Elsa Angel Rose
The Food Safety and Standards Authority of India (FSSAI) has proposed introducing front-of-pack labels to warn consumers when foods are high in salt, sugar, or fat. The move has been prompted by the apex court. The introduction of front-of-pack labels is proposed to be implemented in two phases. In the first phase, only products with a high content of at least two of the nutrients will carry the warning label. In the second phase, the warning will extend to products high in even one nutrient. The FSSAI affidavit proposes a red hexagonal front-of-pack warning label for packaged foods high in two or more nutrients of concern, added saturated fat, sugar, or salt, based on thresholds specified under the Dietary Guidelines for Indians, 2024, issued by the Indian Council of Medical Research-National Institute of Nutrition. Food products inherently rich in fat, sugar, and salt, such as ghee, edible oil, sugar, jaggery, and honey, as well as other similar products and single-ingredient products, are exempted, according to the proposal. There has been both praise and criticism of the move. While food products already contain back of-pack labelling, is there a need for front-of-pack labelling? What difference will front-of-pack labelling make? How effective will it be in ensuring food safety? Can front-of-pack labelling alone suffice to ensure food safety and eventually confront the escalating crisis of obesity and other lifestyle diseases in India? These are some of the overriding questions that consumers, manufacturers, and many others have.
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WHAT IS THE NEED FOR FRONT-OF PACK LABELLING WHEN BACK-OF PACK LABELLING EXISTS?
A pretty common doubt that has come up is: Most food products already have warning labels, ingredient details, and other information on the back of the package. So, why is a front-of-pack label needed, and what difference will it make? “The problem with the back-of-pack nutrition panel is that consumers may not notice, understand, or use it while making a rapid purchasing decision. A front warning is more communicative; it stares at us in the eye and tells us that there is something nutritionally important about this product that one should notice before buying it. FOP labelling was proposed to provide simplified information more prominently. But there is an important caveat, as we already know – symbols and prints on a commercial product do not automatically deter a consumer from picking it up! Cigarettes are a case in point!” explained Dr Sheryl Afonso, a clinical nutritionist.
CAN FRONT-OF-PACK LABELLING SOLVE INDIA’S HEALTH CRISIS?
“Front-of-pack labels alone cannot solve India’s growing burden of obesity, diabetes and heart disease. The problem is much bigger than simply whether a consumer can identify an unhealthy product. A major concern is that a large proportion of the food environment around us is increasingly dominated by products that are cheap, highly processed and heavily marketed. Consumers often want food that is both affordable and convenient, but what is easily available to them is not necessarily healthy or of good nutritional quality. So, front-of-pack labelling can help, but it cannot be the entire solution,” said Sachin. Obesity is one of the biggest health dilemmas India faces. Dr Ashmitha Padma, Consultant – Internal Medicine, shared, “Obesity is an important risk factor for the development of metabolic dysfunction such as insulin resistance and type 2 diabetes mellitus. Diet, which includes highly processed foods containing a high percentage of saturated fats, sugars and salt, contributes to obesity and metabolic disease not only through increased caloric content, but also through systemic effects that induce inflammation and dysregulation of metabolic function. Given that environmental factors, lifestyle preferences, and cultural environment all play significant roles in obesity development, a comprehensive approach is required to address this public health problem.”
HOW EFFECTIVE CAN FRONT-OF-PACK LABELS BE?
“I would say it can be useful, but in its current form, there is a risk that front-of-pack labels simply become a duplication of information that is already available on the packaging. The bigger issue we need to address is not just the presence of ingredients, but the way products are marketed and the misinformation or misleading impressions created around them,” shared Sachin Sutar, an IFSI-certified nutritionist from Velha. According to this nutritionist, rather than adding front-of-pack labels, what is required is way more transparency, curbing misleading advertisements, celebrity endorsements and more. “The actual quantities of sugar, palm oil and fruit content, for example, could be displayed prominently and perhaps in a simple graphical format so that an ordinary consumer can immediately understand what they are buying. The fact that products creating such health or nutrition impressions can still reach the market shows that we have a much larger regulatory and consumer protection challenge to address. Front-of-pack labelling can be one part of the solution, but unless we also address misleading advertising, celebrity endorsements and the way these products are presented to consumers, its impact will remain limited,” said Sachin. The phase 1 of the front-of-pack labelling proposal requires the warning labels to be put only on food products which have 2 ingredients that are high in salt, sugar or fat, and also the proposal focuses more on added sugars and saturated fats than total sugar and fat content. This creates loopholes. “It means that a carbonated drink or fruit juice dangerously high in sugar (one ingredient out of the 3) could completely escape carrying a warning label because it doesn’t contain salt or fat! Also, the framework focuses heavily on added sugars and saturated fats rather than total sugar and fat content, running contrary to the stricter ICMR NIN guidelines and creating analytical loopholes for companies. The focus should, therefore, be on a scientifically sound system that clearly identifies foods high in nutrients of concern, rather than simply counting how many nutrients cross a threshold,” said Dr Sheryl.
WHAT MORE STEPS CAN BE INITIATED?
India’s lifestyle problem is not entirely caused by consumers failing to read packets or manufacturers failing to put it (neither is ideal). Portion size, sedentary behaviour, and many other reasons are forefront players in this health crisis. “Expecting a red hexagon to reverse these trends would be an overstatement of what labelling can accomplish. Front of-package warning labels can be one component of a comprehensive NCD-prevention strategy, but they cannot substitute for nutrition education, physical-activity promotion, and population-level preventive healthcare,” said Dr Sheryl. Regarding effective steps that can be taken besides front-of-pack labelling, Dr Sheryl explained, “Reformulate the food supply; manufacturers can be encouraged or required to progressively reduce sodium, sugars, saturated fats, trans fats, and excessive energy density in their products. Changing the food itself means every consumer benefits, including consumers who do not read labels. Improve school food environments. Make nutrition education practical rather than theoretical. Make it mandatory for every educational institution and food supplier/ manufacturer to employ a full-time qualified Nutritionist. Regulate nutrition and health claims more aggressively.” The nutritionist pointed out another strong point, “With labelling, we are putting the onus of healthy eating on the consumer. How about shifting responsibility across the system? Including the regulator, schools, the healthcare system, public-health policy.
