India’s commitment to sustainable agriculture has historically been anchored on the balance between tradition and science. Recent advances in plant biostimulants, the substances that enhance plant growth, nutrient use efficiency, and resilience to stress have offered promising tools for improving crop productivity under climate challenges. Among these, protein hydrolysate (PH) -based biostimulants have emerged as one of the most significant innovations, providing an environmentally acceptable alternative to regular fertilisers.
However, a recent policy reversal removed animal-origin protein hydrolysates from the Fertiliser (Control) Order (FCO), 1985. This decision risked the years of science-led agricultural reforms like the plant biostimulants, critical in boosting low productivity in the face of climate change. The decision, which was made public on 29 September 2025, through Gazette Notification S.O. 4441 (E) removed all the eleven approved formulations of protein hydrolysates of animal origin from Schedule VI, banning their use as biostimulants.
While government reserves the right to review and revise its policy regulations, but these changes must be based on scientific reasonings drawn out of careful scientific deliberations. ICAR has 114 research institutes and deemed universities, many of which deal exclusively on natural resource management, soil nutrient and soil fertility. Apparently not much academic excellence, research expertise, professional wisdom and resources that might have been available within these public organizations remained unexplored.
Neither have any scientific data, safety assessments, or technical justification preceded critical reversal of the regulation. The move appeared influenced more by socio-religious sensitivities rather than the risk-based review. The move raises concern among scientists, industry, and progressive farmers who have invested in biostimulants-based technologies since their formal recognition in 2021.
A Landmark Reform and Its Abrupt Reversal
The inclusion of biostimulants under the FCO through Gazette Notification S.O. 882 (E) in February 2021 was a landmark reform. For the first time, India formally recognized biostimulants as a distinct category of agricultural inputs. These are, substances or microorganisms that, when applied to plants, seeds, or soil, stimulate physiological processes to enhance growth, yield, and stress tolerance.
The biostimulants are distinct from biofertilizers and biopesticides, the other two categories of biological inputs that govern plant nutrition and protection from pests. Crucially, the definition explicitly permitted biostimulants derived from plant, microbial, animal, or synthetic sources, provided they met rigorous safety, toxicity, and efficacy criteria.
This reform provided long-awaited regulatory clarity to an emerging sector, to support sustainable and climate-resilient agriculture. The new framework encouraged scientific innovation, research investment, and the entry of validated products into the Indian market. Both plant- and animal-origin protein hydrolysate formulations were approved after thorough evaluation by the Integrated Nutrient Management (INM) Division of the Ministry of Agriculture, based on extensive data covering toxicology, bioefficacy, and quality control.
The recognition of biostimulants under the FCO not only brought India in alignment with global agricultural standards but also demonstrated the government’s confidence in science-driven policymaking. The 2025 reversal, therefore, marks a concerning deviation from this progressive trajectory.
Understanding Protein Hydrolysates: Chemistry Beyond Source
Protein hydrolysates are mixtures of amino acids, peptides, and other small organic molecules derived from the controlled hydrolysis of natural proteins. These products are known to improve nutrient uptake, chlorophyll synthesis, root growth, and tolerance to abiotic stresses such as drought, heat, and salinity. PHs can be obtained from diverse raw materials—plants (such as soybean or oilseed meals), microbes, or animal by-products (such as collagen, fish waste, or leather trimmings). However, once hydrolysed, the resulting amino acids and peptides are chemically identical, regardless of the source.
An amino acid molecule like glycine or lysine has the same structure, NH₂–CH(R)–COOH, whether derived from a plant or an animal protein. After hydrolysis, no DNA, intact protein, or tissue remains. The final product is a biologically neutral solution, indistinguishable in composition and performance between plant and animal origins.
Describing such products as “animal remains” is, therefore, scientifically inaccurate. Toxicological and environmental evaluations worldwide have consistently shown PHs to be non-toxic, biodegradable, and beneficial for soil microbial activity. The European Union, the United States, and Japan all classify protein hydrolysates, irrespective of source, as safe and sustainable agricultural inputs.
Inconsistency within the Fertiliser (Control) Order
What makes the recent prohibition particularly perplexing is its inconsistency with the FCO’s existing provisions. Under the same regulatory framework, several fertilizers of animal origin, such as raw and steamed bone meal, remain officially approved. These are routinely used as organic fertilizers, valued for their phosphorus and calcium content, and are widely accepted in both conventional and organic farming systems. The FCO defines “organic fertilizer” as any material of biological origin, plant or animal, subjected to decomposition or microbiological processes that make nutrients available for plant use.
