Entering the European market for pigeon peas

European countries. Growing demand for healthy foods and plant-based proteins as well as ethnic foods creates opportunities for new suppliers on these niche markets. To successfully enter the European market for pulses, your pigeon peas should be of high quality and must fulfil stringent food safety requirements.

1. What requirements must pigeon peas comply with to be allowed on the European market?

Whenever food products are placed on the European market, they must fulfil general food safety and quality requirements. This also applies to pigeon peas. For a detailed overview, you can check CBI’s summary of the requirements that suppliers of grains, pulses and oilseeds must comply with before putting products on the European market.

The European Commission has set up a search engine that gives small businesses detailed information about product rules and import requirements, My Trade Assistant. It can be searched by EU country and on a product-by-product basis. To check the requirements for pigeon peas, use the Harmonized System (HS) code 0713.60 for dried pigeon peas.

Food safety and product quality are the most important aspects under EU Food Law. Some buyers will also require you to address issues of Corporate Social Responsibility (CSR).

What are mandatory requirements?

Food safety: limited presence of pesticides and contaminants

Consumer safety is the most important aspect when selling a product on the European market. If a product fails to comply with food safety standards, European authorities can impose stricter controls or even ban imports from your country. The responsibility for compliance with European rules lies in the country of origin of an imported food product. Controls take place at European borders and on the market.

To meet the safety standards, you must apply the principles of the Hazard Analysis Critical Control Point (HACCP) system. Moreover, EU food safety standards require you to ensure traceability of your product throughout the supply chain. Important food safety requirements include limited or no pesticide residues, limited or no presence of contaminants such as metals or stones, and no microbes such as salmonella or E. coli.

Contamination with heavy metals is another concern in pigeon peas and other pulses. The European Commission has laid down maximum levels for cadmium and lead (see Table 1, pigeon peas fall under pulses).

Table 1: Maximum allowed levels of heavy metals in pigeon peas

Relevant foodstuff categories	Maximum levels (mg/kg wet weight)
	Lead	Cadmium
Cereals and pulses	0.20
Pulses and protein from pulses: Pulses, except protein from pulses Protein from pulses		0.040 0.10

Source: European Regulation (EC) No 1881/2006 setting maximum levels for certain contaminants in foodstuffs

Cases of contamination in products that have been placed on the European market are reported in the EU Rapid Alert System for Food and Feed (RASFF).

Labelling of allergens

If you are delivering packaged pigeon peas directly to wholesalers or retailers in Europe, your product should follow the Codex General Standard (PDF) for the Labelling of Pre-packaged Foods or Regulation (EU) No. 1169/2011 on the provision of food information to consumers in Europe.

If the presence of allergens cannot be ruled out, the labelling of your product must clearly inform consumers about potentially present allergens. The allergen information should be highlighted on the ingredient list, for example by using a different font, letter size or background colour.

Figure 1: Example of pigeon pea product labelling highlighting potential allergens

Source: Profundo

Packaging

Pigeon peas are commonly transported in 25 kg or 50 kg polypropylene (PP) bags. Two EU packaging regulations are relevant for pigeon pea exports to Europe: Regulation (EC) No 1935/2004 states that packaging materials should not release harmful levels of their components into foods. Moreover, they should not change the taste, smell or composition of food. Exporters using plastic materials like polypropylene must follow Regulation (EU) No 10/2011 on plastic materials intended to come into contact with food.

What additional requirements and certifications do buyers ask for?

Quality standards

There are no specific European food quality standards for dried pulses like pigeon peas. In general, food imports into Europe must be:

• Safe and suitable for human consumption;
• Free from abnormal flavours and odours;
• Free from dirt in amounts that may be harmful to human health (for example, your product should be free of dead insects or plant residues);
• Free from sand, living insects, mites or other impurities.

To ensure high quality of your pigeon peas, proper storage is crucial. Particular attention needs to be paid to the moisture level of the grains. Table 2 provides an indication of high, medium and low grades of pigeon pea qualities.

