Policy Circle, January 11, 2023
By George Cheriyan and Simi TB
The Food Safety and Standards Authority of India released a draft notification on September 13 2022, amending the Food Safety and Standards (Labelling & Display) regulations 2020 and invited views and comments from the public. Through this amendment, FSSAI intends to introduce front of pack nutrition labelling in the country for packaged food products wherein packed food will be star rated based on their nutritional values.
There are objections from all quarters on the type of front of pack nutrition labelling format chosen, but recent news reports highlighting the concerns of local food manufacturers are grabbing more attention. The manufacturers fear that traditional Indian foods will lose out to modern food manufacturers once FSSAI begins ranking food products based on star ratings. This is exactly one of the reasons why consumer organisations had been advocating against the star rating of food products.
FSSAI should not serve as a platform to rank various food products and take a decision at the behest of consumers, but it should merely communicate complex information to consumers by simplifying it into a standardised format to guide, inform and steer consumer food choice and behaviour.
Providing information vs purchasing decision
By opting for a star rating system, FSSAI is bestowing itself the responsibility to decide on food products that a consumer should consume, based on its nutrient composition and then forcing it upon the consumers without realising that health and nutrition requirement differs from consumer to consumer and cannot be generalised. Only the consumers themself are in a position to decide if he should consume a particular product or not.
The role of a regulator should be to inform the consumer in the simplest form about foods that are high in sugar, salt and fat and it is the consumer who should decide whether to purchase it or not. That is where the effectiveness and usefulness of a warning label come into picture. A consumer who buys traditional food like laddu or jalebi very well knows it is high in sugar and fat. So, there is no need to worry about losing out to modern food. Also, it encourages manufacturers to reformulate their food products according to the purchasing preference for healthier options.
The proposed star rating label where the bigger food manufacturers can easily tweak and make their products look healthy by adding positive nutrients will adversely impact small-scale local food products that are part of regional and traditional food culture. Such traditional local foods stand to be poorly rated compared with their modern counterparts, potentially impacting the economic stability within the sector as they make up almost three-fourths of India’s packaged foods industry.
Besides imbalance in the food system could also prop up as cultivation of local raw materials and ingredients, which are mostly used in the production of traditional foods, contribute to the development of a more sustainable environment, protecting rural areas from depopulation and providing a wider variety of food choices for consumers gets slowly affected.
Concerns over front of pack nutrition labelling
The argument of businesses against front of pack nutrition labelling don’t sound reasonable at the same time. There are apprehensions that there would be an increase in production cost, a change in taste as a result of changing the composition of their products, as well as required modifications in labelling and packaging.
It might be a challenge for small business to modify their traditional food products to meet FOPNL criteria without compromising on taste, but it is not an impossible task. The same companies were worried, a couple of years back, about the impact on taste when trans fatty acids (TFA) regulations were put in place. Effective sensitisation and hand-holding by all other stakeholders helped them overcome their fears and they were able to find suitable cost-effective alternatives without compromising on taste.
Any change in the composition will be equally applicable to all packaged food manufacturers in India and hence the argument that consumers would stop purchasing traditional products and prefer other products does not stand. They need to understand that more than 40 countries, both developed and developing, have already brought in similar regulations, and are implementing them without bottlenecks.
(George Cheriyan is Director and Simi TB Policy Analyst at CUTS International, a global public policy research and consumer advocacy organisation. Dr Cheriyan is also a member of the Central Advisory Committee of Food Safety & Standards Authority of India.)
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