FSSAI’s new draft regulation for food safety will promote informed consumer choice

The Food Safety and Standards Authority of India’s (FSSAI) new draft Food Safety and Standards (Labelling and Display) Regulations, 2019, which aims to make salt declaration mandatory on pre-packaged foods, among others, is a positive step.

The new regulations, announced on June 25, 2019, will supersede the Food Safety and Standards (Labelling and Display) Regulations, 2011.

According to the existing regulations, salt is not required to be declared. This means food manufacturers can be selective in salt declaration. Whenever salt content is high in a product, it is often not declared.

Salt declaration will help people in taking informed choices, especially those who suffer from hypertension or are prone to it. Considering India has high prevalence of hypertension — 41 per cent women and 58 per cent men — have hypertension or are pre-hypertensive, declaration of salt on packaged foods will enable consumers to avoid high salt foods.

Another positive change proposed is the mandatory requirement of declaration of added sugar as part of the nutrition labelling. Added sugar is the one which is added to the foods during processing.

Under the existing regulations, sugar is to be declared without specifying how much of it is added and how much is naturally present. Most of the ultra-processed foods are high in added sugar to increase palatability and shelf life.

With the proposed declaration of added sugar, consumers will now be able to choose not to eat empty calories, which would add in preventing and controlling obesity and non-communicable diseases (NCDs) like diabetes.

Moreover, with such a move, food producers will also be compelled to reformulate their products by reducing the added sugar content to compete with brands in the same category.

The proposed regulation, if conceded will make declaration of per serve contribution to recommended dietary allowance (RDA) mandatory. With this a consumer will be informed about the quantity of the ingredient he or she will consume through a particular product as percentage of daily requirement of that ingredient. In other words, how much quota of sugar or fat will consumption of a particular quantity of biscuits exhaust.

As per the existing law, a consumer is expected to be informed only about quantity of ingredients but not their contribution to the RDA. The proposed regulation is a best practice in the global food-labelling system. This practice when complemented with nutrition literacy will set a base for effective nutritional labelling.

The draft also proposes inclusion of serving size and number of servings. However, in order to be able to make it useful from perspective of a consumer, serving size must be standardised within the product category.

The proposed regulation also suggests labelling the ingredients Front-of-Pack (FoP). FoP nutrition labels contain information that allows quick decision making about the nutritional content or relative healthfulness of a product.

The objective of FoP labels is to make nutritional information easily interpretable, viewable and distinguishable to enable consumers take informed decisions while purchasing packaged foods high in fat, sugar and salt (HFSS).

FoP has been integral part of many countries’ such as UK, Singapore, France, Chile, Australia, New Zealand, labelling strategies to control NCDs.

The proposed FoP label has two parts: the first part declares the amount of calories, saturated fat, trans fat, added sugar and sodium per serve; and the second part declares the per serve percentage contribution to RDA.

For nutrients like saturated fat, trans-fat, added sugar and sodium, thresholds are defined and if quantity of these exceeds the threshold the nutrient will be coded with colour red.

However, it is important to strengthen the proposed FoP regulations and align it with the earlier version of the draft which included the key ingredients such as ‘total fat’, ‘total sugar’, and ‘salt’ along with trans-fat and not the subset of the key ingredients such as ‘saturated fat’, ‘added sugar’, and ‘sodium’.

In its current form, the consumers won’t be able to easily understand, and it would be perceived that ‘total fat’ and ‘total sugar’ are not an issue, which should not be the case. Including only saturated fat and added sugar will only address a part of the problem.

Besides, there should be no exemptions to the FoP labelling which, as of now, is given to packages less than 100 square centimetre, beverages providing less than 80 kilo calorie per serve and those sold in reusable bottles. This is because in order to avoid the red coding on their packages, the food companies may start promoting smaller packages.

These companies are already targeting population in rural areas and children with small packages, which will get a further push. Small sized sweetened beverages, chocolates are commonly sold in rural areas and school canteens. It is important to understand that the exemptions should not be there as smaller quantity does not make a product less harmful.

Besides, not just to health it is also detrimental to environment as smaller packaging results in more waste which is difficult and costly to recycle.

The proposed draft does not mention labelling of genetically modified (GM) food. It was, however, a part of the earlier draft. GM labelling should be mentioned as it falls in the purview of packaged food.

The Centre for Science and Environment (CSE) has been advocating for necessary policy framework in advertisements, labelling and claims of HFSS foods and had submitted its report titled ‘Food Labelling Claims and Advertisements’ to FSSAI comprising of our recommendations in 2016. CSE also reviewed the earlier version of this draft in 2018 and submitted comments to FSSAI on the same.

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