Front-of-Pack Labelling:FSSAI Blunders on Draft Food Policy

Front-of-Pack Labelling—the proposed policy might inadvertently harm Public Health, as the consumption of unhealthy food may go up with ‘Stars’ on the label.

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The Food Safety and Standards Authority of India (FSSAI) put up a draft regulation for comments from the public for the Front-of-Pack Labelling of pre-packaged food products. If not changed substantially, the draft is unlikely to achieve the intended objective and the mandate FSSAI has to ensure consumers’ food safety.

Robust scientific evidence indicates that pre-packaged food products (usually industrial formulations and marketed) are responsible for increasing the salt/sugar or saturated fat content of one’s diet. Whether these products are manufactured by MNCs or local companies, increased consumption of such food products is directly associated with obesity, type-2 diabetes, hypertension, heart disease, chronic kidney disease, cancers and adverse mental health. More recent evidence points to negative health impacts on mothers and children. New study findings suggest that the prevalence of high BP in adolescents is substantially high (one in three) and coexists with other cardiovascular disease risk factors. This calls for interventions to reduce the consumption of foods high in sugar, salt, or saturated fats. 

Dr. Navdeep Singh Khaira, a renowned nephrologist working as a Senior Consultant at Fortis Hospital, Ludhiana, said, “I have been following this issue for more than a year. Based on the information received through RTI, I am disappointed that FSSAI continues to rely on the report of IIM on its face value and goes for ‘Stars’ on unhealthy food products. Not only has FSSAI biased the IIM researchers towards HSR and did not even attempt to analyse the IIM report. It implies a predetermined outcome by the FSSAI that brings up Star Rating to all unhealthy food products.”

A member of a scientific panel of FSSAI, who wishes to be anonymous, confirmed, “IIM study outcomes were shared with us in the stakeholders’ meeting, and we were asked to go ahead with HSR. We were never allowed to analyse the IIM report”.

A former BJP MLA, Ravinder Bansal, said, “I’m diabetic. I want to know if the food product being displayed or sold is high in sugar or not on the front of the pack. The 2 “Stars” do not tell me about this fact. I have suggested to the FSSAI to change its current draft. Further, he said, “Label must be simple and true to the content of the food product for people to make an informed choice to buy or eat such products; ‘stars’ on unhealthy foods are misleading.” 

By sticking to a focal point of high sodium, total sugar and total fats, front-of-pack labels will not allow the industry to play around with the algorithms of unhealthy foods, says Ashim Sanyal, COO of Consumer VOICE. Warning labels will also empower customers to make healthier choices and contribute to the prevention of the most concerning diet-related non-communicable diseases (NCDs) in India. He added FSSAI solely relies on the IIM report for the decision taken in favour of HSR on 15-2-22, a report that leading experts have critiqued in its methods and interpretation. 

“Chips, colas and chocolates are bad for your health. And their consumers, mostly children, need to know this in plain, simple words. That’s what a health warning on the pack can achieve, protect our kids from being encashed for profit by the food industry”, said Rujuta Diwekar, a leading nutrition consultant in India.

 Professor Harsh Pal Singh Sachdev, a senior epidemiologist, said, “It is surprising that the food risk factors ‘sugar’ has been capped at 21 g per 100 grams in solid foods, which is way higher than the WHO’s guidelines, based on well-researched nutrient profiles for food products in several regions including Asia. Unless compelling reasons mandate otherwise, FSSAI should have strictly adhered to the WHO Guidelines to identify food risk factors accordingly. It may then re-think its strategy to inform people about food risk factors more directly and honestly.” 

The Nutrition Advocacy in Public Interest (NAPi), a national think tank on nutrition policy, strongly suggested that the regulation be revised. Dr. Arun Gupta, the convener of NAPi, expressed, “there is no scientific evidence that adding a positive factor or nutrient like vegetable/fruit/ nuts, etc. to an unhealthy food product would reduce risk of disease. Body metabolism does not function that way. Neither nuts/fruit/legumes can reduce the absorption of sugar/salt or fat in the unhealthy product nor its negative impact.” 

It is ridiculously high to give a window of 4 years to comply. This conveys a lack of urgency to tackle an epidemic with life-extended and intergenerational consequences. It seems to be a cakewalk for the food industry on top of giving “Stars” to the same food product, which is responsible for the growing epidemic/pandemic of NCDs in India and worldwide. Most countries in the world have rejected Star ratings. Can’t it be done in six months, experts asked? 

Dr. Vandana Prasad, a member of NAPi and a public health professional, pointed out that “Considering that the draft of certain regulations to amend further the Food Safety and Standards (Labelling & Display) Regulations, 2020 is being brought out in the interest of people’s health, it is a fundamental flaw of concept to rate foods from “least healthy to healthiest” [Chapter 6, 14 (2)(b)] and include the notion of declaring warnings against foods that are clearly accepted as being unhealthy. For instance, a packet of chips or a bottle of sugary soda would also be somewhat labelled healthy. Moreover, adding some pos fibre could substantially increase their rating without mitigating their adverse health effects. The vehement response by the food industry against any form of FoPL is testimony to the fact that it depends on massive profits. This draft raises the question of whether the FSSAI exists to protect their interests or the interests of consumers. Even the definition of HFSS is contradictory between the main body of Schedule III that raises the sugar threshold to double the WHO standard. Sadly, the FSSAI has not taken on board the extensive inputs that people in the public health space have made before this.

In their comments, most health professional organisations/public health experts have endorsed the requirement of warning labels depicting factual information about unhealthy nutrients on FOPL. With the G-20 Presidency, India could emerge as a leader in solving this most pressing issue facing humanity and develop robust policies to showcase to the G20 nations how to protect people’s health. ‘Warning labels’ and prohibition of the marketing of unhealthy food products could be critical to tackling global health challenges. Mexico, Chile and many Latin American countries have demonstrated commitment. Having policies to reduce the consumption of such food products will impact the dietary habits of populations and preserve traditional diets.