Front-of-pack nutrition labelling in India
Authors: Richa Pande, SubbaRao M Gavaravarapu, Bharati Kulkarni
Journal: The Lancet Public Health (2020)

Indian policy-makers are trying to curtail the rising consumption of processed foods that are high in fat, sodium, and sugar.1Ministry of health and Family WelfareGovernment of India. National Health Policy.https://mohfw.gov.in/sites/default/files/9147562941489753121.pdfDate: 2017Date accessed: February 24, 2020Google Scholar Front-of-pack nutrition labelling is widely considered to be a powerful and simple tool for discouraging consumption of processed foods. The Food Safety Standards Authority of India is considering implementing symbol-based front-of-pack nutrition labelling, which they intend to make mandatory. In 2018, the Food Safety Standards Authority published draft regulations for front-of-pack nutrition labelling and made them available to the public online.2Food Safety and Standard Authority of IndiaNotice calling for suggestions, views, comments etc from stakeholders on the draft food safety and standards (labelling and display) regulations.https://www.fssai.gov.in/upload/uploadfiles/files/Draft_Notice_Comments_Labelling_Display_11_04_2018.pdfDate: 2018Date accessed: February 24, 2020Google Scholar It considered different symbols and nutrient profiling models and has proposed a format based on nutrient-level cut-offs derived using the recommended dietary allowances for Indians (described by the Indian Council of Medical Research). WHO recommendations will be considered when Indian-specific nutrient cut-off levels are not available.2Food Safety and Standard Authority of IndiaNotice calling for suggestions, views, comments etc from stakeholders on the draft food safety and standards (labelling and display) regulations.https://www.fssai.gov.in/upload/uploadfiles/files/Draft_Notice_Comments_Labelling_Display_11_04_2018.pdfDate: 2018Date accessed: February 24, 2020Google Scholar According to the proposed regulation, if the total amounts of calories, fats, trans-fats, sugar, and sodium per serving exceed the stipulated limits, it would be indicated in red colour. However, there are some concerns regarding the proposed labelling format. First, the proposed format focuses on nutrients of concern (fat, sugar, and salt). It is likely that many regional legume-based snacks, containing considerable amounts of protein, could be red labelled for salt and fat, whereas products like ready-to-consume buttermilk, which could contain relatively high amounts of added salt, will be exempt from mandatory front-of-pack nutrition labelling as they are considered single ingredient products.2Food Safety and Standard Authority of IndiaNotice calling for suggestions, views, comments etc from stakeholders on the draft food safety and standards (labelling and display) regulations.https://www.fssai.gov.in/upload/uploadfiles/files/Draft_Notice_Comments_Labelling_Display_11_04_2018.pdfDate: 2018Date accessed: February 24, 2020Google Scholar Such dichotomy could be misleading. The proposed front-of-pack nutrition labelling recommends following a per serving format, but other labelling formats using nutritive value per unit information could be tested in India.3Hawley KL Roberto CA Bragg MA Liu PJ Schwartz MB Brownell KD The science on front-of-package food labels.Public Health Nutr. 2013; 16: 430-439Crossref PubMed Scopus (322) Google Scholar Second, the proposed labelling format appears to be aimed only at individuals who are literate and nutritionally aware. Almost a quarter of the Indian population is illiterate,4Ministry of Home AffairsGovernment of IndiaState of literacy.http://censusindia.gov.in/2011-prov-results/data_files/india/Final_PPT_2011_chapter6.pdfDate: 2011Date accessed: February 24, 2020Google Scholar therefore pictorial representation would allow better engagement and understanding. Third, it will be crucial to involve the food industry. Unfortunately, Indian food industries have expressed many concerns over the proposed format,6Neo P Wrong move, wrong time: India's colour coded labelling regulations hit red light with the industry.https://www.foodnavigator-asia.com/Article/2019/07/15/Wrong-move-wrong-time-India-s-colour-coded-labelling-regulations-draft-hit-red-light-with-industryDate: Jul 15, 2019Date accessed: February 2, 2020Google Scholar especially using the colour red as it indicates danger and could dissuade consumers from their products. They argue that positive and voluntary labelling is accepted in many countries and should be encouraged in India. Although displaying nutrition information is already mandatory in India, a study5Vemula SR Gavaravarapu SM Mendu VVR Mathur P Avula L Use of food label information by urban consumers in India—a study among supermarket shoppers.Public Health Nutr. 2014; 17: 2104-2114Crossref PubMed Scopus (33) Google Scholar showed that Indians seldom use this information for making food choices as limited general and nutrition literacy mean understanding of the text-intensive nutrient information is difficult. However, this study5Vemula SR Gavaravarapu SM Mendu VVR Mathur P Avula L Use of food label information by urban consumers in India—a study among supermarket shoppers.Public Health Nutr. 2014; 17: 2104-2114Crossref PubMed Scopus (33) Google Scholar also shows that symbols on food labels (eg, vegetarian and non-vegetarian symbols) have better uptake and recall value. Therefore, it might be beneficial for front-of-pack labelling in India to be symbol based, with food images, logos, and health benefits. To be effective, front-of-pack symbols must be a part of the principal display panel and should have appropriate symbol-to-text ratio specifications. Mandatory front of pack labelling must be preceded by strong research and in a format that is understandable and acceptable to all. We declare no competing interests.