Proposal for ‘Front of package label’ in India

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    In Context 

    • Food Safety and Standards Authority of India (FSSAI) is planning to introduce a ‘front of package label’ for junk foods in India.

    What are Front of Package labels?

    • The front-of-pack (FoP) labelling system has long been listed as one of the global best practices to nudge consumers into healthy food choices
      • It works just the way cigarette packets are labelled with images to discourage consumption.
    • It seeks to provide simple nutrition information in a more accessible location instead of on the back or side of packages.
    • WHO’s definition: It defines FoP labels as “nutrition labelling systems that are presented on the front of food packages in the principal field of vision; and present simple, often graphic information on the nutrient content or nutritional quality of products, to complement the more detailed nutrient declarations provided on the back of food packages.”
    • Codex Alimentarius Commission: The Codex Alimentarius Commission, an international food standards body established jointly by WHO and the Food and Agriculture Organization (FAO), mentions that “FoP labelling is designed to assist in interpreting nutrient declarations”.

    Objectives and need of ‘Front of package label’ in India 

    • India definitely needs ‘warning labels’ on front-of-pack, but this must be a symbol-based label with no text and numbers. This is because:
    •  Junk foods have high levels of unhealthy nutrients: There is strong evidence that sugar, salt and fat in junk foods are addictive, like nicotine in tobacco. 
      • There is concern over increasing consumption of junk food leading to obesity in youth and children in India.
        • FoP ‘warning’ labels have helped reduce cigarette consumption. It is time we adopted the same for junk foods.
    • Warning labels are easy to notice and understand: They do not confuse consumers with mixed messages. Their distinct shape, colour and size make them noticeable in the otherwise cluttered and colourful packaging.
    • Warning labels are best suited for India as they do not include numbers, unlike many other FoP labels. 
      • In fact, warning labels that are symbol-based, like that of Israel, can transcend the barriers of literacy and language in India.

    Major Points of the Proposal 

    • FoP labels must include information on nutrients that make food injurious to health. 
      • This should be distinct from the details on the back-of-pack.
      •  FoP labels should aim to inform the consumer, while the back-of-pack label serves the purpose of scientific compliance and enforcement.
    • Factors that need to be considered while designing FOP label include the level of consumer awareness, larger message that shapes up overall dietary habits, evolving science, local context and effective space utilisation.
    • FoP labels should have information on ‘total sugar’ and not ‘added sugar’. There is no analytical laboratory method to differentiate ‘added sugar’ from total sugar and quantify it.
    • The FoP label must have a warning and be simple to read and act upon, as its purpose is to inform consumers about the unhealthy nutrients in junk foods. 

    Global Status in the context of  FoP labelling

    • Countries such as Chile, Brazil and Israel have laws to push the packaged food industry to adopt FoP labelling.
      •  They have used FoP labelling as a measure to fight obesity and NCDs.
    • While there are several formats being used across the world, voluntarily by the industry or enforced by governments, experiments and usage suggest that interpretive ‘warning’ labels are better than the other formats.
      • They warn about the specific nutrient that is present in excess amount in a product and provide binary information — if the product has a warning label for salt, it has excess salt.
      • At least seven countries have adopted warning labels in the past five years. These include Chile, Peru, Mexico, Israel and Uruguay.
        • Brazil and Columbia have announced plans to implement the label in 2022, with Canada likely to enforce it by December 2022 and Argentina, South Africa and the UK considering it.

    Image Courtesy : DTE

    • Chile’s warning label, for instance, is a black-and-white octagon with text saying ‘high in’ for nutrients that exceed thresholds.
      • The overall nutrition of the product can be assessed by the number of octagons on the package — four octagons mean the product is high in all sodium, sugar, saturated fat and calories.

    Status in India 

    • In 2013, an expert committee set up to look into junk food in schools recommended the need for FoP labelling for calories, sugar, fat, saturated fat and salt. 
    • In 2015, FSSAI set up a second expert committee to assess the availability of foods high in fat, salt or sugar in the Indian market and to recommend its regulatory limits and labelling and display requirements.
    • It is recommended to make nutritional information “easy” to understand and resolve “ambiguities” on the correct serving size of packaged and fast foods.
    • In 2018, FSSAI released the draft Food Safety and Standards (Labelling and Display) Regulations, which for the first time proposed FoP labelling for packaged food in India.
      • It was a good move. Despite some limitations in its design, the 2018 draft required food makers to place the information upfront — on the front of the pack —and highlight all the nutrients that exceed thresholds in red.
    • FSSAI called its sixth meeting in June 2021 and FSSAI brought some different criteria to the table as a surprise.
      • On the nutrients to be displayed on the FoP label, it was agreed that ‘sodium’ would be used for fixing thresholds and ‘salt’ could possibly be used on the FoP label. ‘Saturated fats’ are decided instead of ‘total fats’.
      • First, FSSAI proposed to also consider ‘positive nutrients’ in the FoP label.
        • It was about giving scores to ‘positive nutrients’ such as proteins, nuts, fruits and vegetables in the name of promoting wholesome foods.

    Image Courtesy: DTH

    • The system has failed to see the light of day in India even seven years after it was first proposed and despite the experience of FSSAI in enforcing such labels .
      • Since then there have been multiple panels, However, the country has not moved ahead on it towards bringing in a law. 

    Way Forward 

    • India needs to move ahead in protecting consumer health, particularly in times of COVID-19, when we have learnt that those with obesity and comorbidities like hypertension and diabetes are more likely to get severely ill from the disease. There is no time for delay. The FSSAI must come up with a law now with clear timelines. 

    Source: BS