surveillance. India’s diagnostic capacity is concentrated in a limited number of central and regional institutions, with state laboratories varying in accreditation, equipment and throughout. Confirmatory residue analysis needs LC-MS/MS under ISO/IEC 17025-accredited methods, which is unevenly distributed.
The larger constraint lies upstream. Pig rearing in India is largely smallholder and backyard, concentrated in the north-east and parts of eastern and central India. The 20th Livestock Census recorded about 9.06 million pigs in 2019, with Assam alone at around 2.1 million.
Three things follow. Disease-freedom attestations presuppose registered holdings, which backyard units rarely offer. A significant share of slaughter happens outside inspected facilities, so certification governs a narrow, capitalised segment while most output moves through unorganised markets. And accreditation, cold chain and HACCP carry fixed costs that only integrated operators can absorb, pushing smallholders towards aggregation or exclusion.
Ractopamine is a separate question
Ractopamine, a feed additive common in US pork production, is the main point of divergence with exporters. Codex has adopted a 10 µg/kg limit for muscle and fat. India does not approve the drug for food animals and prescribes no limit, so DAHD applies an operational limit of 0.01 mg/kg across edible tissues, which works in practice as zero tolerance.
Because the same prohibition applies to domestic production, this is not a national treatment issue. It is a departure from a Codex standard, which carries the burden of justification under Article 3.3. India needs to state its scientific case openly and build the laboratory capacity to detect and confirm at that threshold.
What needs to change
The Article targets the foundation, not the text. To close the national treatment gap, DAHD should place on record a risk assessment for each attestation on a disease present in India, run a time-bound CSF control programme alongside import conditions, and publish a timetable for extending inspection to domestic slaughter.
On verification capacity, priority should go to accredited confirmatory testing, a statistically designed national residue monitoring plan and standardised state laboratories. On scale, India needs animal identification and traceability for pigs, starting in the north-east, support for producer collectives so smallholders are not shut out, and investment in registered slaughter infrastructure.
Procedural reform means published processing periods, a standing Article 4 procedure for equivalence claims and better coordination between FSSAI and DAHD. On positioning, India should put ractopamine on an explicit Article 3.3 footing.
The 2026 Veterinary health Certificate draft reflects deliberate regulatory maturation under real capacity constraints, but is best seen as a well-constructed legal instrument resting on an incomplete regulatory base.
That base decides what happens next. If India closes the gap between what the certificate asserts and what its system can verify, through laboratories, traceability and registered slaughter capacity, the pork Veterinary health Certificate (VHC) could serve as a template for other commodities and developing economies. If it does not, trading partners will probe that gap under Articles 2.2 and 5.1.
Dr Murali Kallummal is Head of Administration at the Centre for Research on International Trade (CRIT) and Professor at Centre for WTO Studies (CWS), IIFT, New Delhi. Anuveeta Datta Chowdhury is Associate (Legal) at the Centre for WTO Studies CWS.
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Murali Kallummal is Professor, Centre for WTO Studies, CRIT, IIFT, New Delhi. Views are personal.