Table 2: Indicative specifications of pigeon peas

Parameters	Maximum limits			Test method
Foreign matter	Grade 1	Grade 2	Grade 3	ISO 605
Foreign matter	0.5%	1%	2%
Inorganic matter	0.1%	0.5%	0.7%
Broken/split grains	2%	3%	4%
Pest-damaged grains	2%	3%	6%
Rotten/diseased grains	0.5%	0.5%	1%
Discoloured grains	1%	1%	3%
Immature/shrivelled grains	1%	2%	3%
Total defective grains	3%	5%	8%
Moisture content		13%		ISO 24557
Total aflatoxin		10 ppb		ISO 16050
Aflatoxin B1 only		5 ppb		ISO 16050

Note: European Regulation No 1881/2006 regulates the presence of aflatoxins in products for the European market; ppb=parts per billion.
Source: East African Standard – Pigeon Peas (PDF)

Quality certifications

Retailers and food processors in Europe often expect extra food safety guarantees from their suppliers. Voluntary certification schemes are a commonly used means to ensure that products meet quality standards.

Traders, processors and retailers often require their foreign suppliers to have a food safety management system in place that is in line with the principles of Hazard Analysis and Critical Control Points (HACCP). Such a system identifies, evaluates and controls hazards to food safety.

Food management and certification programmes recognised by the Global Food Safety Initiative (GFSI) are widely accepted on the European market. Relevant standards include BRCGS Global Food Safety Standard, FSSC 22000, GLOBALG.A.P. and International Featured Standard (IFS).

Social and environmental sustainability

In addition to food safety requirements, social and environmental sustainability criteria play an increasingly important role in successfully entering the European market. Buyers may require you to provide documentation of appropriate standards and to follow a code of conduct. Such requirements do not depend on the size of your operations. Moreover, supply chain due diligence is increasingly becoming a mandatory part of European business practice. It also leads to stricter codes of conduct for suppliers.

In 2019, the EU launched the EU Green Deal (EGD) as a first step to meet its climate goals for 2050. As EGD policies get implemented, environmental and sustainability standards are expected to become stricter in the coming years. In the context of the EGD, the EU also adopted a proposal for a Directive on Corporate Sustainability Due Diligence. This legislation will make social compliance an obligation for many companies. It currently applies to large companies and their global supply chains, but small and medium-sized enterprises may be included as well in years to come.

Obtaining certification under a widely accepted voluntary scheme can support you in meeting buyer expectations. Some recognised standards and codes of conduct are:

• Business Social Compliance Initiative (amfori BSCI)
• Ethical Trading Initiative (ETI)
• GLOBALG.A.P. Risk Assessment on Social Practice (GRASP)
• Rainforest Alliance
• SAI Platform - Farm Sustainability Assessment (FSA)
• Sedex Members Ethical Trade Audit (SMETA)

What are the requirements for niche markets?

Fairtrade

Schemes like Fairtrade International and Fair for Life define fair trade production practices. They are gaining popularity in Europe, but remain niche markets focussed on socially conscious consumers. Fairtrade International has standards for small producer organisations for vegetables. The organisation handles minimum prices for certified pulses, at US$430/tonne for conventional pulses and US$540/tonne for organic. There is an added premium of US$65 and US$80, respectively.

Certification for ethnic consumption

Ethnic food channels are the key sales points for pigeon peas in Europe. Halal or kosher certifications can play an important role in increasing the market reach of your product.

Organic certification

Europe is a leading market for organic food products and continues to show strong growth. To place organic products on the European market, you have to comply with organic production methods in European legislation. Under Regulation (EU) No 2018/848, producers in third countries who want to supply the European market have to follow the same rules as those producing in the European Union. In January 2022, stricter inspection of organic products came into force to prevent fraud.

To sell organic pigeon peas in Europe, an approved certifying agency must verify that you meet European requirements. Keep in mind that getting a license to supply organic certified products to Europe takes time and costs money.

Figure 2: Fresh green pigeon peas

Source: Pixabay, Estefane Santana

2. Through what channels can you get pigeon peas on the European market?

How is the end market segmented?

The small European end market for pigeon peas is dominated by dried grains for food use. Within the food sector, the key sales channels are stores catering to ethnic communities and food service focussing on Indian cuisine. Most sales are in the UK, which is the key market for pigeon peas in Europe.

Figure 3: Market segmentation for pigeon peas in Europe

Source: Profundo

Presentation: Dried pigeon peas are dominant

Dried grains dominate in the still small market for pigeon peas in Europe. Brands include TRS, Unidex and Western Impex. While pre-cooked pulses are seeing rapid growth as convenient products, in Europe pigeon peas in cans or jars are less common than other pulses. Similarly, pigeon peas as an ingredient for ready-made meals are a niche, and most relevant in the UK with its important Indian food segment.

