On 13th September 2022, The Food Safety and Standards Authority of India (FSSAI) issued draft regulations FSS (Labelling and Display) Amendment Regulations, 2022. The FSSAI has proposed Star Ratings based on nutritional values termed as ‘Indian Nutrition Rating’ (INR) which rates the overall nutritional profile for packaged food by assigning ½ star (least healthy) to 5 stars (healthiest). According to the regulation, more stars indicate that the food product is better positioned to provide for daily human need of nutrients.

Read the regulation here

Important points of the Draft Regulation that are contentious

 Section 1 (2) – Compliance shall be voluntary until a period of 48 months from the date of final notification of these regulations and mandatory thereafter.

Section 2 (1) (ia). FOPNL is a form of supplementary nutrition information that presents simplified nutrition information on the front-of-pack of pre-packaged foods. It can include symbols/graphics, text or a combination thereof that provide information on the overall nutritional value of the food and/or on nutrients included in the FOPNL

Section 2 (2) (a). (a) in sub-regulation (2), after clause (b), the following proviso shall be inserted, namely, – “provided that the percentage of Fruits, Vegetable, Nuts, Legumes & Millets, if present in the food product, shall be declared”.

14. (2) (b)

The INR system rates the overall nutritional profile for packaged food by assigning it a rating from ½ star (least healthy) to 5 stars (healthiest). More stars indicate that the food product is better positioned to provide for daily human need of nutrients.

Schedule III. Table 1

Baseline reference values for Food risk factors and minimum percentage of positive factor per 100 gm or 100 ml on ‘as sold’ basis.

Objections or suggestions were invited by FSSAI after the publication of the draft regulation. Thousands of comments were submitted by experts, consumers, students and activists across India. Some of the comments submitted by experts, consumers and activists are given below:

 Comment submitted by Consumer VOICE | Comments submitted by students | Comment submitted by women | Comment submitted by Nutritionists

 FOPL draft regulation in news

Op-ed of Ashim Sanyal

The front of pack labelling draft regulation is not a healthy affair at all for consumers

TOI Editorial

Be Punchy on Munchy

India has the ill-fated title of the diabetes capital of the world with the figure expected to rise to an alarming mark of 69.9 million by 2025 and 80 million by 2030. With 1 in every 4 persons obese according to NFHS 5, early adoption of right food labels will help consumers make healthy food choices. The ultra-processed food sale in India is also witnessing an exponential growth and experts are worried about its impact on the rising prevalence of NCDs in India. 

One of the most effective tools to reduce consumption of HFSS foods is through mandatory warning lables on food packets.  Simple warnings can help consumers make informed choices and be a first step towards a healthy food system.  Keeping this aspect of improving health eco systems in India, Consumer VOICE organized 6 roundtable discussions with state partners across India.

Rajkot | Lucknow | Kolkata | Guwahati | Indore | Chandigarh

Rajkot, Gujarat

At an event organized in Rajkot, Gujarat on 16^th July, 2022 by Rajkot Saher Jilla Grahak Suraksha Mandal in association with Consumer VOICE, New Delhi, industry leaders, doctors and government officials from Gujarat called for simple, mandatory and interpretive front of pack labels on food and beverages.

Representatives of popular edible oil, FMCG, confectionary, snacks and sweets like recognized the need for effective measures in curbing the rising incidence of NCDs in the state. Some of the important names from the industry who participated in the workshop included Shri Samirbhai Shah, MD, Rajmoti Oil, Shri Vinodbhai Vyas, MD Rajkot District Cooperative Milk Products Union Limited Rajkot, Shri Chandubhai Patel, Balaji Wafers, Shri Pardipbhai Dhadhai, Gopal Snacks. Besides the industry experts, the event also witnessed a large gathering of doctors including Dr Vallabhbhai Kathiria,  Dr Digvijaysinh Jadeja, Dr VK Gupta and Dr RS Trivedi.

Front-of-pack food labelling is considered to be a powerful and simple tool for discouraging excessive consumption of processed foods. Shri Ashim Sanyal, from Consumer VOICE, New Delhi said that “Front-of-Pack warning labelling represents a key component of a comprehensive strategy to promote healthier lives. Every year more than 5.8 million Indians die of NCDs and most of these fatal diseases could be prevented by changing dietary habits and transforming the food industry.”

“Consumption of ultra-processed foods and packaged foods is in the rise in Gujarat and irrespective of the socio economic background, it is putting the lives of our children and youth at peril. We can improve the situation by letting the consumers make the right choice with a simple warning label on the front of food packets for unhealthy foods.” concludes Shri Ramjibhai Mavani, Ex MP and Founder President, Rajkot Saher Jilla Grahak Suraksha Mandal.

