New Delhi: The Food Safety and Standards Authority of India (FSSAI) intends to withdraw its 2022 draft regulations related to Front of Pack Nutrition Labelling (FoPNL) due to a lack of consensus among stakeholders on the viability of the model, according to an affidavit submitted by the regulator to the Supreme Court last month.
The 2022 notification of the draft regulations introduced the ‘Indian Nutrition Rating’ as a FoPNL model to rate the overall nutritional profile of packaged food and assign ratings from half a ‘star’ to five. It meant to provide a quick, easy, standardised way to compare similar packaged foods—the more the stars, the healthier the choice.
These regulations were finalised after a two-year consultative exercise and a survey conducted by the Indian Institute of Management-Ahmedabad (IIM-A).
However, in its affidavit, the FSSAI stated that the authority proposes to withdraw the regulations and conduct further research before finalising a mechanism for FoPNL.
The document was filed in a pending case that the Supreme Court is hearing. In April last year, a bench led by Justice J.B. Pardiwala had asked the FSSAI to carry out necessary amendments and take measures to implement FoPNL. The directions came on a Public Interest Litigation (PIL) filed by a consumer organisation, 3S And Our Health Society.
According to the FSSAI’s affidavit, as part of its fresh exercise, the authority will conduct surveys among consumers to assess the extent of usage of label information, conduct periodic review of FoPNL’s global trends, and conduct a wider stakeholder consultation with the industry, including small, medium, and micro enterprises, besides seeking views of consumer organisations.
The authority will also undertake a systematic mapping of a representative sample of different varieties of packaged foods—both solid and liquid.
For now, the FSSAI has told the top court that certain existing provisions of the Food Safety and Standards Act’s rules and regulations do indicate the true nature of all packaged food products.
The FSSAI has said that its decision to withdraw the 2022 regulations came in the backdrop of an expert committee’s report that highlighted a lack of consensus on star-rating for packaged food products, and the Committee of Secretaries’ (CoS) opinion, saying the issue required wider consultation.
In a meeting held on 9 October 2025, the CoS perused an expert committee’s report, which had been prepared after considering over 14,000 representations to the FSSAI in response to the 2022 regulations. The CoS then opined that there were serious concerns among stakeholders with the draft notification, as it did not balance the requirements of different sections. The CoS, therefore, held that the regulations were unfit for finalisation in their current form.
Observing a need to balance the requirements of different consumers, the CoS recommended that the FSSAI withdraw the draft notification to allow for a proper, comprehensive consideration of the issue.
In view of the expert committee’s observations that there was no consensus among stakeholders on the INR format draft notified by FSSAI, the recently submitted affidavit said that the FSSAI was not in a position to finalise the draft Food Safety and Standards (Labelling and Display) Amendment Regulations, 2022, notified on 13 September 2022.
Petitioner-advocate Rajiv Shankar Dvivedi, speaking to ThePrint on this development, said that the notification introduced a system for package labelling and that the lack of consensus was due to the varied demands of two contrasting sectors—the consumers and the big corporations.
“The industry wants labelling to be limited to fine print on the back of the product. But this information is not sufficient. We have to add value to the information by calling it whether it is good, bad, or indifferent,” Dvivedi explained.
Though the star-based system proposed in FSSAI’s 2022 regulations was not the best, at least it was a start to developing a mechanism where consumers could make an informed choice before purchasing a packaged food product, Dvivedi added.
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Proposals
Last week, Dvivedi, on behalf of the petitioner, submitted to the court a system followed in Israel under which the wrapper and packet of a pre-packaged food product contain warnings in red labels for items high in certain nutrients of concern.
Israel uses red warnings on products high in sodium/sugar/saturated fat, but products without red labels don’t automatically get a green one—they simply don’t carry the warnings if they’re below the harmful thresholds. A voluntary green label, however, exists, but it isn’t part of the mandatory front-of-pack warnings system.
Taking note of these submissions, SC gave four weeks time to FSSAI to revert to the proposal.
According to the FSSAI affidavit, two expert committees have so far reviewed the public representations the authority had received in response to the 2022 regulations. While the first unequivocally supported the INR system, saying it was based on scientific evidence, the second pointed to the lack of consensus among the stakeholders, even as it stressed the need for a “contextually acceptable system of FoPNL”.
The first expert committee considered 14,000 comments received from various stakeholder groups from 17 September 2022 to 17 April 2023. This committee concluded that the FoPNL definition in the 2022 regulations was comprehensive and suggested its enforcement within four years. Adoption of a star-rating system, instead of “least healthy and the healthiest,” would be self-explanatory and encourage consumers to “go for more stars”.
However, in its bid to ensure the regulations did not impact the livelihoods of smaller FBOs or food business operators, the expert committee advised granting adequate time and technical support for compliance in due course.
In early 2025, the FSSAI decided to hold further stakeholder consultations with Micro, Small and Medium Enterprises of India (MSMEs) on the FoPNL system.
As the tenure of the previous expert committee ended in April 2024, a new panel was reconstituted to study the fresh as well as the earlier 14,000 recommendations.
After reviewing the outcomes of the stakeholders meeting and hearing the viewpoints of the industry representatives as well as the MSMEs, the second expert committee noted that while one group preferred the non-interpretive format of listing nutrients of concern, such as sugar, salt, and saturated fat, in bold on the front of the pack, the other favoured colour-coded warning labels that clearly indicate if the levels of nutrients of concern are above the threshold.
The committee itself did not recommend the model of listing nutrients in bold formatting, but it advised the FSSAI to carry out a comprehensive food mapping. However, at the same time, it also recommended that studies, if any, should be conducted after the introduction of FoPNL so that its acceptability and effectiveness can be assessed.
FoPNL, according to this committee, should also be accompanied by policy measures, such as taxing unhealthy foods, curbing marketing of unhealthy choices to school-children, and public awareness campaigns. The committee also emphasised the requirement for ongoing monitoring of the impact of such measures over time.
(Edited by Madhurita Goswami)
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