Retail channels: Ethnic stores dominate

Because of the consumption of pigeon peas especially in South Asian and African cuisines, independent ethnic stores are the main retail channel in Europe. Sales in mainstream supermarkets can be found in the UK but are otherwise not yet widely spread in European countries. There is growth potential in supermarkets though, in line with a movement towards healthier diets. This is especially relevant for organic or health food stores. The use of pigeon peas in ethnic cuisines also means that food service is a relevant channel for their sale, for example in the preparation of Indian meals.

Target group: Ethnic communities and health-oriented consumers

The core group that accounts for the consumption of pigeon peas in Europe are ethnic communities from Asia, Africa and Latin America. Sales to consumers that are health-oriented and focus on plant-based nutrition have potential for growth but are not yet mainstream markets for pigeon peas. Sales in these segments may benefit from targeted information about the nutritional benefits and versatility of these pulses.

Through what channels does a product land on the end market?

There are different ways to reach the European market. Your path may go via middlemen, like traders or brokers, or directly to companies that process, package or market pigeon peas in Europe (Figure 4). Brokers and traders can play a role in opening the market for a little-known product like pigeon peas. They have experience with market conditions and prices, and can help you arrange the logistics of the trade. At present the market is mostly limited to ethnic foods. This may change as consumers choose healthier and more plant-based diets. Currently, organic-certified pigeon peas are rarely offered on the market.

Figure 4: Simplified overview of key European market channels for dried pigeon peas

Source: Profundo

Importers and wholesalers

The small market for pigeon peas in Europe is also reflected in how the trade is organised. The division between importers, food manufacturers and packers, wholesalers and retailers, and food service companies at the end of the chain is less clear-cut than for other agricultural products. Some of the larger traders of pulses also list pigeon peas as part of their offer, like AGT Poortman and ETG World from the Netherlands or Casibeans from Belgium. ETG trades and processes various pulses and is present in all key production countries including India. It also procures around 70% of the African pulse production. In Africa and Asia, most pulses are sourced directly from farmers.

Packers of branded products often import pulses themselves and package them into retail-sized packs. Most of these companies cater to the ethnic food market, especially Indian food stores and food service companies (see Table 4). Such integrated traders include Gunarajan Handelsagentur from Germany and Natco from the UK. TRS from the UK is one of the largest suppliers of ethnic foods in Europe.

Table 3: Pigeon pea importers and wholesalers in Europe – examples

Company name	Country	Comment
Agrifood Trade	the Netherlands
AGT Poortman	UK/the Netherlands
Casibeans	Belgium
CFT Berlin	Germany	Own brand and third party
ETG World	the Netherlands	Raw and processed
Gunarajan Handelsagentur	Germany	Own brand
Ivyfoods	UK
Natco	UK	Own brand
NRG Imports	the Netherlands/Europe	Own brand and third party
TRS	UK/Europe	Own brand
Unidex	the Netherlands	Own brand
Pride Asia Food	UK	Own brand and third party
Western Impex	UK

Food manufacturers

Besides importers and wholesalers of pulses that also market their own brands, relevant food manufacturers in Europe include canning companies, packers, processors and brand product companies. Pigeon peas are not yet a mainstream pulse that is commonly used in food products in Europe. However, this may change in line with the increase in plant-based diets that goes along with growing demand for alternatives to animal proteins. Companies that use pigeon peas as an ingredient will mostly buy from specialised importers.

Processors of organic pulses may be an interesting target group for a less traditional pulse like pigeon peas. Pre-cooked organic pulses are sold by companies like La Bio Idea from the Netherlands or Rapunzel from Germany.

Retail channel

Dried pigeon peas are sold in retail packages commonly weighing 0.5-1.5 kg. In most of Europe, sales of pigeon peas are through ethnic stores and outlets. Online retailers, like Quality Foods Online or Ekirana, sell different varieties of branded pigeon pea products, either in their own country or throughout Europe. In the UK, mainstream supermarkets like Waitrose or Tesco sometimes also offer dried and frozen pigeon peas.

Figure 5: Example of a retail pack of pigeon peas

Source: Profundo

What is the most interesting channel for you?

