Standards and Quality Assurance for Ghee and Butter Oil

Ghee and butter oil are among the most valued dairy products in India, and their quality directly impacts millions of consumers. But how do you know the ghee you buy is pure and safe? The answer lies in a well-structured system of standards and quality assurance measures that regulate everything from the chemical composition of ghee to the way it is packed and labeled. These standards are enforced by key regulatory bodies and help protect consumers from adulteration while ensuring consistency in the market.

Regulatory bodies governing ghee and butter oil quality 🔗

In India, ghee and butter oil quality has traditionally been governed by three major quality control systems. The first and most important is the Food Safety and Standards Authority of India (FSSAI), which now serves as the primary regulatory body for all food products, including ghee. FSSAI sets mandatory standards that every ghee manufacturer must follow before their product can be sold in the market.

The second agency is the Bureau of Indian Standards (BIS), which has published detailed specifications for ghee and butter oil under various IS codes. BIS standards have historically provided a voluntary quality benchmark, covering aspects like chemical composition, physical characteristics, and testing methods.

The third system is Agmark, operated by the Directorate of Marketing and Inspection (DMI) under the Ministry of Agriculture. Agmark certification has long been associated with ghee quality assurance in India. However, it is important to note that in October 2024, FSSAI implemented amendments removing the mandatory requirement for Agmark and BIS certification marks on food products like ghee. Now, FSSAI certification alone is sufficient for manufacturing, storing, and selling ghee, simplifying regulatory compliance for food businesses.

What is ghee according to Indian food laws? 🔗

Under Indian food regulations, ghee is defined as the pure clarified fat derived solely from milk, curd, desi (cooking) butter, or cream. No colouring matter or preservative can be added to it. This definition makes it clear that ghee must be exclusively a milk-fat product – anything else mixed in makes it adulterated.

Butter oil (also referred to as anhydrous butter fat) is defined as a product obtained exclusively from butter or cream through the removal of nearly all water and solids-not-fat content. According to Codex Alimentarius standard CODEX STAN 280-1973, both anhydrous milk fat and butter oil are fatty products derived entirely from milk by processes that result in the near-complete removal of water and non-fat solids. Butter oil may contain permitted antioxidants at levels not exceeding 0.02% by weight.

Key quality parameters for ghee 🔗

The quality and purity of ghee are assessed through a set of well-defined chemical and physical parameters. These act as a fingerprint for milk fat and help detect any form of adulteration.

Moisture content 🔗

Ghee must not contain more than 0.5% moisture under the general FSSAI standards. For Agmark-graded ghee, the limit is even stricter at 0.3%. Excess moisture not only reduces the shelf life of ghee but can also promote microbial growth and spoilage.

Free fatty acids (FFA) 🔗

Free fatty acids, expressed as a percentage of oleic acid, serve as an indicator of freshness and quality. Under FSSAI regulations, the maximum permissible FFA level in ghee is 3.0%. Higher FFA content suggests either poor processing, use of low-quality raw material, or deterioration during storage. In Agmark grading, the FFA limit varies by grade – Special grade allows a maximum of 1.4%, while General grade allows up to 2.5%.

Butyro-refractometer (BR) reading 🔗

The BR reading is a measure of the refractive index of ghee at 40°C. It is one of the most widely used tests for detecting the presence of vegetable oils in ghee. According to research published in PMC, the standard BR reading for ghee ranges between 40.0 to 44.0. Since most vegetable fats and oils have a higher refractive index than milk fat, any significant increase in the BR reading above the standard range indicates possible adulteration.

Reichert-Meissl (RM) value 🔗

The RM value measures the volatile, water-soluble fatty acids present in ghee, particularly short-chain fatty acids like butyric and caproic acid that are unique to milk fat. A minimum RM value of 24 is now required uniformly across India under the latest FSSAI notification. Previously, the requirement varied by region, with non-cotton-tract areas requiring a minimum of 28. A lower RM value can indicate the presence of non-dairy fats or oils. The RM value is particularly useful for detecting adulteration with palm olein and animal body fats.

Polenske value 🔗

The Polenske value measures insoluble volatile fatty acids such as caprylic acid (C8:0) and capric acid (C10:0) in ghee. The standard range is typically 1.0 to 2.0 for ghee from non-cotton-tract areas. Any significant deviation from this range suggests that the ghee may contain adulterants. This test works in conjunction with the RM value to provide a more complete picture of ghee purity.

