The Nutrition Advocacy in Public Interest (NAPI), in its new report titled “50 Shades of Food Advertising”, seeks to expose how seductive, luring, manipulative, and deceptive food advertisements can be. These advertisements lead to increased consumption of unhealthy food products, which are associated with obesity and diabetes, the report states.
India currently holds the dubious distinction of facing both persistent undernutrition among children under five and a rising trend of obesity and diabetes among adults. This dual burden is hardly a point of pride for a country aspiring to become a $5 trillion economy and a global leader across various sectors. Such health challenges could result in a less productive population, with adults performing below their potential.
According to a 2023 study by the Indian Council of Medical Research–India Diabetes (ICMR–INDIAB) study, India has 100 million cases of diabetes, and one in every four individuals is either diabetic, pre-diabetic, or obese. More recently, the Indian Council of Medical Research–National Institute of Nutrition’s (ICMR–NIN) “Dietary Guidelines for Indians” revealed that over 10% of individuals aged 5–19 are pre-diabetic. The Government of India had earlier set a target to halt the rise of obesity and diabetes by 2025 under the National Multi-Sectoral Action Plan to Prevent and Control Non-Communicable Diseases (NCDs) (2017–2022)—a goal that now appears increasingly out of reach.
One of the major underlying factors in the rise of obesity and diabetes is the increasing consumption of unhealthy diets, driven by pervasive and aggressive advertising and marketing of high-fat, high-sugar, high-salt (HFSS) or ultra-processed food (UPF) products. These are rapidly displacing traditional Indian diets.
These products, often rich in sugars, salt, and fats—collectively termed "nutrients of concern"—are seeing rising popularity. According to a study by the World Health Organization India Office (WHO India), retail sales of ultra-processed food (UPF) products in India grew at a compounded annual growth rate of 13.3% between 2011 and 2021.
As per Kantar's Fast-Moving Consumer Goods (FMCG) Pulse Report, 50% of Indian households consumed bottled soft drinks in the 12 months ending March 2024—a 19% increase over previous years. An unpublished WHO India report noted that approximately 200,000 advertisements for HFSS foods are broadcast monthly across select television (TV), print, and digital media platforms.
The “50 Shades of Food Advertising” report offers compelling evidence on how food and drink products are promoted using various manipulative tactics—emotional appeals, endorsements by experts, misrepresentation of real fruit benefits, celebrity promotion, and false health claims. All 50 products studied fall under the HFSS or UPF category.
The report also highlights legislative gaps in frameworks like the Food Safety and Standards Act (FSS Act) 2006, the Cable Television Networks (Regulation) Act 1994 and its Rules, the Consumer Protection Act 2019, and the Norms of Journalistic Conduct 2022. It suggests specific ways to bridge these gaps.
NAPI has submitted proposed amendments to the Press Council of India, the Ministry of Information and Broadcasting, and the Ministry of Consumer Affairs.
The report finds that many advertisements mislead consumers by concealing critical information about nutrients of concern, which is mandated under the Consumer Protection Act 2019. The Advertising Code under the Cable Television Networks (Regulation) Act 1994 states that “No advertisement which endangers the safety of children or creates in them any interest in unhealthy practices... shall be carried in the cable service.” Yet many food advertisements could indeed encourage such practices.
NAPI, therefore, recommends a complete ban on advertising of HFSS and UPF products. It also advocates for regulatory amendments to explicitly define HFSS foods and prohibit advertisements for products that exceed these thresholds.
Food product advertisements deserve distinct regulatory treatment, as they are not comparable to other consumer goods. A February 2024 article in The Lancet stated:
“…A robust regulatory framework is needed to protect children from HFSS food marketing—not just marketing that is ‘directed’ at them—alongside clear, evidence-based food classification criteria.”
According to Dr. Arun Gupta, pediatrician and convenor of NAPI:
“This is the least the Government of India can do as part of its effort to curb the rising consumption of unhealthy diets—and consequently, obesity and diabetes. In the meantime, the government can mandate that every food advertisement disclose in bold letters the amount of nutrients of concern per 100 grams/milliliters. It would be in the public’s best interest for a public health bill to be introduced in Parliament to halt obesity. Failing to do so will only increase the burden of disease and cost—both for families and the healthcare system.”
Dr. Nupur Bidla, a social scientist and NAPI member, adds:
“Through Right to Information (RTI) queries, we discovered that the Food Safety and Standards Authority of India (FSSAI) takes 1–2 years to refer misleading ads to a committee, which continues to seek clarifications from companies. Despite over 100 such cases, none have been penalized, even when the FSSAI committee deemed them misleading. This delay is a gross injustice to Indian consumers and grants companies the freedom to profit while public health suffers. The report proposes an objective method to identify misleading food advertisements to enable swift decisions.”
She further states:
“NAPI recommends that authorities adopt this method to quickly identify misleading advertisements and take immediate action.”
The World Health Organization’s (WHO) 2022 report on food marketing noted:
“It confirms that marketing of foods contributing to unhealthy diets remains pervasive and persuasive, reinforcing the rationale for action to restrict such marketing to children.”
In 2023, WHO further recommended strong policies to protect children from harmful food advertising. Dr. Vandana Prasad, a community pediatrician and NAPI member, notes:
“The World Health Organization Southeast Asia Regional Office provided a nutrient profile model and set thresholds for sugar, sodium, and fat in 18 food categories—beyond which marketing should be prohibited. Now that the ICMR–NIN guidelines have established thresholds for sugar, fat, and sodium in solids and liquids, these should be used to create official HFSS definitions and regulations."
