Front-Of-Pack Labelling: Time for Action

Nuffoods Spectrum, June 22, 2021

By George Cheriyan & Simi T.B.,

Helping consumers to make informed choices of healthy packaged food

One of the leading universities in Australia recently published a study on ultra-processed foods and beverages sales in 80 countries. Findings of the study showed that from 2009 to 2019 the rate of sales growth of ultra-processed food and beverages were highest in lower-middle-income regions of Asia when compared to the rest of the world. What is more worrisome is that among the Asian countries, India was topping the list at 7.8 percent, while the growth was close to stagnant in high income countries like United States and Germany.

Various institutions including World Health Organisation (WHO), Food and Agriculture Organisation (FAO), and United Nations Childrens Fund (UNICEF) have time and again advocated for avoiding such unhealthy foods from people’s diet. The findings of such studies can easily be correlated to the rise in non-communicable diseases (NCDs) among the population in India. The ‘Health of the Nation 2021’ report released by a leading chain of hospitals in India shows the growing trends of NCDs spreading in India during the past few years. It has revealed that NCDs have contributed to a staggering 64.9 percent of total deathsin the country. The report also cautioned that individuals with NCDs have a greater mortality risk during the on-going pandemic crisis.

The 2030 agenda for sustainable development adopted by the United Nations (UN) consider NCDs as a major challenge for sustainable development with the target to reduce premature mortality from NCDs by one-third by 2030. This becomes even more challenging as highly processed, packaged foods that tend to be high in fats, sugars and/or salt are often less expensive than fresh and nutritious foods.

Front-of-Package Labelling (FoPL)

Insertion of simplified nutrition information on the front of food packages is a cost-effective strategy to guide consumers make healthier choices and discourage them from consuming foods that are high in salt, sugar, fat, the critical nutrients causing rise in NCDs. In short, it is a tool that aids consumers in improving their diets. It helps them make an informed decision.

Chile is a country with high levels of Sugar-Sweetened Beverages (SSB) intake. With an intent to curb high rates of obesity among its population, Chile in 2012 regulated the nutritional content of food and its marketing across the country. Such a move was first in the world and it included three concrete measures in one policy. First, it mandated a front-of-package label (FoPL) for most food products that are high in a certain level of calories, sugars, sodium, and saturated fat, and then it regulated the advertising and marketing of products with FoPL, particularly limiting advertisements targeting audiences younger than 14 years old. Finally, it prohibited all products that exceed the thresholds of critical nutrients from being sold in schools. Purchases of high-in beverages significantly declined following implementation of Chile’s Law of Food Labelling and Advertising; these reductions were larger than those observed from single, standalone policies, including sugar-sweetened-beverage taxes previously implemented in Latin America.

In India FoPL was first recommended in 2014 by an expert committee constituted by Food Safety and Standards Authority of India (FSSAI) in 2013. After years of consultations, in May 2018, FSSAI published a draft Food Safety and Standards (Labelling and Display) Regulations, 2018. In 2019, FSSAI issued draft notification Food Safety Standards (Labelling and Display), Regulations, 2019. In 2019 December, FSSAI delinked FoPL from general labelling regulations. However, the country is yet to bring in some regulation regarding FoPL, though some active discussions are happening over time.

Challenges to Implement

It is true that FoPL is a cost-effective mean to check marketing claims at point of purchase. It can empower consumers and promote production of healthy foods and food products. Even our neighbouring country Sri Lanka have implemented FoPL and Bangladesh is already far ahead in the process of implementation. However, even after years of deliberations, India is facing several barriers and challenges in the process of bringing out such a regulation. However, it is expected that the spirit shown by FSSAI to eliminate the industrially produced trans-fat in all oils, fats and foods by January 2022, one year ahead of WHO deadline, in spiteof stiff opposition from the industry, will be shown here too for larger interest of the consumers.

Consensus on Thresholds

Confusions and objections are raised regarding Nutrient Profile Model (NPM) and fixing up of threshold. The WHO SEARO model that was put together after years of consultation with experts from world over is perfectly aligned to the Codex Alimentarius. This must not be tweaked or weakened, as it would pose detrimental to the health of the people in the long run. Extensive research regarding these issues has already taken place, even a recent study by National Institute of Nutrition agrees to the limits on salt, sugar and fats set by WHO. In the 2019 notification FSSAI also follows these thresholds.

Format for Label

In a country like India where consumers are mostly illiterate and ignorant, FoPL to be introduced must provide clear, simple, interpretive information that is readily understood by most. A “High in” warning label on packaged foods and beverages could effectively discourage consumers from purchasing such products, compared to when products do not have warning labels. Already Chile, Israel, Peru, Mexico, Brazil and Uruguay have adopted a warning label system. However, across the globe the food and beverage industry continues to strongly and extensively oppose such warning labelling regulations, instead, prefer Guideline Daily Amount (GDA), which includes hard to understand numbers, which could easily mislead consumers. Even several studies have shown that GDA is a less effective labelling system compared to ‘high in’ front of package warning labels.

Per Serving Vs Per Unit

Likewise, the use of per serving sizes, which Industry usually favour, is also increasingly being rejected across the globe. ‘Per serving sizes’ are found to be arbitrary and difficult to regulate as they are not standardised. It lacks consistency thereby posing a challenge to consumers’ ability to easily interpret information and compare food products. Such complex serving size logic should not be introduced in a country like India, where consumers hardly spend less than 10 seconds to choose a product. Other than causing confusion, it also gives room to the industry to manipulate the thresholds, altering the serving size, and then dipping the percentage of products that will have the warning with ‘High in’ label. Instead ‘per 100g/100ml’ format largely recommended by the Codex and adopted by most countries, including European Union Member States and Israel (‘per serving’ as a voluntary addition) should be adopted.

Time for Action

In recent years, FoPLs are increasingly being implemented by governments internationally to support consumers to make healthier food choices. For instance, Mexico hardly took six months to debate and approve the official FoPL regulation, in spite of strong opposition from the industry. FSSAI has already spent a number of years discussing and consulting stakeholders, it is high time to move fast without any further delay and come out with strong regulation. Most countries have started to reap the benefits from positive consumer behaviour since the implementation of the FoPL. It has helped those governments to save money from direct and indirect healthcare costs.


Authors’ details- George Cheriyan is Director and Simi T.B. is Policy Analyst. Both work at CUTS International, a global public policy research and consumer advocacy organisation headquartered in Jaipur.

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