India’s HFSS labels plan puts food industry on alert

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I ndia’s food manufacturing industry is bracing itself for new proposals on front-of-pack labelling displays of ingredients high in fat, sugar and salt by India’s food regulator, the Food Safety and Standards Authority of India (FSSAI).

Industry insiders, however, argue the proposed thresholds for the ingredients are unrealistically low – so any warning signs used on the labels could become ubiquitous and be ignored. 

The FSSAI was forced by India’s Supreme Court to present draft proposals in an affidavit through legal proceedings brought by the Kerala-based NGO 3S and Our Health and following years of delays at the agency over designing a warning labels.

This latest draft showed the FSSAI is now proposing a front-of-pack warning in a red hexagon even if just one of the three ingredients high fat, sugar or salt (HFSS) breaches a FSSAI threshold it plans to base on data from the Indian Council of Medical Research National Institute of Nutrition (ICMR-NIN). This is a change from earlier drafts where excessive levels of two of these key ingredients would need to be present to trigger a warning.

The FSSAI has promised in its affidavit to finalise formal draft regulations within four months, a pledge revealed in documents released when the Supreme Court reserved its order on 28 September.

The regulator has been debating mandatory front-of-pack labelling of HFSS products since 2022. But, with no action forthcoming, the Supreme Court warned it would pass an order ordering the implementation of labelling system if the FSSAI fails to act.

The agency may consider dropping an earlier plan for a one-year voluntary compliance phase-in period to food businesses, which the Supreme Court questioned in its statement reserving its order.

The proportion of children aged five to 19 in India with a high body mass index has been growing 4.8% annually over the past 15 years (2010 to 2025), according to the latest data from the World Obesity Federation NGO.  

According to the ICMR-NIN, the high consumption of ultra-processed and calorie-dense food and drinks and increasingly sedentary lifestyles are seen as the culprits.

Concerned health activists have been flagging the rising consumption of HFSS foods among Indians, especially children, for more than a decade but industry pressure has stalled regulatory action each time, Dr Arun Gupta, convenor at Indian think tank Nutritional Advocacy in Public Interest and M.R. Rajendran Nair, 3S and Our Health Society’s chairman, told Just Food.

Nair said: “Consumer behaviour will certainly be influenced by faithful communication. Commercial interest is holding the food business operators from doing so [printing warnings] and that is why there should be a regulatory measure.”

The food industry in India is unhappy with the front-of-pack labelling proposals. Former FSSAI CEO Pawan Agarwal gives a flavour of the unease, telling Just Food: “The FSSAI-proposed thresholds based on dietary guidelines for Indians by ICMR-NIN can be extremely stringent. This would mean that you can only have half a cube of sugar in a 100ml cup of tea.” 

Industry watchers suggests providing information to consumers based on nutrient levels within recommended serving sizes.

“The FSSAI is not looking at a balanced diet but individual items,” Dr Subodh Jindal, the former president of All India Food Processors Association (AIFPA), says. “One does not consume 100 grams of pickle or chutney. Thresholds should be on the basis of serve size. The FSSAI thresholds are unscientific. Food manufacturers may add synthetic sugars and fats which are very harmful, to stay within the FSSAI limits.” 

Amit Lohani, founder-director of Forum of Indian Food Importers and MD of distributor Max Foods Group, added: “I think there should be some tweaking of thresholds and also the portion size needs to be based on the category of product. You cannot have a 100ml or 100-gram portion size for everything because that actually doesn't look at the holistic view.”

Former FSSAI CEO Agarwal says the NIN dietary guidelines for sugar being less than 3g/100g; sodium less than 625mg/100g and saturated fat under 4.2g/100g (https://nin.res.in/dietaryguidelines/pdfjs/locale/DGI_2024.pdf) should not apply as thresholds for prepackaged food. “The current proposal which FSSAI has placed before the Supreme Court is still half-baked,” he tells Just Food. 

It was during Agarwal’s four-year tenure as CEO of the FSSAI that an initial draft for displaying food health warnings was mooted. Agarwal, who stepped down in February 2020, claims industry pressure brushed the matter under the carpet and now warning standards will be too tough. Almost 90% of food packages will have the warning, he claims, leading some business leaders to argue that such widespread application could backfire.