Baudouin test 🔗

The Baudouin test is a chemical test specifically designed to detect the presence of vanaspati (hydrogenated vegetable fat) in ghee. For ghee to pass quality standards, the Baudouin test must be negative. A positive result is a clear indication of adulteration with vanaspati, which is a common and inexpensive adulterant in the Indian market.

FSSAI standards for ghee: state-wise variations 🔗

One of the unique aspects of ghee standards in India has been the regional variation in quality parameters. Because the composition of milk fat is influenced by the breed of animal, the feed given, and the geographic region, the FSSAI has historically set different BR reading and RM value ranges for different states and union territories.

For example, areas known as cotton tracts – where cottonseed is extensively fed to cattle – produce ghee with different physico-chemical characteristics. Research has shown that ghee from cotton tract areas has a BR reading range of 41.5 to 45.0, an RM value minimum of 21, and FFA not exceeding 2.0%. This is because cottonseed feeding alters the fatty acid profile of milk fat, resulting in lower RM values and slightly different refractive indices compared to ghee from other regions.

However, the latest FSSAI amendments have moved towards greater uniformity, with a nationwide RM value minimum of 24 now applicable across the country.

Standards for butter oil and anhydrous milk fat 🔗

Butter oil must conform to essentially the same quality parameters as ghee, with one key difference: the BR reading for butter oil is specified as 40.0 to 44.0 at 40°C. For imported butter oil, the Reichert value must not be less than 24. Butter oil should have a pleasant taste and flavour, be free from off-odour and rancidity, and must not contain any added colouring matter.

At the international level, the Codex Alimentarius distinguishes between four categories of milk fat products: anhydrous milk fat (minimum 99.8% milk fat), milk fat (minimum 99.6%), anhydrous butter oil (minimum 99.6%), and butter oil (minimum 99.3%). These global standards help facilitate international trade in dairy fat products while ensuring consumer protection.

The BIS standard for butter oil (IS 13689) covers requirements like milk fat content (minimum 99.5%), moisture (maximum 0.5%), FFA content, and organoleptic properties. The product must be derived exclusively from milk or milk products and should meet microbiological safety requirements as well.

Agmark grading system for ghee 🔗

The Ghee Grading and Marking Rules, first introduced in 1938, established a three-tier grading system under Agmark. Although Agmark certification is no longer mandatory for ghee since October 2024, it remains an important voluntary quality mark that many manufacturers continue to use.

Special grade (red label) 🔗

This is the highest quality grade. The ghee must have a well-defined granular texture when solid, be white with or without a yellowish or greenish tint that is uniform throughout, and have a natural sweet and pleasant odour with an agreeable taste. The maximum FFA content allowed is 1.4%. The moisture content must not exceed 0.3%, and all purity tests including Baudouin and phytosterol acetate tests must be negative.

General grade (green label) 🔗

This grade has the same texture, colour, and purity requirements as Special grade. The only difference is a higher allowable FFA level of up to 2.5%, which accounts for ghee that may be slightly older or processed from cream that is not as fresh.

Standard grade (chocolate label) 🔗

The quality requirements for Standard grade are the same as those defined under the PFA Rules (now FSSAI regulations). The maximum permissible FFA for this grade is 3.0%. This grade represents the minimum acceptable quality level for marketed ghee.

Each Agmark label is printed on watermark paper of the Government of India with a micro-tint background bearing the words “Government of India” in olive green to prevent counterfeiting. Every label has a unique serial number, and the product must clearly display the packer’s name, batch number, date of packing, and net weight.

How Agmark quality control works in practice 🔗

Even though Agmark certification is voluntary, the process for obtaining and maintaining it is rigorous. An authorized packer must have a laboratory and trained staff at their premises. Before ghee is packed and labeled, a sample from each melt (batch) is drawn and sent to a Regional Agmark Laboratory for analysis. The Central Agmark Laboratory in Nagpur serves as the apex testing facility, with Regional Laboratories spread across eleven nodal cities.

If the laboratory finds that a batch does not meet the specified standards, the packer is immediately informed and must remove all Agmark labels from the tins filled from that batch. Additionally, periodic check samples are drawn from stored Agmark ghee to verify that the product has not deteriorated beyond the prescribed limits. If a Special grade ghee develops excess acidity during storage, it may be downgraded to General or rejected entirely.

