India is on the cusp of a significant shift in how food products are labelled, especially when it comes to foods high in fat, sugar, or salt (HFSS). The ongoing discourse revolves around whether existing nutritional information should be made more prominent on the front of packaging. However, the core question is whether food labels should merely present factual data or also assist consumers in interpreting it.
According to the Food Safety and Standards (Labelling and Display) Regulations, 2020, detailed nutritional information must be disclosed on pre-packaged foods, including data on energy, fat, saturated fat, trans fat, added sugar, and sodium. The debate is not about a lack of information but whether that information is clear, visible, and practical for consumers when making purchasing decisions. The Lok Sabha addressed this in February 2026, mentioning the FSSAI’s label literacy campaign, “#HarLabelKuchKehtaHai,” part of the “Eat Right India” initiative, which emphasizes helping consumers understand these declarations.
From Nutritional Disclosure to Front-of-Pack Interpretation
The Food Safety and Standards Authority of India (FSSAI) has explored two approaches. In September 2022, draft amendments were proposed to define HFSS foods and introduce a front-of-pack labelling system based on an Indian Nutrition Rating. This model would provide a summary assessment of a packaged food’s nutritional profile, with specific exemptions. By 2025, government responses in Parliament clarified the draft aimed to identify HFSS foods and incorporate front-of-pack nutrition labelling.
In February 2025, FSSAI suggested a draft amendment to display the per-serving percentage contribution to the Recommended Dietary Allowance for added sugar, saturated fat, and sodium in bold, larger fonts. This approach did not categorize products as healthy or unhealthy but aimed to highlight key nutritional elements more prominently.
The two approaches serve different purposes. An RDA-based declaration offers numerical data for consumer assessment, while a summary rating uses a nutrient profile to present a comparative indicator. A warning label goes further, indicating that certain nutrients exceed specified thresholds. The policy decision lies in how much interpretation the regulator should provide versus leaving it up to the consumer.
The Judicial Dimension
The discussion has gained prominence through the Supreme Court case of 3S and Our Health Society v. Union of India. The petition sought directives for front-of-package warning labels to indicate sugar, salt, and saturated fat levels. The Supreme Court concluded the petition by directing the formation of an expert committee to recommend amendments to the Labelling and Display Regulations.
The Supreme Court further instructed the authorities to seriously consider introducing front-of-pack warning labels and requested a response. FSSAI proposed a phased warning label regime: Phase 1 for products high in two or more concerning nutrients and certain sweetened beverages, and Phase 2 for products high in any one such nutrient. While public debate might suggest warning labels are imminent, enforceable requirements will only emerge from final regulations.
This evolution signifies that front-of-pack labelling is transitioning from policy discussion to regulatory proposal under judicial review. The form of the label, nutrient-profile criteria, and regulation path are now before the Court, underscoring the importance of a transparent, evidence-based process with thorough consultation and rationale.
Defining the Regulatory Subject
Before deciding what should appear on a package’s front, the law must specify the products subject to this requirement. “HFSS” is a policy term, but it needs to be a legal classification defined by regulations specifying relevant nutrients, thresholds, measurement bases, exclusions, and classification methods. This issue is evident in FSSAI’s recent actions concerning food in schools. On August 11, 2026, FSSAI proposed draft amendments defining food products high in added fat, sugar, or salt.
The use of “added” is critical, distinguishing it from total nutrient content or overall nutritional composition. Choices such as whether classification should depend on total or added quantities, measurement per 100 grams, milliliters, or servings, and the handling of naturally occurring nutrients must be informed by scientific evidence but translated into clear, consistent rules for implementation and enforcement.
Clear definitions are crucial for enforcement. A front-of-pack requirement should ensure consistency between manufacturers, importers, and authorities. Ambiguity leads to inconsistent labels, disputes over coverage, and unnecessary reformulation costs without improving consumer understanding. The absence of a clear, enforceable framework remains a major gap in food law.
Prominence, Context, and Label Integrity
This debate is not a contest between public health and commercial convenience. Both regulators and food businesses have an interest in labels that convey material information accurately. A technically complete label may be ineffective if consumers cannot understand it, while overly simplistic symbols may lack sufficient evaluative context.
The FSSAI’s National Stakeholder Consultation on food labelling, advertising, and claims in August 2025 acknowledged these competing considerations. It focused on truthful declarations, implementation challenges, consumer protection, public health, and alignment with global standards. The consultation also recognized the benefits of implementing label changes on a predictable annual cycle to reduce uncertainty.
Practical implementation will be crucial if a new front-of-pack model is adopted. Labels are linked to product specifications, laboratory data, artwork approvals, packaging inventories, licensing, and e-commerce listings. Final rules will need a realistic transition period, clear handling of existing packaging materials, and consistency across physical and digital displays.
The Direction of Travel
India has yet to finalize a front-of-pack framework for HFSS foods. The 2022 rating proposal, 2025 RDA focus, Supreme Court proceedings, and 2026 draft regulations for school foods indicate active consideration. Supreme Court filings suggest a shift towards an interpretive warning label model, focusing on thresholds, design, phasing, transition, and enforceability, which will arise only with explicit final regulations.
Nutrition labelling is moving beyond the back of the pack. Information about sugar, salt, and fat is increasingly expected to be prominent and understandable at the point of purchase. The effectiveness of the final framework will depend on coherent rules and definitions, scientifically sound criteria, proportionate exemptions, workable transitions, and consistent enforcement.
About the author: Shalini Sinha is the Global General Counsel (Media & Marketing) at The Magnum Ice Cream Company. The author’s views are personal and do not reflect the views of The Magnum Ice Cream Company.
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