Mains Articles

Labelling Junk Food [Mains Articles]

A nexus between the powerful processed food industry and the government is sabotaging efforts to enforce a sound statutory framework suggested six long years ago. Food giants mislead and misinform consumers about the food they eat, while the food regulator remains the willing spectator.
By IT's Mains Articles Team
December 30, 2019


  • Why it was in news?
  • What is the current practice for food safety regulation?
  • What is Recommended Dietary Allowance (RDA)?
  • Background
  • Provisions of Draft Food Safety and Standards (Labelling and Display) Regulations, 2019
  • Criticism of Draft Notification
  • International practice in food regulation
  • Conclusion

Labelling Junk Food

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Why it was in news?


  • In a recent study conducted by the Centre for Science and Environment (CSE), the amount of salt and fat in several “junk food” was well above proposed regulatory thresholds.
  • Study decided which nutrients were above thresholds by using concept of Recommended Dietary Allowance (RDA). Study tested salt, fat, transfats and carbohydrates in 33 popular junk foods.
  • These findings are significant as Food Safety and Standards Authority of India (FSSAI) is yet to make into law draft regulations on setting limits, and publicising information, about nutrients in fast and packaged foods.

Why it was in news

What is the current practice for food safety regulation?

  • Currently, Food Safety and Standards (Packaging and Labelling) Regulations, 2011 only require companies to disclose energy (kilo calories), protein, carbohydrates, total fat, trans-fat and saturated fat contained per 100g or per millilitre or per serve.
  • However, it is not easy for consumer to find how much is actually contained in a serving. There are also no disclosures on high salt content and added sugar, and no compulsion on companies to disclose nutritional information on the Front of the pack (FoP).

Need for new food regulatory system

  • In 2016, the Global Panel on Agriculture and Food Systems found that 6 of the top 11 risk factors driving the global burden of disease were related to
  • In India, Overweight/obesity levels among the 15-49-year-old population have doubled in a decade. In urban areas, about one-third of the population is overweight/obese. Obesity is the primary trigger for hypertension and type-2 diabetes.
  • Likewise, about two-thirds of Indians die because of non-communicable diseases (NCDs).

Noncommunicable diseases

  • Noncommunicable diseases (NCDs), also known as chronic diseases, are not transmissible directly from one person to another. NCDs are tend to be of long duration and are the result of a combination of genetic, physiological, environmental and behaviours factors.
  • The main types of NCDs are cardiovascular diseases (like heart attacks and stroke), cancers, chronic respiratory diseases (such as asthma) and diabetes.
  • Many NCDs are associated with an unhealthy diet.

What is Recommended Dietary Allowance (RDA)?

  • Recommended Dietary Allowance is the estimated amount of a nutrient (or calories) per day considered necessary for the maintenance of good health.
  • RDA is used to understand how much of any nutrient (salt, sugar, fat) should be consumed from different meals. As per RDA, ideally, an adult should consume no more than 5g of salt, 60g of fat, 300g carbohydrate and 2.2 g of trans fat every day.
  • The RDA has been agreed upon by expert bodies such as World Health Organization (WHO) and the National Institute of Nutrition (NIN), Hyderabad.

Factors affecting RDA:

RDA suggested for Indian population is based on the reference man and reference woman. Reference man and Reference woman are defined on the basis of body weights of well-nourished healthy adults who have satisfactory growth.

Factors affecting RDA

  • In general, requirement is more for men than women.
  • Adult men and women require nutrients for maintenance whereas infants and children require it for growth and maintenance. Nutrient requirements during childhood are proportional to growth rate.
  • Among adults, requirements are related to body weight and size.
  • During menstruation, pregnancy and lactation women require some nutrients more than the normal times.
  • Requirements of sports persons and athletes who perform high levels of extreme activity are high sometimes 2-3 times the normal times.
  • Sedentary person needs much less nutrients than a moderate to severely active person.
  • Extremes of climate or high altitude alters the need for certain nutrients.



2013: FSSAI set up a committee to regulate packaged snacks, which recommended that information on calories, sugar, fat, saturated fat and salt be displayed upfront. However, this report was discarded.

2015: FSSAI set up a second expert committee led by D Prabhakaran, which endorsed the recommendations made by the first committee and therefore was discarded.

2018: FSSAI made Food Safety and Standards (Labelling and Display) Regulations, 2018, which said that a packet should have clear information on how much each nutrient contributed to the RDA and that those ingredients which breached the RDA should be marked in ‘red’. However, draft never became a law. The draft 2018 sought mandatory declaration of salt as sodium chloride (Till now, salt did not figure in food labels). The draft also proposed ‘Front of pack’ (FoP) nutrition labelling.