Pigeon peas are not yet a mainstream product in Europe. Most of the pigeon peas sold on the European market are imported by companies that supply the ethnic food market. This applies specifically for the sizable Indian community in the UK, as well as African communities in several European countries. Imports from India are frequently part of mixed shipments together with other pulses and spices for specialty ethnic markets in Europe.

Since specialised ethnic food retailers dominate the market and often import themselves, you can best connect to such specialised importers. Larger traders with a varied offer of pulses and links to other European markets are found in the Netherlands and Belgium. In the future, innovative food brands that are interested in developing the market for pigeon peas may also create demand from other parts of the market.

To find a place on the market, consistent quality and sufficient volumes are important. If the available processing and cleaning technology in your country is not yet up to European standards, it is recommended to find a larger importer with their own cleaning facilities.

3. What competition do you face on the European market for pigeon peas?

According to FAO figures, global production of pigeon peas reached around 5 million tonnes in 2020. However, it seems that some smaller producers, like Peru, are not considered in these figures. The global production of pigeon peas is strongly dominated by India. In 2020, India accounted for around 78% of global reported production (Figure 6). Malawi (8%) and Myanmar (7%) followed in second and third place. Other East African countries like Tanzania and Kenya also contribute to production, along with small volumes in the Caribbean and Latin America. These other producers all had shares below 3%.

Which countries are you competing with?

Pigeon peas on the European market are only sourced from developing countries. Although Malawi has been the top supplier for several years now (Figure 7), export volumes show strong fluctuations owing to factors like an unorganised sector (especially in East Africa), changing prices and the impact of pests and pathogens such as fusarium wilt disease.

Pigeon pea imports to Europe peaked in 2020 during the height of the COVID-19 pandemic but slowed down again in 2021. This was the same for many food crops and notably for dried pulses with long shelf life. The ‘other’ origins include a varied selection of producers as well as countries that re-export pigeon peas from other origins.

Malawi: large producer focusses on export markets

Malawi is the second-largest producer of pigeon peas globally, reaching around 424,000 tonnes in 2020. The production is dominated by smallholders who intercrop with maize, sorghum and other crops. The country’s output has increased significantly in the last 20 years. This growth is mainly driven by the introduction of wilt-resistant varieties.

Despite its high nutritional value, only 10% of Malawi’s pigeon pea production is consumed domestically. It is still seen as a food to be eaten only when nothing else is available. In light of the negative impact of the COVID-19 pandemic, climate change and rapidly increasing costs for agricultural inputs, the Nandolo Farmers’ Association (NFA) in cooperation with Christian Aid want to encourage higher domestic consumption instead of exports to volatile markets. The farmers’ association has criticised the lack of structured markets for pigeon peas as contributing to the decreasing production of this pulse in the country.

In recent years, Malawi was the top supplier to the UK as the largest European market for pigeon peas. However, these volumes only account for a small share of Malawi’s overall exports of pigeon peas. Most exports are destined for India as well as neighbouring countries and sometimes the Caribbean. Malawi’s competitiveness is limited by high freight costs due to the land-locked position of the country and low pigeon pea grain quality compared to countries like Tanzania and Kenya.

India: largest producer and importer of pigeon peas with volatile demand

India is by far the largest producer and consumer of pigeon peas globally. Pigeon peas, or toor dal in Hindi, are among the most popular pulses in India and form the basis for various dishes.

Production reached 3.9 million tonnes or 78% of world production in 2020. While 2019 saw a dip to 3.3 million tonnes in Indian production, bumper crops in 2017 and 2018 resulted in 4.9 and 4.3 million tonnes, respectively. To meet domestic demand, imports of pigeon peas, mostly from African countries and Myanmar, reached 650,000 tonnes in 2017. These declined by around 20% in the following years due to massive surpluses from a large domestic harvest. As a reaction, the Indian government imposed temporary import restrictions on pigeon peas, especially affecting East African suppliers that rely on the Indian market.

Indian exports are very small compared to production and imports. Exports fluctuated between 9,000 and 15,000 tonnes in the last five years. On the small European market, India is nonetheless an important supplier. It is unclear whether Indian exports are sourced from Indian production or imported pigeon peas. Pigeon pea exports to Europe are almost entirely destined for the UK. These exports reached around 800 tonnes in the last two years (Figure 7). The role of India as a supplier of pigeon peas to this market is mostly linked to the large ethnic community from South Asia, particularly India.