Lucknow, UP

In Lucknow, UP, the event was organized on 18th July, at Hotel Comfort Inn, Vibhuti Khand, Gomti Nagar by Consumer Guild in association with Consumer VOICE. Representatives of popular edible oil, FMCG, confectionary, snacks and sweets like recognized the need for effective measures in curbing the rising incidence of NCDs in the state. Some of the participants in the event titled Front of Pack Labeling – Role of the Industry” included Manish Agarwal – Assocham, DP Singh – Indo American Chamber of Commerce , Ramesh malhotra- Ritz, Abhitosh Asthana of Pure Gonics and SP Singh Assistant Commissioner, UP Food Safety and Drug Administration and Chief Food Safety officer of same department participated.

Rinki Sharma from Consumer VOICE who also graced the occasion said that the lives of our children and youth at peril because of high consumption of HFSS foods and simple warning labels can ease the situation.

Sh. Abhishek Srivastava, Chairman- Consumer Guild, Lucknow spoke about the rise in NCDs in the State of Uttar Pradesh and the need reduce consumption of unhealthy packaged foods through simple and mandatory warning labels.

Kolkata, West Bengal

The event in West Bengal, Kolkata was organised by Honcho Tech For Good Foundation, Kolkata in association with Consumer VOICE, New Delhi, industry leaders, doctors and government officials from West Bengal called for simple, mandatory and interpretive front of pack labels on food and beverages. Simple warnings can help consumers make informed choices and be a first step towards a healthy food system.

Dr Sadajit Banerjee, MD, Medicine said, ”High burden of diabetes, obesity, stroke and cardiovascular diseases are linked to the increased consumption of unhealthy packaged foods that are High in Salt, Sugar and Fats that are readily available in the market.”

Representatives of popular edible oil, FMCG, confectionary, snacks and sweets like (PS Brand Oil, Ruby Food Products Pvt. Ltd., Pran Foods Ltd., Sugar and Spice, Bapuji Cake Pvt. Ltd.) recognized the need for effective measures in curbing the rising incidence of NCDs in the state. As important stakeholders for a healthy nation, they lent their support to a people friendly FOPL. Kaushik Nag of Pran Foods Ltd. said that ”We are committed in ensuring healthy food to our consumers and will take necessary steps as guided by FSSAI and the scientific community in ensuring that our products meet global standards.”

”A key step in this is to ensure that ingredients that like salt, sugar, and fats are used within permissible global limits.” said Indranil Dasgupta, Director – Social Initiatives, Honcho Tech For Good Foundation.

Front-of-pack food labelling is considered to be a powerful and simple tool for discouraging excessive consumption of processed foods. Nilanjana Bose, Project – Head from Consumer VOICE, New Delhi said that ”Front-of-Pack warning labelling represents a key component of a comprehensive strategy to promote healthier lives. Every year more than 5.8 million Indians die of NCDs and most of these fatal diseases could be prevented by changing dietary habits and transforming the food industry.”

Recognizing the importance of measures like high taxes on sugary foods and Front of pack labels, Luna Chatterjee, Brand Strategist, Partner Curator CCi’s, Foodpreneur said that ” We are taking baby steps towards labelling and having FOPL will work wonders for the industry. It will not only help in improving public awareness regarding food ingredients but also deter consumers from consuming unhealthy and harmful food. ”

Guwahati, Assam

The industry roundtable discussion was organized in Guwahati by Consumers’ Legal Protection Forum, Assam in association with Consumer VOICE, New Delhi.

Representatives of popular edible oil, FMCG, confectionary, snacks and sweets like Repose, Sitajakhala, Nivaz recognized the need for effective measures in curbing the rising incidence of NCDs in the state. As important stakeholders for a healthy nation, they lent their support to a people friendly FOPL.

Swapan Nath, General Manager, REPOSE said that “We are committed in ensuring healthy food to our consumers and will take necessary steps as guided by FSSAI and the scientific community in ensuring that our products meet global standards.” “A key step in this is to ensure that ingredients that like salt, sugar, and fats are used within permissible global limits’ Dr. Birendra Kumar Das, Chairman, NIVAZ said.

Front-of-pack food labeling is considered to be a powerful and simple tool for discouraging excessive consumption of processed foods. Nilanjana Bose from Consumer VOICE, New Delhi said that “Front-of-Pack warning labeling represents a key component of a comprehensive strategy to promote healthier lives. Every year more than 5.8 million Indians die of NCDs and most of these fatal diseases could be prevented by changing dietary habits and transforming the food industry.”

“Consumption of ultra-processed foods and packaged foods is in the rise in Assam and irrespective of the socio economic background, it is putting the lives of our children and youth at peril. We can improve the situation by letting the consumers make the right choice with a simple warning label on the front of food packets for unhealthy foods” said Advocate Ajoy Hazarika, Secretary, Consumers’ Legal Protection Forum, Assam .

