Food labels: Global experts, ICMR-NIN tell FSSAI, One nutrient should trigger a warning

The ICMR-National Institute of Nutrition (ICMR-NIN) has asked the Food Safety and Standards Authority of India (FSSAI) to make sure that warning labels appear on packaged foods as soon as they go over the limit for any single nutrient of concern. They warned that requiring two nutrients to be high could let foods with a lot of sugar, salt, or fat avoid being noticed by consumers.

In a letter dated September 3 to the FSSAI CEO, ICMR-NIN Director Dr Bharati Kulkarni suggested that the planned red-hexagonal warning labels should be simple, easy to see, and easy to understand. She also recommended using separate warnings like “HIGH SUGAR”, “HIGH FAT”, and “HIGH SALT” to give consumers clearer information.

This advice comes as FSSAI is developing rules for warning labels on foods high in fat, sugar, and salt (HFSS), after the Supreme Court reviewed the proposed system.

The letter was sent just days before the Supreme Court strongly questioned FSSAI’s plan to introduce warning labels in two phases. Justices J.B. Pardiwala and K. Vinod Chandran asked why warnings should first apply only to products high in two or more nutrients, and not to those high in just one nutrient from the start.

The court also asked for details about the size, font, color, placement, and design of the red-hexagonal warnings, and whether there should be separate warnings for each nutrient. It told FSSAI to give a clear, science-based timeline for moving to the second phase, warning that without this, the changes could be delayed for a long time. FSSAI has 10 days to reply.

In a separate letter, more than 50 global experts, including nutrition and public health specialists from Chile, Mexico, Brazil, Australia, Canada, South Africa, the UK, the US and India, make a similar case.

A letter signed by more than 60 top global nutrition scholars, including researchers from Harvard, Johns Hopkins, Oxford, and the countries mentioned by the Supreme Court, has supported India's proposed warning labels. They specifically recommended removing the rule that requires two or more nutrients to trigger a warning.

The scholars write: 'Individual nutrients can independently pose health risks... products that are high in only one nutrient of concern should not be exempt from warning requirements,” says Dr Arun Gupta, senior Paediatrician and Convener, NAPi, who had been advocating the use of warning labels on packaged food in India

“Products should receive a separate warning for every nutrient that exceeds the relevant threshold,” the experts said, arguing that added sugar, saturated fat and sodium can each independently contribute to adverse health outcomes.

“On the colour of the labels, they say multiple experiments were conducted to determine the strongest label design; the black, octagonal warning label outperformed in providing contrast that does not mingle with colours of the packet,” he adds.

Don’t wait for two red flags.

The two interventions challenge the idea that a packaged food should qualify for a front-of-pack warning only when it crosses the limits for two or more nutrients.

Under a single-nutrient approach, a product high in sugar would carry a high-sugar warning even if it does not cross the prescribed thresholds for salt or saturated fat. If more than one nutrient exceeds the limit, corresponding warnings could be displayed together.

Global experts supported nutrient-specific warnings, citing guidance from the World Health Organization and evidence from countries like Chile.

ICMR-NIN has gone a stage further by suggesting that separate and clear red hexagons showing 'HIGH SUGAR', 'HIGH FAT' and 'HIGH SALT' should be used, on the grounds that such labels would at once inform consumers of the nutritional issue in question and would thus eliminate the need for them to interpret the figures on the back of the pack.

Warnings must not disappear into packaging.

The global experts have also flagged another potential loophole: visibility.

They have asked FSSAI to specify minimum sizes and the requirements for the position of the warnings so that they cannot be hidden or made less noticeable by the packaging design and have suggested a fixed, uniform, high-contrast background, for example, a white box or border.

The experts also cited international evidence supporting black-and-white warning designs, on the grounds that black warnings are harder to hide against colorful packaging.

This matters because mandating a warning alone does not guarantee consumers will notice or understand it, especially when the rest of the package is designed to attract attention.

ICMR-NIN cautions against cherry-picking thresholds

ICMR-NIN has also asked FSSAI to consider the full scientific basis behind the Dietary Guidelines for Indians (DGI), 2024, rather than adopting individual nutrient cut-offs.

The institute said the DGI thresholds were developed by considering energy density alongside amounts of added fat, added sugar, and salt, as well as the recommended upper limits for total fat and total sugar.

For solid foods, the framework sets an energy threshold of 250 kcal per 100 grams; for liquids, the corresponding threshold is 70 kcal per 100 ml, along with nutrient-specific criteria.

India's top nutrition research institute and international experts have voiced the same concern in the labeling debate, and both sides are advocating for a system that is simple, clearly displayed, and hard for manufacturers to weaken by combining nutrients or through packaging design.

For consumers, the point is simple: a single red flag should be enough to trigger a warning.