By Dev Narsinghani*
A recent Counterview article rightly pointed out that the Indian market is flooded with packaged snacks, instant noodles, and sugary drinks, and it welcomed the Food Safety and Standards Authority of India’s (FSSAI) push for red front-of-pack warning labels on such items.
However, to truly understand the magnitude of this public health intervention, we must look past broad strokes and examine the precise mechanics of a critical, recent regulatory shift. On 23 September 2026, the FSSAI quietly altered the foundation of its warning label proposal, and the implications of this single administrative change are far more sweeping than previously assumed.
Originally proposed on 28 August 2026, the FSSAI plan featured a phased approach. A red hexagonal warning stating "High Sugar," "High Fat," or "High Salt" would initially apply only if a product exceeded limits in two or more of these nutrients, with a stricter single-nutrient threshold introduced at a later date. After the Supreme Court questioned this phased rollout, the FSSAI dropped the phases entirely. Under the current, revised plan, a food product high in even just one of these three nutrients must carry the warning. This seemingly minor pivot fundamentally alters the landscape of food labeling in India.
To quantify the real-world impact of this change, I condicted an open analysis using the India Label Index, running 665 Indian packaged food labels through both versions of the rule. The results are stark. Under the current single-nutrient plan, 71 percent of these 665 foods would carry a warning label. Under the dropped, two-nutrient plan, only 41 percent would have been flagged.
This shift effectively adds a warning to roughly 30 out of every 100 packaged foods, specifically targeting those that are excessively high in just one area. Most commonly, this involves added sugar in 45 percent of foods, added fat in 43 percent, and salt in 33 percent.
The categories where this regulatory switch matters most are precisely those that evade the multiple-nutrient trap.
Soft drinks and energy drinks present the clearest case. While 69 percent are high in added sugar, sugar is typically their only elevated nutrient. Consequently, the warning rate for this category skyrockets from a mere 3 percent under the old plan to 69 percent under the current one. Similarly, sauces, ketchup, and spreads jump from 33 percent to 76 percent, while yoghurt and curd products surge from 3 percent to 34 percent.
Conversely, categories like biscuits, cookies, chips, and crisps see minimal change, moving from 93 to 98 percent and 91 to 94 percent respectively, simply because they are already routinely high in two or more of these critical nutrients. Even instant noodles and pasta, a staple highlighted by Counterview, carry a median salt content of 2.5 grams per 100 grams, which represents half of the entire daily limit set by the World Health Organization for adults.
It is crucial to contextualize these findings. This warning system remains a proposal, not yet enacted law. The Supreme Court reserved its order on this matter on 28 September 2026, and as of mid-October, a final ruling is still pending. The FSSAI has indicated it needs approximately four months to finalize the rule, followed by a one-year grace period for companies to comply. Furthermore, this 71 percent figure is not a proxy for the volume of ultra-processed foods, as the warning is triggered strictly by sugar, fat, or salt thresholds, not by the degree of processing.
The analysis also evaluates broad categories rather than specific brands, rating no individual product. Because the data is sourced from volunteer-contributed entries on Open Food Facts and relies on total fat rather than added fat, the fat figures represent an upper estimate. With only 665 Indian foods possessing the complete nutritional data required for this test, these category percentages should be viewed as indicative rather than absolute.
Consumers need not wait for the Supreme Court’s verdict or the FSSAI’s final notification to apply these standards. The thresholds cited by the FSSAI are derived directly from the ICMR-National Institute of Nutrition’s Dietary Guidelines for Indians 2024. For solid foods, a product is considered high if it contains more than 3 grams of added sugar, 4.2 grams of added fat, or 625 milligrams of salt per 100 grams. For beverages, the limits are even stricter, at 2 grams, 1.5 grams, and 175 milligrams per 100 milliliters, respectively. Anyone can turn a package over today, locate the nutrition table, and compare these values.
The broader India Label Index reveals that six in ten Indian packaged foods list an added sugar, encompassing 3,798 distinct labels. This includes 75 percent of soft drink labels and 67 percent of instant noodle and pasta labels. Ultimately, the entire debate hinges on that one pivotal rule change. By shifting from a two-nutrient to a single-nutrient trigger, the FSSAI’s current plan would place a warning on 71 percent of tested Indian packaged foods, compared to just 41 percent under the discarded framework. As the data unequivocally shows, it is this single-nutrient shift that bites hardest into the everyday staples flooding our market, making transparent, front-of-pack labeling more vital than ever.
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*Mumbai-based health changemaker and operator who works on label transparency with Food Pharmer
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