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Column | Front-Of-Pack Warning Labels On Packaged Food Are Must

When regulating the marketing of unhealthy industrial food items, can the FSSAI stand up to the industry it is meant to police?

Where’s the Warning?: Front-of-pack labels need to provide Indian consumers more details | Photo: Shutterstock

Packaged chips, noodles, biscuits, chocolate, sugary drinks or juices are all mostly industrially formulated ultra-processed food products (UPFs) high in fat, sugar or salt (HFSS), known as nutrients of concern. They also contain additives, colours and flavours. These combinations are used to make them addictive. But the front-of-pack label (FOPL) does not display any such information. The Food Safety and Standards Authority of India (FSSAI) has been working on the FOPL policy for over a decade. The food industry was always consulted as a key “stakeholder” and opposed any warning that the public-health people argued for. The FSSAI called it “lack of consensus” and did little. Serious public allegations followed that the regulator was protecting industry profits.

A public-interest litigation by the charitable society 3S and Our Health brought the matter to the Supreme Court. In February 2026 the court asked the FSSAI to put warning labels on HFSS foods. The FSSAI responded in August, denying warning labels. The court warned that it would issue directions. The FSSAI then agreed on labels, however, lacunae existed in the proposal. On September 10, the court asked the FSSAI 13 questions anchoring the issue in Article 21—the right to health, and Article 47—the state’s duty to improve public health. Some of these are: why should a warning appear only when a product is high in two or more nutrients? Why is there no timeline for phase two? Why are there no pictures for a population with uneven literacy?

The Process is Flawed

In the FSSAI’s own 2021 consultations on FOPL, about 80 per cent of invited stakeholders were food manufacturers/associations. In August 2025, in a national consultation I witnessed high drama in Vigyan Bhawan as the food industry opposed any such regulations despite sound scientific evidence presented. Out of the more than 500 people attendees barely 10–15 were from public health. The rest was from the food industry who told us, “why don’t you promote exercise”. During a consultation on March 19 this year to discuss the SC directions that a warning was needed, there were more than 60 people from companies and their associations. There were just two of us from public health.

What did the industry ask for on March 19? Do not put a warning on the front. It is “simplistic” and will “alarm” people. Judge the product by one serving, not by 100 grams, so a pickle or a sauce slip through. Talk about portion control and education instead. Given all the power of the food industry, the FSSAI denied the suggestion to put warning labels in their next submission in the SC citing there was “no consensus”. Why expect a consensus when the process is filled with undeniable conflicts of interest? Everyone with a food product on the shelf is invited to design and write the rules meant to restrain that product!

Reversing its Position

The court asked the FSSAI to explain why it reversed its 2021 position. On thresholds, it was agreed to use total sugars, not added sugars, because what matters is total sugar or free sugar. The Indian Council of Medical Research-National Institute of Nutrition dietary guidelines for Indians say the same and recommended total fats to be used. On the unit of measurement, the industry wanted a “per serve” basis, which was rejected and per 100 g or 100 ml was adopted. These reversals tilt the framework towards the industry which was party to the decisions.

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The Lancet series on ultra-processed foods and human health (2025) called food-industry interference “the single largest barrier” to cutting the consumption of these food products worldwide. India is no exception.

A warning label helps the consumer to make well-informed choices.

For whom should a food authority work? For the company that sells the packet or for the child who eats it? The deeper problem is structural. India has no policy on prevention and management of conflict of interest in any sector.

In September 2026 more than 60 nutrition scholars—from Harvard, Johns Hopkins, Oxford, the University of Chile and Mexico’s National Institute of Public Health—signed a written comment endorsing warning labels for India. Their advice matches the view of the Government of India’s National Institute of Nutrition which also wrote to the FSSAI in early September. Sound evidence from India exists, including a randomised experiment in six states with 2,869 adults in 2022. Only 39 per cent participants in the control group correctly identified all products high in nutrient(s) of concern. The biggest differences were observed for the warning label. Another trial, among adolescents in Mumbai, published in World Nutrition in 2026, found that warning labels led to the healthier choice 80 per cent of the time, ahead of nutri-score (56.7 per cent) and the health star rating (66.7 per cent).

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The slow harm of consuming ultra-processed food products, mostly HFSS, is also a food-safety issue and arguably, the larger one. India is one of the fastest-growing markets for UPF sales. It grew 150 per cent from 2009 to 2023. Retail sales surged from $0.9 billion in 2006 to nearly $38 billion in 2019, a 40-fold rise. During the same period obesity has nearly doubled in both men and women. ­­Type-2 diabetes is soaring.

A warning label is a cheap, tested tool that helps the consumer to make well-informed choice. Chile saw a 23 per cent fall in sugary-drink purchases after warnings and restriction of advertisements.

Get the Warning Right

The Supreme Court supports warnings. The Economic Survey 2025-26 recommends them. The Parliamentary Committee on Consumer Affairs recommends them. The only organised opposition is from the food industry. As a public-health expert, I would expect a warning for every nutrient of concern, binding timeline and use total sugar and total fat for thresholds. Further, people would benefit by use of high-contrast black-and-white hexagons that are harder to hide and that, too, in two languages—Hindi and English. The question is not whether India can afford warning labels. It is whether India can afford not to have them.

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The regulatory process should be finished in three months at the FSSAI, the Ministry of Health and Family Welfare and in Parliament. If there is a phase two, it should be timed at 12 months the way Israel did. The process must be free from conflicts of interest. Future consultations should be separate for public health and the industry. The Government of India should adopt a conflict-of-interest rule for food/nutrition regulation on the lines of World Health Organisation Framework Convention on Tobacco Control (FCTC) Article 5.3.

Such a change in direction can answer the question: do our institutions work for the citizens whose health they are bound to protect or for the industries whose profits depend on the products driving this non-communicable diseases epidemic?

(Views expressed are personal)

Arun Gupta is a Paediatrician and the convenor of nutrition advocacy in public interest

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