Tanzania: suffering from Indian market loss, potential is seen in local and regional markets

Tanzania is among the top-5 producers of pigeon peas worldwide, but due to India’s dominance still only accounted for a share of around 3% in 2020. High-yielding varieties resistant to wilt were introduced several years ago, replacing the traditional pigeon pea variety (Babati white). The new varieties are also cultivated by small and marginal farmers with the main goal of selling to export markets.

Since 2018, Tanzania experienced a drop in the production of pigeon peas, followed by a slight increase in 2020. The import restrictions imposed by India in 2017 had a significant effect on pigeon pea exports from Tanzania and on hundreds of thousands of farmers. India is the country’s main export market but limited its purchases after a bumper crop. Due to the sudden market loss, more than 70,000 tonnes of pigeon peas were not harvested in 2017/2018 and went to waste on the fields. Tanzanian production declined the following years as farmers feared a further price drop. India lifted the import restrictions in April 2022 up until March 2023.

The government of Tanzania started a campaign in 2022 to promote the health benefits of pigeon peas, especially for schoolchildren, aiming to increase domestic consumption. Increased local consumption would reduce risks from sudden loss of markets, like what happened with India. At the same time, initiatives are being taken to develop the market in other African countries.

Myanmar: important supplier to key consumer markets

Production of pigeon peas in Myanmar fluctuated greatly in recent years. In 2020, Myanmar was the fourth-largest producer with a total of around 340,000 tonnes. The country exports a large share of its production, mainly destined for India. India’s imports from Myanmar fluctuate strongly, depending on its own harvest. In recent years, Indian imports from Myanmar fluctuated between less than 50% and more than 95%. In years when India lowers its imports, like during the import restrictions imposed in 2017, Trinidad and Tobago increases in importance as a recipient. Europe is only a tiny customer of Myanmar’s overall exports.

Kenya: heavily fluctuating exports, aims to increase production

Kenya is among the top pigeon pea producers in East Africa. According to 2021 figures, the country produced around 275,000 tonnes, considerably more than the 125,000 tonnes reported by the FAO for 2020. The country sees large potential for a boost in production for the domestic market as well as exports. This should be achieved by new varieties that are early-maturing and drought and disease-resistant. Pigeon peas are consumed in traditional dishes like pigeon peas in coconut milk (Mbaazi Wa Nazi).

The European Union has provided financial support to a 2021 pigeon pea extension manual (PDF) published by the Kenya Agricultural and Livestock Research Organization. The focus lies on new technologies for dryland farming and alternative disease and pest management methods.

Exports have heavily fluctuated in the last five years, with highs of up to 50,000 tonnes and a low of 850 tonnes. The key destination in years with high exports is Trinidad and Tobago. In Europe, Belgium received regular supplies between 100 and 500 tonnes.

Peru: small producer

It is unclear how many pigeon peas are currently produced in Peru. Since the country is not included in the FAO statistics, production is probably relatively low and informal. The Ministry of Agriculture recently supported a production programme in the Lambayeque region. The aim is to make pigeon peas more available to the local population. Peruvian company Andes Alimentos reports on its sourcing of organic pigeon peas from the Cajamarca and La Libertad regions.

According to trade statistics, Peru exports around 2,000 tonnes per year, with imports staying somewhat lower. In 2021, imports from Ecuador totalled 1,200 tonnes while exports reached 1,500 tonnes.

Which companies are you competing with?

ETG World is one internationally operating trader that plays a role across several African production countries. The Netherlands-based company helps small-scale farmers reach international markets. It has a presence in Malawi and Tanzania for the sourcing of pigeon peas.

Below are other local companies in developing countries that supply the European market.

Suppliers from Malawi

As the largest exporter to the European market in recent years, Malawi caters mostly to the UK. Exports to other European countries are very small and irregular. Companies include HMS Food and Grains, exporting split pigeon peas to countries like the UK, USA and India, and Rab Processors, exporting pigeon peas (split and whole).

Suppliers from India

India only exports small volumes of the total available pigeon peas from production and imports, but still accounts for a considerable share of European imports. These are split between a large number of Indian exporters.

