NAPi presents a framework to the FSSAI for FOPL

The Food Safety and Standards Authority of India (FSSAI) has yet to enact regulations requiring nutrition warning labels on packaged foods.  The Supreme Court of India has tasked the FSSAI to finalise the regulations within three months, which will conclude in mid-October; as a result, the FSSAI is racing against a deadline to examine over 14,000 public opinions on front-of-pack food labelling (FoPL).

Nutrition Advocacy in Public Interest (NAPi), an evidence-based nutrition policy think tank, has presented the FSSAI with the ethical framework termed the “Weightage Scale for Stakeholder Comments.” This scale will guide the FSSAI and its expert committee to evaluate public comments by weighing the quality of sources and evidence against the number of submissions.

NAPi’s proposal builds on its "Comprehensive Policy Analysis," which advocated for a strong warning-label-based system and the prohibition of advertisements for high-fat/sugar/salt (HFSS) and ultra-processed food products. The proposal cites global evidence and India's current health crisis, including increased prevalence of obesity, diabetes, and hypertension in the country.

Health experts, public health advocates, and consumer groups believe that the lack of binding laws is concerning and that the timely implementation of clear, visible warning labels might save future healthcare expenditures. This suggested strategy seeks to address lifestyle-related diseases by alerting consumers to high quantities of sugar, salt, and fat. 

The establishment of FoPL is said to promote informed consumer choices. Advocates and experts cite successful implementation and positive consumer behaviour in countries including Chile, Mexico, and Brazil, where such norms have positively impacted consumer awareness and purchasing habits.

Dr. Arun Gupta, a paediatrician, former member of the Prime Minister’s Council on India’s Nutrition Challenges, and the Convenor of NAPi, said, “The FSSAI is at a crossroads. It can either be remembered as the regulator that empowered millions of Indians to make well-informed choices, or the one that capitulated to food corporations.” 

He added, “This ‘Weightage Scale’ provides a simple, fair, and transparent roadmap for them to choose public health. We urge the FSSAI and its ‘Expert Committee’ to adopt this framework to ensure their analysis is defensible and based on evidence, not the number of comments”.

Industry representatives exhibit a divided stance; while some major companies support clearer nutritional disclosures to foster consumer trust, smaller manufacturers have voiced apprehension. The apprehension follows concerns regarding compliance costs and potential supply chain disruptions.

The proposed Weightage Scale allocates scores from zero to 10 for various stakeholders based on their input’s influence on policy or regulation. 

Independent scientific evidence from institutions such as the Indian Council of Medical Research (ICMR) and the All India Institute of Medical Sciences (AIIMS), as well as national and global public health bodies and science publications, is assigned the highest weight (nine-10/10). Consumer rights organisations, the World Health Organisation (WHO), and the United Nations Children’s Fund (UNICEF) receive high weight (eight/10) for their evidence and accessibility. Individuals and MSMEs are given low weightage (3-4), with MSMEs’ input potentially limited to implementation challenges rather than dictating policy content due to vested interests. Industry associations, lobby groups, and food industry representatives are assigned minimal weight (0-2/10) due to their clear commercial interests, though their insights on logistical challenges may be considered.

NAPi implores the FSSAI to adopt the framework to ensure a transparent evaluation process and to publish a report that substantiates its final decision based on evidence and ethical principles.