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Front of Pack Labelling in India

April - June 2021

Globally, unhealthy diets are the main reason for the increase in non-communicable diseases (NCDs) like cardiovascular disease, obesity,  diabetes and the like, resulting in innumerable deaths year after year. Varieties of processed and ultra-processed foods, which contain trans fats, high salt, sugar, saturated fats, and refined carbohydrates, are  available in the market making it  hard for consumers to identify and select the ones that are nutritious. Positioning nutritional information on the back or side of labels leads to a poor grasp of the nutritional information required by consumers to make healthy food choices Thus, the purpose of Front of Pack Labelling (FoPL) is to  empower consumers to make healthier choices by providing information about the overall nutritional quality/warning about the nutrients of concern present in  the food product, in a straightforward, easy, simple and clear manner. Some of the FoPL designs used around the world include the Nutri Score system that grades the overall nutritional quality of the food products from A to E, the Star Rating system that grades the products based on the overall nutritional content, and the Warning Labels system that alerts consumers to the presence of   high salt, high sugar and fats in processed food. The World Health Organisation (WHO) has developed a guiding framework to enable countries across the globe to develop, adopt, evaluate and monitor a suitable FoPL system.



Packaging and Labelling

The Food Safety and Standards Authority of India (FSSAI) introduced regulations on Packaging and Labelling in 2011. The ‘Food  Safety and Standards (Packaging and labelling)Regulations, 2011, mandated that prepackaged food products should include a description of food contained in the package long with a  list of ingredients used in it. With subsequent amendments, changes mandating format for displaying the license number, step by step regulations on trans fat, the display of warning messages such as ‘May not be nutritionally appropriate for pregnant and  lactating women and children under age of 5’, and  ‘Consumption of more than 3 gm shall be avoided’, the specification of gluten free food, labelling of edible oil and fat, limitations of dietary fibres in foods like flakes, noodles, pastas and savories, limitations on doses of radiation for food products like fresh fruits, vegetables, cereals and fish to inhibit ripening, delay ripening, insect disinfestation etc, the font size of the label and voluntary display of trans fat free logo, were included.

In 2018, the FSSAI proposed a draft Food Safety and Standards (Labelling and Display) Regulations, 2018, highlighting certain criteria for labelling and display on the front of food packs. Under this, the FSSAI proposed the Guiding Daily Amounts (GDA) design for FoPL , with the nutrient(s) of concern (high on sugar/salt/fats) in the food product to be marked in RED. The FSSAI also laid down the thresholds for sugar, salt/sodium and fats for various food and beverage categories which was in line with the WHO- SEARO model. Faced by opposition from the industry, the FSSAI developed a modified set of thresholds in 2019 – a study done and validated based on the Indian context and environment. However, due to continued resistance from the industry, this also did not see the day of light. 

Considering the constant increase in NCD’s and the related deaths in the country, it is important that the FSSAI notifies the FoPL Regulations soon. The thresholds should be scientific and evidence based as have been arrived at by the WHO and FSSAI, the measures units based (for example, per 100gms ) as against the serve size which could be very confusing, and the design should be simple and effective, providing clear warning about the presence of high sugar, salt and fat content in food. This will help consumers make informed choices and the industry reformulate in the interest of public health. 

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