Experts back warnings for high level of each nutrient — not just fats, sugar, or salt content

Why in the News

A front of pack warning should be triggered when a food carries a high level of any single nutrient, and not only when it is high in two nutrients at once. That position has been put to the Food Safety and Standards Authority of India (FSSAI), the country’s food safety regulator, by global nutrition researchers and by the ICMR National Institute of Nutrition (NIN), whose Dietary Guidelines for Indians 2024 supply the thresholds being used. FSSAI has proposed a red hexagonal warning triggered only where a food is high in two of three nutrients in the first phase, moving to each nutrient in the second. The Supreme Court is separately examining a petition to make front of pack labels mandatory on foods high in fats, sugar or salt. What is contested is how far the first phase label can be diluted before it stops doing the work it exists to do.

What is a front of pack warning label?

1. Front of pack warning label: A mark placed on the front face of a packaged food declaring that the product carries a high level of a nutrient of concern.
2. Nutrients covered: The Indian proposal covers fats, sugar and salt.
3. Threshold basis: A warning appears once the nutrient crosses a defined cut off, and those cut offs are referenced to the Dietary Guidelines for Indians 2024.

What do the experts want the trigger rule to be?

1. Single nutrient trigger: The warning should be triggered for each nutrient separately, so a food high in salt and in fat carries a red hexagon stating each.
2. Multiple labels as a signal: Evidence from Chile shows consumers understand products carrying more warning labels to be less healthy than products with fewer or none.
3. Evidence of impact: Warning labels are the only type of label with real world evidence of impact. That evidence covers consumer beliefs and behaviour, the nutritional profile of the food supply, and the healthfulness of purchases and dietary intake.

Why are the colour and background of the label contested?

1. Visual absorption into packaging: A colour based label placed over packaging of a similar colour becomes less noticeable, and surrounding graphic elements can minimise it further.
2. Black hexagons: The experts asked for black hexagonal boxes in place of the red one, since black and white designs are harder to visually mask on colourful packaging.
3. A fixed contrasting background: Mandating a white background behind the warning preserves its purpose, which is rapid identification at a glance.

What does the ICMR National Institute of Nutrition add on thresholds?

1. Energy density as the basis: The thresholds for identifying foods high in fats, sugars and salt should be set on the total energy density of the food.
2. No cut off read in isolation: Added fat and added sugar cut offs should not be considered apart from the accompanying energy and total nutrient content. FSSAI told the court that the warnings would be triggered on the levels of added sugars and added fats.
3. The failure mode of a two nutrient rule: Products substantially high in one nutrient escape consumer attention while the two nutrient trigger operates.
4. Higher thresholds, time bound: Where phasing is operationally necessary, a time bound transition at higher thresholds, progressively lowered, avoids indefinite postponement.

What has the Supreme Court asked the regulator for?

1. A justified timeline: The Court has asked FSSAI for a scientifically justified and clearly defined timeline for implementing the second phase.
2. The recorded reason: Without such a timeline, the Court said, implementation may take a backseat or be postponed indefinitely.
3. Sweetened beverages: The Court also sought clarity on which sweetened beverages will receive the warning in the first phase.

Challenges to the front of pack warning label

1. Reach into the unpackaged food trade: A label rule touches only packaged food, and a large share of what is sold in India moves loose or through small manufacturers. Eg. Street sold namkeen and locally packed sweets carry no nutrition panel at all.
   The Fix: Tie labelling compliance to the FSSAI licence and registration number small manufacturers already hold, so enforcement runs through an existing list.
2. Reformulation to the threshold rather than to health: A manufacturer can cut a flagged nutrient just below the cut off while leaving the product’s overall energy unchanged. Eg. Sugar trimmed slightly and offset by fat keeps a product under the trigger.
   The Fix: Review the cut offs on a fixed cycle against reformulation data collected from the market.
3. Legibility on small packs: A hexagon on a single serve sachet occupies too little area to be read at a glance, which defeats the design’s purpose. Eg. Single serve sachets dominate rural sales of biscuits, chips and instant noodles.
   The Fix: Set a minimum label size as a share of the front panel rather than as an absolute dimension.
4. Regulatory delay through consultation: Labelling rules draw sustained industry objection, and each further round of consultation pushes implementation out. Eg. The Indian Nutrition Rating star system, put out in draft in 2022, has still not taken effect.
   The Fix: Notify the second phase thresholds in the same regulation as the first, so the transition needs no fresh rule making.

Conclusion

The question is no longer whether India will label packaged food but whether the first version of the label is strong enough to be worth carrying. A trigger that waits for a second nutrient builds a gap into the rule and gives manufacturers a period in which the worst single nutrient products stay unmarked. The regulator now has to answer the Court with a dated transition rather than a stated intention, and that answer is what decides the value of everything already agreed.

Back2Basics: Food Safety and Standards Authority of India

1. Statutory body established under the Food Safety and Standards Act, 2006.
2. Functions under the Ministry of Health and Family Welfare.
3. Lays down science based standards for food articles and regulates their manufacture, storage, distribution, sale and import.
4. Issues licences and registrations to food businesses and runs the national food safety surveillance system.

Matching Previous Year Question

“[2016] With reference to pre-packaged items in India, it is mandatory to the manufacturer to put which of the following information on the main label, as per the Food Safety and Standards (Packaging and Labelling) Regulations, 2011? 1. List of ingredients including additives 2. Nutrition information 3. Recommendation, if any, made by the medical profession about the possibility of any allergic reactions 4. Vegetarian/non-vegetarian Select the correct answer using the code given below. (a) 1, 2 and 3 (b) 2, 3 and 4 (c) 1, 2 and 4 (d) 1 and 4 only Answer: (c)”