The Debate Over Food Labelling Guidelines in India

Introduction

India stands at a critical juncture in its public health reform, facing a sharp rise in lifestyle-related diseases. A key initiative under review is the introduction of clearer food labelling on packaged products to help consumers make informed nutritional choices. The Food Safety and Standards Authority of India (FSSAI) has proposed new guidelines; however, the current approach — a Health Star Rating (HSR) — has drawn criticism for failing to effectively warn consumers about harmful ingredients. Experts argue that direct, visual warning labels would be more impactful and inclusive.

1. What triggered the current discussion on food labelling in India?

A Public Interest Litigation (PIL) filed by NGOs 3S and Our Health prompted the Supreme Court to direct the government to finalise and implement food safety labelling norms within three months. The case highlighted the growing consumption of foods high in salt, sugar, and fat — and the urgent need for clear, visible warnings on such products.

2. What are the current proposals from the government?

In September 2022, FSSAI introduced draft Front-of-Package Nutrition Labelling (FOPNL) guidelines featuring the Indian Nutrition Rating (INR), a star-based system ranging from 0.5 to 5 stars — where more stars indicate a healthier product.

Main components of the draft FOPNL guidelines:

• Indian Nutrition Rating (INR): Summarises a product’s overall nutritional quality using an algorithm.
• Mandatory FOPNL for select categories: Initially applies to high-consumption packaged foods with significant public health impact.
• Nutrients of concern: Total sugar, saturated fat, trans fat, and sodium.
• Exemptions: Raw food items like milk, eggs, fruits, vegetables, meat, and fish.
• Voluntary implementation: To become mandatory in phases.
• Star display: Shown on the top-right corner of the package, from 0.5 (least healthy) to 5 stars (most healthy).
• Limitation: No direct warning symbols for high fat, sugar, or salt content.

Criticism of the draft:

The star rating can mislead consumers since manufacturers can improve scores by adding small amounts of protein or fibre. For example:

• A sweetened cereal fortified with vitamins may still receive 4 stars despite high sugar content.
• A chocolate bar with nuts might score higher, masking its excessive fat levels.

This weakens the system’s effectiveness, especially when shoppers make quick decisions within 6–8 seconds at the shelf.

3. Why are experts opposing the star rating system?

Public health experts argue that the star system:

• Oversimplifies complex nutritional information
• Can be manipulated through token healthy ingredients
• Fails to clearly warn about high-risk nutrients like sugar or salt
• Is difficult for consumers with low literacy to interpret quickly

4. What alternative model is being recommended?

Experts advocate for “warning labels”, inspired by Chile’s model. These use black octagonal symbols prominently placed on packaging to indicate:

• Excess sugar
• Excess salt
• Excess saturated fat
• High calorie content

These visual warnings are universally understandable, even for non-literate consumers, making them a more inclusive solution.

5. What real-world evidence supports the warning label model?

In Chile, 18 months after implementing warning labels and restricting junk food advertising:

• Consumption of sugary beverages fell by 25%
• Children’s exposure to unhealthy food ads declined significantly
• School environments improved due to junk food restrictions

(Source: PLOS Medicine, 2019)

6. What are civil society groups demanding?

• Transparent, balanced stakeholder consultations
• Equal representation for consumers, nutritionists, and NGOs — not just industry bodies
• Immediate shift from star ratings to symbol-based warning labels
• Stronger regulation for informal and counterfeit food markets

7. How inclusive are India’s current labelling efforts?

Current FOPNL rules apply largely to the formal packaged food sector. However, India’s vast informal market — including sweet shops, roadside stalls, and small-scale producers — remains outside regulation. This enforcement gap undermines consumer protection.

Experts recommend that FSSAI:

• Enhance intelligence and monitoring systems
• Expand coverage to unbranded and small-scale food producers

8. Why are ultra-processed foods a growing concern?

Ultra-processed foods are gaining popularity in urban and semi-urban India. These items are typically energy-dense but nutrient-poor, contributing to rising obesity, diabetes, and hypertension. Aggressive marketing towards children further worsens the issue. Warning labels can counteract this trend by promoting awareness and encouraging healthier choices.

9. What changes are expected next?

Following the Supreme Court’s directive, FSSAI must finalise and implement the new guidelines within three months. Civil society groups are pressing for:

• Adoption of warning labels as the default labelling system
• Time-bound rollout with clear implementation phases
• Strict compliance checks, especially in Tier-II and rural areas

10. Why is this debate critical for India’s future?

India is witnessing a surge in non-communicable diseases (NCDs) driven by unhealthy diets. With public healthcare systems under strain, an effective food labelling policy can reduce disease burden, healthcare costs, and mortality — empowering citizens to make better, informed dietary decisions.