“In such a scenario, there is a strong possibility that the consumer would become insensitive to the warning labels and the whole exercise done in the interest of public health would lose its effectiveness and become meaningless,” Federation of Indian Chambers of Commerce and Industry (FICCI) director general Jyoti Vij says. That’s contested by Dr Gupta: “Even if 100% of packets have the warning, inform the consumer and let them decide.”

Retail sales of ‘ultra-processed’ foods (UPFs) in India surged 40-fold from $900m in 2006 to nearly $38bn by 2019, according to a study published late last year in The Lancet. The figures were highlighted in the country’s Ministry of Finance’s India Economic Survey in January, which estimated that sales growth continued 150% annually until 2023.

According to estimates issued by the US Department of Agriculture (USDA) last year, the overall Indian food retail market was valued at $389bn in 2025. The department also projected the sector could grow at a CAGR of 8.5% between 2024 and 2029 to $352.8bn. Based on those numbers, the potential market for UPFs is, on paper at least, huge.

However, Dr Jindal says the typical Indian palate is accustomed to heritage foods, the recipes of which, he argues, should guide the development of front-of-pack labels. That view is consistent with a PwC consumer survey conducted in India last year, in which 74% of respondents said their food preferences remained rooted in cultural heritage and traditions.

“The government should undertake a scientific ground level study of indigenous food habits and nutritional requirements, work on that algorithm and develop the standards for India, instead of blindly imposing borrowed standards,” Dr Jindal says.

For industry groups, however, the concern is not only whether the thresholds reflect Indian diets but also whether manufacturers can meet them at an acceptable cost.

Vij says any labelling demands imposed on manufacturers need to take account of reformulation costs. “MNCs have access to R&D facilities to reformulate while keeping products affordable, the [smaller] MSMEs will be at the receiving end with little technical expertise, access to research and limited finance. Thresholds should incentivise the manufacturers to make improvements gradually and provide adequate time to make the changes,” she argues.

FICCI wants to see a framework built around evidence of how Indians consume particular products, rather than uniform thresholds applied across categories. It is calling for the FSSAI to conduct a nationwide study on household dietary consumption patterns and develop reference serving sizes for different food categories, similar to the Reference Amounts Customarily Consumed measure in the US. “This will help ensure that future nutrition policies are based on actual consumption patterns and that front-of-pack labelling is practical, relevant, and easy for consumers to understand,” Vij adds.

Related objections have been raised, with some arguing a label based solely on sugar, salt, and fat could obscure other nutritional attributes.

At the Forum of Indian Food Importers, Lohani calls for a more holistic approach. “The present [proposed] labelling ignores the food matrix, a product has other aspects to it rather than just HFSS,” he says, calling for other parameters, such as protein or fibre content, to be included.

“To give you a perspective, a diet cola will look healthier than a block of cheese, which is not a reality,” Lohani adds.

He also argues that front-of-pack labels could create a practical compliance burden for imported products. “In terms of the labelling, this will have an impact on the [imported] product, and this will create a lot of stickering or labelling which will be done in bonded warehouses before the product can enter the Indian market,” Lohani says.

That concern over cost and compliance sits alongside a broader industry argument: that purchasing decisions are shaped by price and convenience as much as by nutritional warnings. Himanshu Manglik, president of Gurgaon-based consultants Walnutcap and formerly a senior executive for Nestlé in India, cites the PwC survey, which found that even health-conscious consumers balance taste, price, and nutrition, with value the most important consideration for 63%. “Consumers will search for convenience, taste and value irrespective of red flagging,” he says.

Rather than relying on warnings alone, Manglik argues the FSSAI should account for the regional diversity of food culture in India and support a wider shift in eating habits. He says the food regulator should treat India as a federation of smaller markets, where traditional and regional recipes help consumers understand food combinations and ingredients, as well as innovative products. He adds: “Not just red-flagging but partnership in R&D, nutritional awareness and lifestyle changes will be integral to solutions countering NCD [non-communicable diseases] challenges.”

Public-health advocates acknowledge that labels alone will not resolve India’s diet-related disease burden, although they see mandatory front-of-pack warning labels as a necessary starting point. Nair says further policies will be needed to promote healthy food habits. “Warning labels would be a first step but there would need to be more concerted action by society,” he says.

Dr Gupta believes HFSS labels could launch changes in consumer habits that would then needs to be accompanied by nutritional literacy and new rules on advertising. Tackling India’s growing obesity rate will be a tough task but the country’s health advocates believe front-of-pack labels will be a vital tool.