New Delhi: Shifting away from interpretive front-of-pack warning labels, India’s food safety regulator has proposed a nutrition table for packaged foods.
In a compliance affidavit filed before the Supreme Court on 3 August, the Food Safety and Standards Authority of India (FSSAI) proposed displaying the government’s recommended daily limits for added sugar, saturated fat and salt alongside the nutrient content of a product per 100 g and its serving size, instead of using warning symbols to identify foods high in these additives.
The affidavit was filed in response to a public interest litigation by Kerala-based non-profit organisation 3S And Our Health Society, which has sought mandatory front-of-pack warning labels for foods high in fat, sugar and salt (HFSS).
In February this year, the Supreme Court directed FSSAI to revert within four weeks on a front-of-pack labelling framework for packaged foods. The bench of Justices J. B. Pardiwala and K. V. Viswanathan endorsed a suggestion that such labelling could include warning symbols for products high in sodium, sugar or saturated fat, alongside a positive logo for healthier products, and asked the authority to take this into consideration.
After reviewing FSSAI’s earlier compliance affidavit, the bench said it was “not satisfied” and observed, prima facie, that the exercise undertaken so far had “not yielded any positive or good result”.
Public health experts say the latest proposal moves away from the warning-label approach indicated by the court and instead places the burden of interpreting nutritional information on consumers.
“The court had pointed towards simple warning labels that consumers can understand instantly. Instead, FSSAI has proposed a numerical table that asks consumers to work out how much sugar, salt or fat a product contributes to their daily intake, weakening the purpose of front-of-pack labelling,” said Dr Arun Gupta, convenor of Delhi-based think tank Nutrition Advocacy in Public Interest India (NAPi).
What FSSAI has proposed
According to the affidavit, packaged foods would carry a table displaying the government’s recommended daily intake—25 g of added sugar, 10 g of saturated fat and 5 g of salt—alongside the amount of these nutrients present in the product per 100 g and its serving size.
Unlike interpretive warning labels, which immediately indicate when a product is high in sugar, salt or fat, the proposed format simply presents the numbers, leaving consumers to compare them with the recommended daily limits.
FSSAI said the proposal is based on the ICMR-National Institute of Nutrition’s Dietary Guidelines for Indians, 2024.
The affidavit also outlines the process followed before arriving at the proposal. After seeking additional time from the court in March, FSSAI held a stakeholder consultation on 19 March with consumer groups, industry representatives and farmer organisations.
According to the affidavit, most industry bodies opposed warning labels, arguing that labels should help consumers make informed choices without creating fear. FSSAI acknowledged that the consultation did not produce a consensus.
The regulator said it subsequently held discussions at the ministerial level, in the Central Advisory Committee and within the Food Authority before finalising the proposal placed before the court.
Experts question the proposal
Dr Gupta said the proposal overlooks the need to first define what qualifies as HFSS food and ignores the strong scientific evidence supporting interpretive warning labels.
“Without scientifically defined nutrient thresholds, it is impossible to decide which foods should carry a warning label,” he said.
He said the proposal shifts attention from the nutritional quality of the food itself to a person’s overall daily diet by asking consumers to compare product-level nutrient values with recommended daily intake limits.
Gupta also alleged that FSSAI relied heavily on the views expressed by industry during the March stakeholder consultation while largely overlooking written submissions made later by public health organisations.
Although the affidavit cites the ICMR dietary guidelines as the scientific basis for the proposal, Gupta said it does not incorporate some of the document’s key recommendations.
According to him, the affidavit does not address Guideline 15 of the dietary guidelines, which specifically focuses on reducing the consumption of packaged foods high in fat, sugar and salt and provides nutrient thresholds for total sugar and total fat.
He also said the proposal overlooks recommendations made in the Union government’s National Multisectoral Action Plan on Non-Communicable Diseases (2017), the Economic Survey 2025-26, and recent observations of a parliamentary committee, all of which have supported stronger front-of-pack warning labels.
In its affidavit, FSSAI said the proposed amendments will first be placed before the Food Authority for approval, followed by the Union health ministry. They will then be published as draft regulations inviting public comments before a final notification is issued.
(Edited by Viny Mishra)
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