Bone meal, blood meal, fish meal, and other animal-based materials fall squarely within this definition. Their specifications under the FCO include moisture, total phosphate, nitrogen content, and particle size, all designed to ensure safety and quality. In other words, animal-derived fertilizers have been accepted under Indian law for decades, and their continued approval affirms that such materials pose no inherent religious, ethical, or safety risk when processed according to scientific standards.
By contrast, the ban on animal-derived protein hydrolysates, products even more refined and purified than bone meal, introduces a contradiction. It selectively disallows one form of animal-origin input while continuing to permit others under the same law. Such a selective prohibition creates regulatory asymmetry, erodes internal consistency, and weakens the credibility of science-based governance.
Science, Sentiment, and Policy: Striking the Right Balance
India’s cultural diversity and spiritual traditions are rightly respected in policymaking. However, agricultural regulation must remain grounded in empirical evidence. Policies driven primarily by perception rather than data risk sending mixed signals to both farmers and researchers. There is a difference between acknowledging public sentiment and allowing sentiment to override science. While faith and ethics have a place in guiding societal values, they cannot serve as the basis for technical standards that determine agricultural inputs.
The role of government regulation is precisely to ensure that such decisions are informed by risk assessment, transparency, and evidence. The revocation of animal-origin PHs has the unintended effect of casting doubt on India’s regulatory predictability, an essential factor for research investment and innovation. Scientists and companies that complied with the 2021 framework and developed validated formulations are now left uncertain about the continuity of policy. This uncertainty discourages future investments and undermines confidence in India’s otherwise progressive agricultural governance.
Why Policy Reconsideration Is Warranted
A science-based reconsideration of the 2025 notification would serve several crucial purposes:
Restoring Policy Coherence:
The current FCO allows animal-based organic fertilizers such as bone meal and fish meal. Prohibiting protein hydrolysates derived from similar sources creates inconsistency. Aligning the regulation across categories would ensure internal coherence and prevent arbitrary exclusions.
Encouraging Circular Economy:
Protein hydrolysates of animal origin are often produced from collagenous byproducts of meat or leather industries, materials that would otherwise contribute to environmental waste. Their utilization as biostimulants exemplifies circular economy principles, turning waste into value.
Strengthening Climate-Resilient Agriculture:
PH-based biostimulants improve nutrient efficiency and crop resilience, thereby reducing dependence on chemical fertilizers. Revoking them without scientific cause risks slowing progress toward the government’s sustainability goals under the National Mission on Sustainable Agriculture.
Protecting Farmer Interests:
Farmers are the ultimate beneficiaries of science-led reforms. Limiting access to safe, effective biostimulants curtails their ability to manage stress-prone crops efficiently. Ensuring product diversity and choice fosters innovation and economic benefit at the farm level.
Safeguarding India’s Scientific Integrity:
India’s reputation as a science-respecting nation depends on consistent, transparent regulatory decisions. Reversing the recent ban based on evidence would reaffirm that India’s policies are guided by reason and not rhetorically.
Way Forward: A Constructive Path
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A balanced resolution is well within reach. The government could consider the following steps to restore confidence while maintaining public trust:
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Constitute a technical review committee under the INM Division to re-examine the scientific data on protein hydrolysates of animal origin, including toxicology and environmental impact.
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Invite public and scientific representations to ensure transparency and address any ethical or religious concerns through dialogue rather than prohibition.
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Reinstate the approved formulations that had earlier cleared the multi-tier scientific scrutiny under the 2021 framework, pending any new evidence to the contrary.
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Develop clear labelling guidelines to distinguish plant- and animal-derived formulations, allowing informed choice by users without denying access to proven technologies.
Such measures would demonstrate that India’s policy system is both responsive and rational. It can accommodate cultural diversity while remaining steadfastly anchored in scientific logic.
Conclusion: Let Science Lead
Protein hydrolysate-based biostimulants, whether derived from plants or animals, represent a class of safe, sustainable, and scientifically validated agricultural technologies. Their prohibition on non-scientific grounds risks undermining India’s progress toward sustainable intensification and nutrient efficiency. The issue at hand is not one of faith versus science, but of ensuring that public policy respects both belief and evidence in their rightful domains. India has long shown that science and culture can coexist harmoniously when guided by rational governance.
Revisiting the 2025 notification with an open, evidence-based approach would not only correct a policy inconsistency but also reaffirm India’s leadership in sustainable agriculture. In doing so, the government would send a message loud and clear, that its decisions concerning farmers welfare, environment safety, and agricultural innovation in India will continue to be guided by science, transparency, and national interest.
