The Food Safety and Standards Authority of India (FSSAI) has proposed a single-phase rollout of front-of-pack nutrition labelling (FoPL) with a four-month period to finalise the draft regulations. This will be followed by a voluntary compliance window of 365 days for food businesses.
The proposed 365-day transition period is aimed at preventing commercial losses arising from existing stocks of printed packaging material.
In this system, products high in salt, sugar or fat would carry red warning symbols even if only one of those ingredients exceeds limits.
This is different from FSSAI’s earlier plan of including warnings only when two ??ingredients breach thresholds.
The proposal was submitted before the Supreme Court in a compliance affidavit filed in response to the court’s September 10 order in a case concerning front-of-pack nutrition labelling.
FSSAI said the draft amendment regulations would be placed for a mandatory 60-day consultation with stakeholders in India and through the World Trade Organization platform before being finalised and sent to the ministry for publication in the official gazette.
Under the proposed framework, packaged food products exceeding specified thresholds for nutrients of concern, would carry a red hexagon on a white square background on the front of the package, with the label naming the nutrient concerned.
Where two or three nutrients cross the prescribed thresholds, the same hexagon would carry the names of the applicable nutrients. The warning would be positioned prominently on the top left of the front of the pack, with the font at least one point larger than that used in the nutrition information table at the back.
In its affidavit, FSSAI said the proposed design draws broadly from the Canadian front-of-pack labelling model. The regulator has proposed using the Dietary Guidelines for Indians, 2024, issued by the ICMR-National Institute of Nutrition (ICMR-NIN), as the basis for nutrient thresholds.
Unlike the earlier proposal that contemplated a two-phase implementation, the latest affidavit says products high in any one of the specified nutrients would be covered.
FSSAI has also proposed a separate front-of-pack warning, “contains non-calorific sweetener”, for certain products, which is currently required on the back of the pack.
For beverages, the proposed format would identify the relevant beverage category where the prescribed nutrient threshold is crossed.
Categories listed include carbonated water, non-carbonated water-based beverages, fruit beverages, fruit drinks, ready-to-serve fruit beverages, fruit syrups, synthetic syrups, fruit-based beverage mixes and caffeinated beverages.
Importantly, FSSAI has said the level of food processing would not determine whether a product attracts the warning. Instead, the regulatory trigger would be a nutrient content.
For instance, a freshly prepared lemon drink containing added sugar or salt above the prescribed threshold could attract a warning, while packaged chips would be assessed on their added fat and salt content irrespective of their processing category.
The affidavit proposes thresholds for added sugar, added fat and salt based on the 2024 dietary guidelines.
FSSAI has indicated a preference for considering added sugar and added fat, rather than total sugar and saturated fat, for the front-of-pack assessment. It said naturally occurring sugars in foods such as fruit and milk are accompanied by other nutrients and therefore need to be distinguished from sugars added during processing.
FSSAI said the longer period is also based on recommendations of a high-level committee of NITI Aayog, which had proposed extending the labelling compliance period from 180 days to one year.
Separately, FSSAI told the court it would undertake nutrition-awareness campaigns, including through schools. It has proposed collaboration with the education ministry and CBSE to introduce food and nutrition literacy in school curricula and encourage schools to obtain its Eat Right School certification.
