The Food Safety and Standards Authority of India (FSSAI) has proposed a single-phase system of front-of-pack warning labels under which packaged foods high in even one nutrient of concern — such as salt, sugar or fat — could carry a prominent warning on the front of the pack.
Public health advocates have welcomed the shift from the earlier proposal, under which two or more nutrients would have to cross the prescribed threshold. But Nutrition Advocacy in Public Interest (NAPi) has raised concerns over the proposed timeline and several elements of the design and nutrient criteria.
In its latest affidavit before the Supreme Court, FSSAI has proposed covering products high in any one nutrient of concern. Where two or three nutrients cross the threshold, they would be displayed together in the proposed red-hexagon warning. FSSAI is also considering a front-of-pack declaration stating “CONTAINS NON-CALORIC SWEETENER” for foods and beverages containing non-caloric sweeteners.
NAPi questions the timeline
The proposed system could take until July 2028 to become mandatory, according to the timeline outlined by FSSAI.
The authority has proposed around four months to finalise the draft regulations, including a 60-day period for comments, followed by a 365-day implementation period for food businesses.
NAPi has questioned why another round of public consultation is required when the regulatory process has been underway since September 2022. “This is not a fresh effort towards the notification, its part of the ongoing process from September 2022. By again opening at this stage to public comments and stakeholder consultation, where is the guarantee for a consensus?” said Dr Arun Gupta, Convenor, NAPi.
The public health group has said implementation should take place by July 1, 2027, or earlier, arguing that the delay is not justified from a public-health perspective.
What will the warning label look like?
FSSAI has proposed a red hexagon against a white background, placed on the front of the package. The nutrient that crosses the prescribed threshold would be identified inside the hexagon.
If a product is high in one nutrient, that nutrient would be displayed. If two or three nutrients cross the threshold, they would appear together in the same hexagon.
FSSAI has also proposed that the warning font be at least one point larger than the nutrition information provided on the back of the pack.
NAPi, however, says each nutrient should have a separate hexagon, rather than combining multiple nutrients in one symbol.
The group has also questioned FSSAI’s proposed method for determining warning size. It says the warning should be proportionate to the package's principal display area, rather than linked to the size of the nutrition information panel.
NAPi has cited front-of-pack systems in Chile, Mexico, Peru and Argentina, arguing that larger, bold warnings and strong contrast can make them more visible and accessible, including for people with colour-vision deficiency.
High in salt, sugar or fat: one is enough
Under the latest proposal, a product would not need to be high in multiple nutrients to attract a warning.
FSSAI is proposing thresholds based on the ICMR-NIN Dietary Guidelines for Indians, 2024.
The proposal uses criteria related to added sugar and added fat, rather than total sugar and saturated fat, for the relevant thresholds.
This distinction has emerged as another area of concern for NAPi.
Why NAPi wants total sugar considered ?
NAPi argues that relying on added sugar could allow some products to avoid a warning despite having a substantial overall sugar or calorie load.
For example, products could potentially reformulate by replacing added sugars with other ingredients while retaining a high glycaemic or energy load, the group said.
“Addition of sugar over and above what is naturally or inherently present in foods increases the total calorie intake without providing significant additional nutritional value. Using added sugar instead of total sugar on front-of-pack labeling (FOPL) carries specific public health, regulatory, and consumer risks. A pre-packaged food product with zero added sugar (using alternatives) might get a clean chit from an FOPL badge, falsely appearing healthier. Food companies can easily reformulate products to hide or substitute added sugars while keeping total glycaemic and caloric loads high, bypassing warning labels,” Dr Gupta says.
he has also raised an enforcement concern, arguing that laboratories cannot chemically distinguish between added and naturally occurring sugars once mixed into a food product.
NAPi has therefore urged FSSAI to consider total sugar and total fat, along with energy density, rather than treating the added-sugar and added-fat thresholds in isolation.
The group has referred to a September 3 communication from ICMR-NIN, which it says makes clear that the 2024 Dietary Guidelines should be considered as an integrated framework, including energy density and total nutrient considerations.
What about ultra-processed foods?
FSSAI’s proposal does not use the level of processing as a criterion for determining whether a product should carry a front-of-pack warning.
NAPi has questioned this approach and said that if ultra-processed foods are to remain outside the present system, FSSAI should address the issue separately within a defined timeframe.
The group has pointed to Colombia’s approach to identifying ultra-processed foods and suggested that front-of-pack identification of non-ultra-processed foods could also encourage reformulation.
The non-caloric sweetener warning
Alongside nutrient warnings, FSSAI has proposed moving the declaration “CONTAINS NON-CALORIC SWEETENER” to the front of products containing such sweeteners.
The intention is to make the information more visible to consumers at the point of purchase. NAPi has welcomed this part of the proposal.
Why NAPi is questioning a red hexagon on compliant beverages
NAPi has also flagged FSSAI’s proposal that beverages falling within the prescribed nutrient thresholds could carry a red hexagon identifying the beverage category.
The group argues that this could confuse consumers because a red hexagon may no longer necessarily indicate that a product is high in a nutrient of concern.
It has called for reconsideration of this provision.
The bigger issue
FSSAI’s latest affidavit represents a significant change in the proposed front-of-pack labelling system: one nutrient crossing the threshold could now be enough to trigger a warning.
But NAPi’s response suggests that the next stage of the debate will centre on what exactly the warning should measure, how prominently it should be displayed and, crucially, how soon consumers will see it on food packets.
For a policy under discussion since 2022, NAPi’s central objection is that consumers should not have to wait until 2028 for mandatory warnings to take effect.