Nature Bio Foods (NBF) is an important Indian exporter of organic pulses, including pigeon peas, as well as other dried pulses. It offers whole, split and de-husked varieties. It provides detailed product specifications including product characteristics, physical parameters and food safety information. On its website, NBF lists the various organic, food safety and social certifications for India, the Netherlands and the USA. NBF has its own subsidiaries in the Netherlands and the USA to better serve the local markets. The Kogta Group is another important supplier of split/non-split pigeon peas and other pulses. The company lists its various awards and recognitions on its website and stresses the quality of its production process. Similarly, pulse exporter Nima Enterprises provides information about its certifications and its processing and manufacturing setup on its website.

Other exporters from India include Shri Lakshmi Agro Foods with its brand Udhaiyam, Jayaco, M.K. International and Agronic Food.

Suppliers from Tanzania

R.V. Exports is engaged in the export of agricultural commodities from Tanzania, which include pigeon peas. Afrisian Ginning Ltd (AGL) is also involved in the export of pigeon peas from Tanzania. Both companies offer basic information about the products on their websites.

Suppliers from Myanmar

Paing Family International Co. is a diversified exporter of agricultural products, including pigeon peas, to European markets. Arkar Oo Co. is a HACCP-certified exporter of pulses, including pigeon peas, to the UK. It stresses the high quality of its products and its advanced processing capabilities. Other suppliers of pulses include Thwin International, Golden Key Co. and Shwe Thit Oo Co.

Suppliers from Kenya

Among exporters from Kenya is SUBA General Exports, a private company that specialises in the export of a wide variety of goods from Kenya to Europe, including pigeon peas. Greenfoods Agri is a global agri-business focussed on local and international markets for the trade of pulses and beans from East Africa.

Suppliers from Peru

Andes Alimentos is an important Peruvian supplier of dry pigeon peas that works closely with their producers to manage their fields with organic methods. On its website, the company presents its certifications and the network it has established through participation in fairs. Agro Fergi is another Peruvian exporter that emphasises its certifications, including EU Organic and BRC Certification. XPODEKA is an exporter that guarantees traceability of its products along with high food safety and quality standards. Other suppliers of pigeon peas include Copesba, Aplex Peru and Integral export.

Which products are you competing with?

To enter the European market for pigeon peas, fulfilling European food safety requirements and ensuring regular and reliable supplies of a high-quality product are important preconditions. The market for ethnic foods is quite established but has low growth rates. However, alternatives for Indian dishes exist, for example in the form of split yellow peas or lentils. To enter this market, a direct link with importers and wholesalers catering to this segment may be the most promising approach. Knowing the specific requirements, preferred varieties and other criteria for this specific market is an important advantage in finding an entry point.

The European mainstream consumer market for pigeon peas is by comparison very immature. Few consumers will have heard of pigeon peas, their characteristics and uses. There are various traditionally consumed and better-known pulses that compete for attention among European consumers, such as different varieties of beans, lentils and peas. Moreover, dried pulses increasingly compete with pre-cooked products that are offered for more convenience. However, the observed trend towards healthier, plant-based diets also offers opportunities for little-known pulses like pigeon peas, especially if they are available at competitive prices. Organic certification could be another important selling point as this market tends to offer more variety in pulses.

4. What are the prices for dried pigeon peas?

Prices for pulses like dried pigeon peas are influenced by various factors, including product quality and compliance with food safety requirements, as well as production and certification standards. Price fluctuations depend on varying supplies and the overall volatility of commodity markets. Prices are influenced by supply-and-demand in India as the major global market for pigeon peas. Lower Indian demand, like during recent years with high domestic production, can cause steep price drops in other producer countries. Given the current drastically rising energy and transport costs, origin also plays an increasingly important role in buying decisions.

Looking at the UK as the key European market, average import prices in the last five years varied between US$717 and US$1,187 per tonne between 2017 and 2021 (see Figure 8). During the COVID-19 pandemic, demand for pulses increased and the overall price level went up. Meanwhile, container freight rates spiked. On common trade lanes from Asia to Europe, the price for shipping a standard container increased more than sixfold since 2019. Increasing energy costs also affect the prices of processed products.

European retail prices for dried pigeon peas vary between €3.20 and €4.20 per kg. Retailers achieve the highest margins in the chain (Figure 9).

Profundo carried out this study on behalf of CBI.

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