Nutrition Advocacy in Public Interest (NAPi) has submitted a formal proposal to the Food Safety and Standards Authority of India urging it to convert its existing 2022 draft labelling regulations into a system of mandatory interpretive warning labels in line with the Supreme Court’s recent directions. In a letter addressed to FSSAI Chief Executive Officer Rajit Punhani, the organisation said the authority already possesses a ready procedural framework through the Draft Food Safety and Standards (Labelling & Display) Amendment Regulations, 2022, notified on September 13, 2022, and need only amend that draft to replace the proposed Indian Nutrition Rating with clear warning labels.
The submission, signed by Dr Arun Gupta on behalf of NAPi, follows the Supreme Court’s order of August 13, 2026 in the matter of 3S and Our Health Society versus Union of India and another. The bench led by Justice J.B. Pardiwala had observed that an earlier direction of February 10, 2026 had not been taken seriously and asked the government counsel whether the authorities did not want the people of the country to remain healthy. The Court directed the implementation of clear, interpretive warning labels, stating that it was not merely suggesting but directing such a measure, and fixed a two-week deadline for compliance.
NAPi has proposed specific textual changes to the 2022 draft. These include updating the short title to 2026, making compliance mandatory after a transition period, inserting definitions for front-of-pack nutrition labelling and high-fat-sugar-salt foods based on thresholds already present in the draft, deleting provisions for the Indian Nutrition Rating system including star ratings and related tables, and inserting a new requirement that all HFSS products display a black-and-white octagonal or red circular warning symbol stating “HIGH IN” the relevant nutrient of concern—total sugar, saturated fat or sodium—in both English and Hindi. Products carrying the milk logo would not be exempted. The organisation has also recommended using the nutrient thresholds suggested in the 2022 draft and the ICMR-NIN dietary guidelines of 2024, with food business operators required to submit nutrient profiles through the FoSCoS system for generation of the appropriate label.
The proposal cites Indian and international evidence in support of warning labels. A recent randomised controlled experiment in Mumbai with 120 adolescents found that warning labels led 80 per cent of participants to choose a healthier product, outperforming health-star rating, Nutri-Score and a no-label control, while also enabling the fastest decision-making and highest comprehension. An earlier six-state field experiment showed higher correct identification of unhealthy products with warning labels than with numerical tables or star ratings. NAPi notes that the World Health Organization and the Pan American Health Organization recommend warning labels as best practice, and points to the experience of Chile, Mexico and Israel where such labels have driven consumer shifts and product reformulation.
The letter further places the proposal within a broader national consensus, referring to the Ministry of Health and Family Welfare’s National Multisectoral Action Plan, the Economic Survey 2025-26 call for urgent nutrient thresholds and warning labels, ICMR-NIN guidelines, recommendations of two parliamentary committees, answers to parliamentary questions, demands from citizens and members of Parliament, statements by doctors and scientists, and a consensus statement by 29 civil society and public health organisations. It frames the issue as linked to the constitutional right to health under Article 21.
NAPi has urged FSSAI to adopt the proposed amendments as a logical continuation of the existing process rather than beginning afresh, to incorporate them into its next compliance submission to the Supreme Court, and to include the organisation in future technical consultations. A copy of the letter has been marked to the Secretary, Ministry of Health and Family Welfare.
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