India currently holds the dubious distinction of facing both persistent undernutrition among children under five and a rising trend of obesity and diabetes among adults. This dual burden is hardly a point of pride for a country aspiring to become a $5 trillion economy and a global leader across various sectors. Such health challenges could result in a less productive population, with adults performing below their potential.
According to a 2023 study by the Indian Council of Medical Research–India Diabetes (ICMR–INDIAB) study, India has 100 million cases of diabetes, and one in every four individuals is either diabetic, pre-diabetic, or obese. More recently, the Indian Council of Medical Research–National Institute of Nutrition’s (ICMR–NIN) “Dietary Guidelines for Indians” revealed that over 10% of individuals aged 5–19 are pre-diabetic. The Government of India had earlier set a target to halt the rise of obesity and diabetes by 2025 under the National Multi-Sectoral Action Plan to Prevent and Control Non-Communicable Diseases (NCDs) (2017–2022)—a goal that now appears increasingly out of reach.
One of the major underlying factors in the rise of obesity and diabetes is the increasing consumption of unhealthy diets, driven by pervasive and aggressive advertising and marketing of high-fat, high-sugar, high-salt (HFSS) or ultra-processed food (UPF) products. These are rapidly displacing traditional Indian diets.
These products, often rich in sugars, salt, and fats—collectively termed "nutrients of concern"—are seeing rising popularity. According to a study by the World Health Organization India Office (WHO India), retail sales of ultra-processed food (UPF) products in India grew at a compounded annual growth rate of 13.3% between 2011 and 2021.
As per Kantar's Fast-Moving Consumer Goods (FMCG) Pulse Report, 50% of Indian households consumed bottled soft drinks in the 12 months ending March 2024—a 19% increase over previous years. An unpublished WHO India report noted that approximately 200,000 advertisements for HFSS foods are broadcast monthly across select television (TV), print, and digital media platforms.
The “50 Shades of Food Advertising” report offers compelling evidence on how food and drink products are promoted using various manipulative tactics—emotional appeals, endorsements by experts, misrepresentation of real fruit benefits, celebrity promotion, and false health claims. All 50 products studied fall under the HFSS or UPF category.
The report also highlights legislative gaps in frameworks like the Food Safety and Standards Act (FSS Act) 2006, the Cable Television Networks (Regulation) Act 1994 and its Rules, the Consumer Protection Act 2019, and the Norms of Journalistic Conduct 2022. It suggests specific ways to bridge these gaps.
NAPI has submitted proposed amendments to the Press Council of India, the Ministry of Information and Broadcasting, and the Ministry of Consumer Affairs.
The report finds that many advertisements mislead consumers by concealing critical information about nutrients of concern, which is mandated under the Consumer Protection Act 2019. The Advertising Code under the Cable Television Networks (Regulation) Act 1994 states that “No advertisement which endangers the safety of children or creates in them any interest in unhealthy practices... shall be carried in the cable service.” Yet many food advertisements could indeed encourage such practices.
NAPI, therefore, recommends a complete ban on advertising of HFSS and UPF products. It also advocates for regulatory amendments to explicitly define HFSS foods and prohibit advertisements for products that exceed these thresholds.
Food product advertisements deserve distinct regulatory treatment, as they are not comparable to other consumer goods. A February 2024 article in The Lancet stated:
“…A robust regulatory framework is needed to protect children from HFSS food marketing—not just marketing that is ‘directed’ at them—alongside clear, evidence-based food classification criteria.”
According to Dr. Arun Gupta, pediatrician and convenor of NAPI:
“This is the least the Government of India can do as part of its effort to curb the rising consumption of unhealthy diets—and consequently, obesity and diabetes. In the meantime, the government can mandate that every food advertisement disclose in bold letters the amount of nutrients of concern per 100 grams/milliliters. It would be in the public’s best interest for a public health bill to be introduced in Parliament to halt obesity. Failing to do so will only increase the burden of disease and cost—both for families and the healthcare system.”
Dr. Nupur Bidla, a social scientist and NAPI member, adds:
“Through Right to Information (RTI) queries, we discovered that the Food Safety and Standards Authority of India (FSSAI) takes 1–2 years to refer misleading ads to a committee, which continues to seek clarifications from companies. Despite over 100 such cases, none have been penalized, even when the FSSAI committee deemed them misleading. This delay is a gross injustice to Indian consumers and grants companies the freedom to profit while public health suffers. The report proposes an objective method to identify misleading food advertisements to enable swift decisions.”
She further states:
“NAPI recommends that authorities adopt this method to quickly identify misleading advertisements and take immediate action.”
The World Health Organization’s (WHO) 2022 report on food marketing noted:
“It confirms that marketing of foods contributing to unhealthy diets remains pervasive and persuasive, reinforcing the rationale for action to restrict such marketing to children.”
In 2023, WHO further recommended strong policies to protect children from harmful food advertising. Dr. Vandana Prasad, a community pediatrician and NAPI member, notes:
“The World Health Organization Southeast Asia Regional Office provided a nutrient profile model and set thresholds for sugar, sodium, and fat in 18 food categories—beyond which marketing should be prohibited. Now that the ICMR–NIN guidelines have established thresholds for sugar, fat, and sodium in solids and liquids, these should be used to create official HFSS definitions and regulations."
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