Front-of-package labelling: Why India should opt for warning labels

Policy Circle, June 29, 2021

By George Cheriyan & Simi T.B.,

Front-of-package labelling: High blood pressure, high sugar levels and obesity are the top risk factors for mortality in India. The prevalence of overweight and obesity is growing so faster than the world average that it is projected it will reach 30.5% and 9.5% among men, and 27.4% and 13.9% among women by 2040. Non-Communicable Diseases (NCDs) are now responsible for more than 65% of all deaths in India (approximately six million deaths). Between 1990 and 2016, the share of NCDs increased from 37% to 61% of all deaths in the country.

The World Economic Forum and Harvard School of Public Health had earlier highlighted the economic burden of NCDs in India. A study by them states that India stands to incur a cost of $4.58 trillion between 2012 and 2030 due to NCDs and mental health conditions. Of this, cardio vascular diseases (CVDs) alone would cost $2.17 trillion. The study further states that while several nations have implemented stronger regulations on salt content in food products and have subsequently seen lower rates of CVDs, no such restriction is in place in India.

Front-of-package labelling can reduce NCDs, obesity

Similar results are observed in numerous other studies too, which points out that the burden of NCDs keep rising in India largely due to excessive consumption of calorie dense foods and beverages containing high levels of saturated fats, trans-fatty acids, sugars and salts. The changing consumer preference to ready-to-eat foods, bakery products, frozen foods and other ultra-processed pre-packaged foods over healthy alternatives have increased substantially over the years.

In fact, the current value of Indian gourmet food market has crossed $1.3 billion and is still growing rapidly at an annual compound growth rate (CAGR) of 20%. So, to tackle the challenge posed by the NCDs and obesity, and to simultaneously change the local obesogenic environment, the government needs to promote a comprehensive nutrition policy including a strong regulation related to front-of-package labelling (FOPL).

FOPL strengthens consumers’ right to choose

The display of food products in stores can make consumers perplexed and confused over selection of healthier food. A majority of consumers have no nutritional knowledge and there is a need for some guidance at the time of purchase that is easy to understand.

Most consumers spend fewer than 10 seconds selecting each item, which does not give them enough time to compare the nutrition facts panels that are found on the back of packaged foods. As per Nielsen Report (2011), 59% consumers around the world have difficulty understanding nutrition labels on food packing. As per the study of National Institute of Nutrition (2013) only 50% of the adolescents were found to be reading the nutrition panel and ingredients list on the packets.

A supermarket exit survey (2013) shows only about 20% of the consumers checked the nutrition information on the food label and about 40% of the consumers said they would like to have some easy-to-understand symbols than the text intensive nutrition information on back of the pack. If front-of-package labelling presented in an easily understandable manner on the food packs, could aid the consumers make healthy food choices.

Why warning labels are more effective

While a variety of front-of-package labelling exist with different approaches and designs interpreting the nutrition present, negative warning labels that easily help identify unhealthy products have proved to be most effective for discouraging junk food and ultra-processed food choices.

Simple, interpretive labels are adopted in countries like Chile, Canada, Israel, Peru, Mexico, Brazil, and Uruguay. These labels have played a crucial role in shaping consumer level food behaviour. The warning label would be ideal for India too as it has proven useful to all consumer categories regardless of age, literacy proficiency or socioeconomic strata.

More importantly it would act as an efficient tool to guide those consumers who are medically advised to reduce the intake of fat, sugar or salt in their diet, thereby encouraging them towards a healthy eating habit. Further, as the nutritional values declared are for 100 g or 100ml of the food product as opposed to the serving size, the warning label restricts manufacturers to control the nutritional profile as desired.

There are lots of experiments, surveys and study reports that justify the stand for a warning label when compared to the other types. Last year a meta-analysis of 14 experimental studies that scrutinised existing front-of-package labelling in force found that only warning labels significantly reduced the sodium content of purchases, as did traffic light labels to some extent, but no effects on purchasing were found for Health Star Rating, NutriScore, or Guideline Daily Amount (GDA) labels.

A 2017 study in Uruguay comparing warning labels to traffic light labels and industry GDA-style labels found that warning labels were better able to help consumers correctly identify products with high content of unhealthy nutrients. Such a label on snack foods had a greater relative impact on children’s choices than other labels. Consumers perceived products bearing warning labels as less healthy than the same products featuring GDA or traffic light labels. It also showed that warning labels were more effective in encouraging reformulation of ultra-processed products than the other two labels.

Another study published in 2019 in International Journal of Behavioural Nutrition and Physical Activity says a Canadian consumer who saw ‘high in’ nutrient warning labels purchased less calories, sugar, and saturated fat from beverages and less calories and sodium from foods. Also warning labels outperformed traffic light, Health Star, and nutrition grade labels.

Recent studies in Brazil found that warning labels significantly outperform traffic light labels and GDAs in capturing consumers’ attention, improving their ability to identify healthier products and products high in nutrients of concern, and increasing their intention to buy a relatively healthier option.

Time to act based on science

In 2019, a large survey of parents from four Latin American countries found that the most vulnerable parents with low education and are overweight preferred a warning label over other labels. In the same year a survey of adults from Mexico and the United States to analyse consumers’ understanding of four different front-of-package labelling types including the warning labels, GDAs, multiple traffic lights, and Health Star Ratings showed that warning labels were the easiest for consumers to understand.

A recent study by George Institute for Global Health dismissed as flawed the Australia and New Zealand’s health star food rating system. It found that the loopholes in the system is facilitating food products high in salt, sugar and fats scoring higher ratings and misleading the consumers.

While it’s appreciable that lots of discussions and deliberations are happening on this topic at the behest of FSSAI, one should not forget that more the delay, the higher the damage in terms of health cost and medical expenditure. The other countries’ best practices and findings of various international studies and surveys should always be relied upon before zeroing in on the format for front-of-package labelling for any country.

Ultimately, selection of an ideal front-of-package labelling suitable for a country should be based on science and not by anyone’s vested interests. It should ensure that consumers have all the information and visible warnings to make choices towards healthier lifestyles.

(George Cheriyan is Director and Simi T.B. is Policy Analyst at CUTS International, a global public policy research and consumer advocacy organisation based in Jaipur.)

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