Based on the recommendation of a committee headed by B. Sesikeran, FSSAI formed Draft Food Safety and Standards (Labelling and Display) Regulations, 2019.

Provisions of Draft Food Safety and Standards (Labelling and Display) Regulations, 2019:



  • Mandatory declaration: Mandatory declaration by packaged food manufacturers about nutritional information such as calories, total fat, trans fat, sugar and salt per serve on the front of the pack.
  • Labelling requirements: Prescribed the labelling requirements of pre-packaged foods and display of essential information on premises where food is manufactured, processed, served and stored.
  • Advertisement constrain: HFSS (high in fat, sugar or salt) food products shall not be advertised to children in any form.
  • Colour code: High fats such as sugar and salt, trans-fat and sodium content should be coloured as ‘red’, if the value of energy from total sugar or fat is more than 10 percent of the total energy in the 100 grams/ml of the product. The colour coding will make easier for consumers to know about the nutritional value of food products and will help them make choices as per their requirements.

Colour code

  • Genetically Engineered (GE) ingredients: All food products having total Genetically Engineered (GE) ingredients 5% or more shall be labelled.
  • Bar code: The nutritional information should also be provided in the form of bar code.

Criticism of Draft Notification

Unscientific regulations

  • These regulations are not scientific enough neither practical to be implemented. The salt, sugar and fat content of packaged food depends on the taste requirement of the consumer and is not manufacturers’ choice


  • Food companies had opposed because they felt ‘red labeling’ of food signified danger, fearing that this would give consumers the impression that they were consuming toxic food. This would be counterproductive to the larger aim of having viable packaged food industry.
  • Moreover, a recent study of the Centre for Science and Environment (CSE) found that all the food that it tested needs to be marked ‘red’.

Added sugar

  • Draft replaced sodium chloride with salt, total fat with saturated fat and total sugar with added sugar. This dilutes information on the health harm posed by packaged foods.
  • As per Draft, in the case of ‘added sugar’, the product would be labelled red if the energy provided by the added sugar is more than 10 % of the energy provided by 100 g of the product. In the 2018 draft, the notification had used ‘sugar’ and not ‘added sugar’. However, 2019 draft introduces ‘added sugar’, but has taken the same threshold as the one for ‘total sugar’ of 2018 draft (50 g/day). This will appease the beverage and juice industry, but will compromise on health instead.

Mislabelling of transfats

  • Transfats need to be completely eliminated in foods as they are indicted for heart diseases. The results show that in almost all the food CSE tested, companies have under-reported the amount of transfats in their products. The 2019 draft code is not aimed at total elimination of trans fats.


  • Norms of 2019 draft are unscientific. Moreover, the packaged industry argues, immense quantities of junk food (fried food sold on unregulated pushcarts) are consumed in India with no check on their nutritional status. Hence, there is an inherent unfairness in regulating one section (regulated food industry) alone.

Information passing

  • Instead of labelling food which instil fear among people, government should inform food industry on what makes a healthy diet as the nutritional information only guides consumers on how to regulate their intake.

Increases confusion

  • The proposed labelling regulations publish too many numbers and an assortment of colour codes. This could potentially confuse people particularly because India has a vast non-English speaking population.
  • Moreover, the red mark labelling for one component (i.e., high salt) could mislead consumers. This is because other components (such as fat, calorie etc.) may not be over the FSSAI limits.

International practice in food regulation

  • Surveys undertaken by the WHO show that a vast majority of European countries have some form of front-of-pack labelling, but fewer countries have interpretive systems which explain the health factor of foods (as given in Food safety regulation 2019 draft).
  • Countries are learning that too many labels do not work. Instead, warning labels are the best option.



Example of Chile


  • Warning labels on food products were first implemented in Chile in 2016. Chile shows a black hexagon, with phrases such as ‘high in salt’ or ‘high in trans’, on the front of package. The more the hexagons the less desirable the product becomes for the consumer.
  • Surveys suggest that as these labels are easy to understand, even children are becoming more conscious about the health impact of their favourite snacks. Mothers, who did not understand labels earlier, use the number of labels as a guide and understand that products with more labels are less healthy.


  • Consumption of junk foods, that are high in salt, fats and trans fats can have deadly impacts as they are an open invitation to non-communicable diseases like diabetes, hypertension, heart ailments and even cancer.
  • As India is already the diabetes capital of the world and hypertension is a household phenomenon in the country, it is clear that if no action is taken on the bad food, the burden of NCDs will overwhelm our health infrastructure and economy.
  • Hence, it is in the interest of consumers, food industry and the nation that the dangers of junk food are disclosed and widely disseminated.



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