Conditions for authorized packers 🔗

The ghee grading rules lay down strict conditions for authorized packers. The factory and laboratory must be clean, well-ventilated, and sanitary. No fat or oil other than ghee can be present on the premises to prevent cross-contamination. The clarification temperature during manufacturing must never exceed 110°C. Ghee must be packed hygienically in clean, sound, and new tins (with or without lacquering), glass bottles, or food-grade plastic containers.

Detection of adulteration: the science behind the standards 🔗

All of the quality parameters described above serve a single critical purpose – detecting adulteration. Since ghee commands a price nearly three times that of edible vegetable oils, the incentive to adulterate is high. Common adulterants include palm oil, vanaspati, animal body fat, and other vegetable oils.

The BR reading is the frontline test for vegetable oil adulteration, as most vegetable oils raise the refractive index beyond the acceptable range for milk fat. The RM value drops when non-dairy fats are mixed in, since these fats lack the short-chain volatile fatty acids that are characteristic of milk fat. The Baudouin test specifically catches vanaspati, and the phytosterol acetate test detects plant-derived sterols that have no place in genuine ghee.

Advanced techniques such as RP-HPLC (Reverse Phase High-Performance Liquid Chromatography) and GC-MS (Gas Chromatography-Mass Spectrometry) are now also used to detect sophisticated forms of adulteration that may escape conventional tests. Studies have shown that methods like solvent fractionation, when coupled with RM value and BR reading tests, can improve the detection sensitivity for adulterants like palm oil and sheep body fat.

Recent regulatory changes and their impact 🔗

The October 2024 FSSAI amendment that removed the mandatory requirement for Agmark certification on ghee was a significant regulatory shift. Previously, ghee with a lower Reichert value than what was prescribed for a particular area of sale could only be sold if it bore an Agmark seal. This restriction has now been removed, and FSSAI certification is the only mandatory requirement.

This change simplifies the compliance process for businesses and reduces costs, but it also means that consumers now rely more heavily on FSSAI’s enforcement mechanisms to ensure ghee quality. The FSSAI’s Methods of Analysis manual provides standardized analytical procedures for testing milk and milk products, ensuring consistency in how quality checks are performed across the country.

Despite these regulatory streamlining efforts, the core quality parameters – BR reading, RM value, Polenske value, moisture, FFA, and Baudouin test – remain unchanged and continue to serve as the foundation of ghee quality assurance in India.

Why these standards matter for consumers 🔗

For consumers, these standards serve as an invisible safety net. Every time you purchase a branded or certified ghee product, its composition has been tested against defined limits to confirm it is genuine milk fat, free from adulterants, and safe for consumption. The standards also ensure consistency – ghee you buy today should have the same quality as what you bought six months ago from the same brand.

For manufacturers, compliance with these standards is not just a legal requirement but also a trust-building measure. In a market where adulteration is a persistent problem, meeting or exceeding quality benchmarks differentiates genuine products from substandard ones.

What do you think? With the removal of mandatory Agmark certification for ghee, do you believe FSSAI alone can effectively ensure ghee quality across India’s vast and diverse market? How do you personally check for ghee quality when making a purchase?

References

1. https://www.fssai.gov.in/upload/uploadfiles/files/Compendium_Food_Additives_Regulations_21_10_2022.pdf
2. https://www.dmi.gov.in/GradesStandard.aspx
3. https://edairy.net/agmark-bis-isi-no-longer-needed/
4. https://www.fao.org/input/download/standards/171/CXS_280e.pdf
5. https://pmc.ncbi.nlm.nih.gov/articles/PMC9579228/
6. https://pmc.ncbi.nlm.nih.gov/articles/PMC9304484/
7. https://upload.indiacode.nic.in/showfile?actid=AC_CEN_23_31_00011_193701_1535099362507&filename=ghee_grading_and_marking_rules%2C_1938_amended_in1950%2C1961%2C1966%2C1981%2C1991.pdf&type=rule
8. https://foodsafety.institute/food-laws-standards/agmark-quality-grading-agricultural-products/
9. https://tax2win.in/guide/fssai-standards-for-milk-and-milk-products