Recognizing the importance of measures like high taxes on sugary foods and Front of pack labels, Hrishikesh Acharyya, Managing Director, SITAJAKHALA said that “We welcome the idea of a strong FOPL that will help consumers quickly understand and identify healthy foods. Global evidence points to warning labels having immediate health benefits but also being favorable to the industry. There is affordable technology and market acceptance for food industry to ensure that food and beverages are healthier as per global standards.” Speaking at the event, Samiran Baruah, Designated Officer and Anupam Gogoi, Food Analyst, Commissionerate of Food Safety, Govt. of Assam said, “We will ensure that food companies are abiding by the standards which will improve the health of consumers of the state. “

Indore, MP

A  Roundtable consultation on ‘Front of Pack Labelling – Role of the Industry’ was organised by Consumer VOICE in partnership with Indore based AAS and Bhopal Based National Centre for Human Settlements & Environment (NCHSE) at Indore on 25th July 2022.

Shri Hariram Mujalda, Joint Director, Industries, ZIO-Indore was the Chief Guest on the occasion.

Mr. Avinash Shrivastava, Dy Director, NCHSE welcomed the guests and the participants and appraised the participants about the programme.

Ms. Rinki Sharma, Project Head, Consumer VOICE while sensitizing the participants especially the Industry Managers on the issue of NCD burden and its causes in India, said that “Amidst the rising concerns over obesity and other non-communicable diseases (NCD) ailments in our country, it becomes imperative for consumers to be a stakeholder in deciding what to eat and what is to be avoided. Front-of-Pack warning labeling represents a key component of a comprehensive strategy to promote healthier lives. It enables consumers to identify in a quick, clear and effective way, products high in salt, sugar and fats. She also highlighted that every year more than 58 lakh Indians die of NCDs and most of these fatal diseases could be prevented by changing dietary habits and transforming the food industry. She produced successful examples of FOPL adopted by other countries.  She further elaborated upon ongoing process of development of FOPL in the country and reasoned out why a warning label indicating “High in” sign of particular nutrient is required for the protection of interest of the consumers and how the industry could facilitate it.

Dr. Pradip Nandi, DG, NCHSE while introducing the subject said that in India Non-communicable diseases (NCDs) like diabetes, hypertension, heart disease and obesity are of growing concern.  In 2016 India reported 63% of total deaths due to NCDs, of which 27% were attributed to Cardiovascular disease (CVD). One of the main reasons of such NCD burden is the consumption of unhealthy foods that are high in fat, salt or sugar and are readily available in the market.  He also stressed the importance of the threshold level of daily intake of fat, salt and sugar as recommended by WHO and a FOPL on the packaged food indicating warning for any nutrients which are more than the permissible limits.

The Chief Guest Shri Mujalda in his address said that India is facing a daunting task of minimizing the Non-communicable disease (NCD) burden due to consumption of unhealthy foods, which are high in Fat, Sugar and Salt. He stressed that it is important that packaged foods should clearly indicate levels of these nutrients to provide the consumers an opportunity to choose the healthy food items. He further said that this could be achieved by developing a consumer friendly FOPL, for which Industries should come forward and expressed their views. He called upon the industry managers to ensure that the levels of ingredients like salt, sugar and fats in their products are within permissible global limits. He expressed hope that industry would abide by the regulations about the FOPL to safe guard consumer interest. He also said the Industries Department is willing to extend all possible support to the Food industry implement the regulation when it is finalized.

Representatives of popular edible oil, FMCG, confectionary, snacks and sweets like Gokul ke Namkin, Amitabh Business Corporation, Moksha Confectionary Pvt Ltd, Raj Packaging, Agarwal Namkin, Om Namkin, Shree Khrishna Enterprises, Soni Food, Jaiswal Enterprises etc participated in the Roundtable Discussion and expressed their views about FOPL/Warning Label. In general Industry Managers appreciated the need for FOPL to ensure effective measures in curbing the rising incidence of NCDs in the state. As important stakeholders for a healthy nation, they lent their support for a people friendly FOPL. Shri Amitabh Singhal of Amitabh Business Corporation said that “We are committed in ensuring healthy food to our consumers and will take necessary steps as guided by FSSAI /Government.”

Chandigarh

The Industry Consultation Round Table discussion in Chandigarh was held on 25th July by Citizens Awareness Group in association with Consumer VOICE, New Delhi. Industry leaders, doctors and government officials from the region called for simple, mandatory and interpretive front of pack labels on food and beverages. Simple warnings can help consumers make informed choices and be a first step towards a healthy food system.

Recognizing the importance of measures like high taxes on sugary foods and Front of pack labels, Sanyal said that “We welcome the idea of a strong FOPL that will help consumers quickly understand and identify healthy foods. Global evidence points to warning labels having immediate health benefits but also being favorable to the industry. There is affordable technology and market acceptance for the food industry to ensure that food and beverages are healthier as per global standards.”

Speaking at the event, Sukhwinder Singh from the Food Safety Department said, “We will ensure that food companies are abiding by the standards which will improve the health of consumers of the state.”

“Consumption of ultra-processed foods and packaged foods is on the rise in Chandigarh and irrespective of the socio economic background, it is putting the lives of our children and youth at peril. We can improve the situation by letting the consumers make the right choice with a simple warning label on the front of food packets for unhealthy foods.” concludes Surinder Verma, Chairman, Consumer Awareness Group.