The Nutrition Advocacy in Public Interest (NAPI) has raised serious concerns over the Food Safety and Standards Authority of India’s (FSSAI) latest move to open a fresh public consultation on front-of-pack labelling (FOPL) regulations, warning that the process could further delay a policy that has already been in the works since September 2022.
While welcoming certain improvements in FSSAI’s affidavit dated 23 September 2026 — including the abandonment of the two-phase structure and the “two or more nutrients” trigger, as well as the proposal to include a warning statement for non-caloric sweeteners — NAPI argued that the decision to invite public comments at this stage risks derailing consensus rather than building it.
The organisation insisted that the process should remain internal to FSSAI and the Ministry of Health rather than becoming a dilatory public consultation, especially since this is not a fresh notification but part of an ongoing regulatory process.
NAPI also criticised the proposal to stretch implementation up to July 2028, calling it unreasonable for public health goals and demanding that the regulations take effect by 1 July 2027 or earlier, given the inordinate delay already caused.
On the design of warning labels, NAPI questioned why two or more nutrients of concern should be placed together in a single hexagon, arguing that each nutrient deserves its own separate hexagon.
It also took issue with FSSAI’s insistence on a font size only one point larger than the nutrition information at the back and on using the Canadian model for label size, noting that Canada does not use hexagons and that Mexico and Chile offer more useful models with specific requirements based on the package’s main display area. NAPI called for bold and bigger fonts and for hexagon sizes to be adjusted accordingly, emphasising the specific advantages of black and white warnings.
A major point of contention was FSSAI’s proposal to use “added” sugar instead of “total” sugar on front-of-pack labels.
NAPI warned that this carries serious public health, regulatory and consumer risks, as a product with zero added sugar could falsely appear healthier, companies could reformulate to hide or substitute added sugars while keeping total glycaemic and caloric loads high, and testing laboratories cannot chemically distinguish between added and naturally occurring sugars once mixed into a food product.
It cited FSSAI’s own analysis that adding sugar over and above what is naturally present increases total calorie intake without significant additional nutritional value, and referred to a NIN letter dated 3 September clarifying that the DGI 2024 thresholds should be considered as an integrated framework rather than adopting selected nutrient values independently. NAPI also suggested that FSSAI consider a separate hexagon for energy, as indicated by the DG NIN.
Other concerns included the need to explicitly capture two languages in the label design, since the current draft states the label shall be in English or Hindi in Devnagri script.
On ultra-processed foods, NAPI noted that FSSAI does not propose to use the level of processing as a criterion for warning labels, and while it accepted that this could be kept separate, it insisted the matter be addressed in a timebound manner within one year, citing the Economic Survey’s recommendation to define ultra-processed foods and the sufficient science showing increased intake is harmful to health.
NAPI also questioned why compliant beverages within the threshold limit should carry a red hexagon with the beverage category name, warning that consumers will learn that a red hexagon does not mean the product is high in anything, which is misleading and lacks rationale.
Finally, NAPI reiterated ICMR-NIN’s support for a simple, prominent and easily understood warning system, stressing that the proposed first-phase requirement of being high in two or more nutrients may allow products substantially high in a single nutrient to escape consumer attention, and that the red-hexagon warning should be triggered when a product exceeds the threshold for even one nutrient of concern.
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