By Dr Saurabh Arora*

In India there is a rising trend of packaged and processed food which has made labeling indispensable and mandatory for Food Business Operator’s (FBOs) and manufacturers. Considering the importance of labeling, the government all over the world is striving to give the right message and to regulate and apprise the consumers about the food they choose and the proportion of ingredients in it.  It is a matter of concern that a large number of people are overweight and grappling with high blood pressure. There is an apparent dietary shift as people are largely drawn towards processed and junk foods. Obtrusively, there is a surge in consumption of ultra-processed foods.    

In this scenario, the Food Safety and Standards Authority of India (FSSAI)regulations  has updated that it is necessary that the FBOs who are manufacturing the packaged foods must ensure that all the food is packed and labeled as per FSSAI regulations from time to time.

Primarily, the food packaging must ensure all the labeling requirements or else they have to bear the brunt of heavy penalties. Indeed it is the accountability of the Food Business Operators (FBO’s) to provide accurate information on the product label to the consumers. Moreover, proper packaging is mandatory to obtain a Food license.

Why is safe packaging of food products a key concern in India?

The growing concern on the health impact of packaged foods has led FSSAI to take stringent measures such as all pre-packed food needs to comply with the packaging and labeling regulations. As per FSSAI labeling guidelines, a product has to be properly labeled with all essential information before it is ready for sale in the market. The labeling includes printed or graphic content information about the packaged food product.

From the perspective of consumers the label information is imperative as they evaluate the product based on the content of information like the ingredients, weight, price, expiration date, nutritional value, etc. before purchasing a product.

The labeling conveys the information about the manufacturer, packer, distributor, and seller. Moreover, it is a medium through which manufacturers can notify the customers about the quality and the vital aspects of their food products.

Consumers have become more aware today as they review the labels to know about the ingredients composition, nutritional value, expiration and other contents on the label. This is why it is indispensable for the FBOs to provide all the required and relevant information on the packed food products before applying for the FSSAI license.

The Food laws state that every packaged food has to be labeled with vital information and should abide by the labeling and packaging laws in the country.

The Food Business Operator (FBO) must be registered with FSSAI and acquire the relevant licenses for the business. 

Front of Pack Labeling

Currently, food packets carry nutrition labels at the back of the packet which makes it difficult for the consumers to read. 

The new rules have mandated the packaged food companies to label high fat, sugar and salt content and the necessary information in front of the package itself. 

The food industry wants the label to be a guideline for informing the consumers about the quantity of salt, sugar, sodium and fats in the packet without giving the health warning to make consumers make an informed decision without discouraging the consumption of packaged food. 

Complying with labeling requirements is pivotal as labeling error could prove to be catastrophic both for consumers and manufacturer or food business operators. 

FSSAI has clarified that the ’Display of Information (Menu labeling) in Food Service Establishments will be crucial  for Food Business Operators (FBOs)  from the beginning of the year 2022.

The guideline  is in reference to 9th Amendment  of Food Safety and Standards (Packaging and Labeling) Regulations, 2011 notified on 21 ‘ August, 2020 vide Gazette Notification F. No. REG-18/Menu Labeling/FSSAI-2018. The idea is to provide all the nutritional information to consumers. 

Labeling is the most important aspect of packaging food items and it conveys vital information about the food products besides obtaining legal compliance. The information on the packaging of the food should be adequate and accessible to each person in the food chain involved with handling, storing and displaying the product. 

The label should provide information on food allergen in the product as ingredients or where cross contamination cannot be excluded as per Food Safety Standards (Packaging and Labeling) Regulations 2011. 

The food labels will also declare per serve percentage contribution to RDA (recommended dietary allowance) on the front of the pack.

Significance of the new regulations

It is significant to manage the Recommended Dietary Allowance of the products for the health of consumers.The new regulations prescribed the limits of ingredients with the definite limits as a restraint on the companies to maintain healthy products.

The display of sodium and cholesterol which was only claimed in the old regulation of 2011 has been mandatory for the companies. 

The display of dietary fiber has been made compulsory. 

All packaged food products have to be in compliance with Food Safety and Standards Act 2006 

It  has been stated by the FSSAI  that the practice of Menu labeling in a self-compliant manner, no sampling of the food items listed on the menu cards/boards/booklets by the FBOs shall be carried out to check/verify the respective declarations of calorific value and nutritional information till 30th June, 2022.

 FSSAI has also clarified that any non-compliance may be addressed by issuing improvement notice under Section 32 of the FSS Act, 2006 for further compliance. 

The direction has been issued with the approval of Competent Authority in exercise of the power vested with Food Authority under Section 16(5) of the FSS Act, 2006. 

The food authority has decided the timeline for mandatory compliance of the provisions relating to labeling. 

Till 1^st july 2022 the food business operators can use specific labeling provisions on a voluntary basis.

Food Products Standards and Food Additives Amendment Regulations 2021, and the Food Safety and Standards (Labeling and Display) Amendment Regulations 2021 as enclosed are re-operationalize with effect from 1^st July 2022.

What We Offer

We as a group also operate the National Food Laboratory to support the industry for FSSAI testing and compliance under PPP model. 

Our network of laboratories in pan India locations provide food testing and personal consulting sessions, industry updates and insights.  Our online portal www.foodsafetyhelpline.com provides the detailed information related to the FSSAI Guidelines for Labeling & Packaging. We help you better understand and effectively implement the requirements of new and evolving laws of Food Safety and Standards Act 2006. We help in arranging and preparing all the vital documentation that is required for the product approval and product labeling. Our experts are well versed in the regulations and provisions and provide complete label reviews for compliance with the FSSAI, enabling them to safeguard against any penalties and queries.

Food Safety Helpline is your single window with multiple choices if you are looking for information on FSSAI compliance. Through our portal we provide your regular news update, online training courses to better understand the requirements and manage the operations. 

*A prolific inventor, pharmacist, scientist, technophile, and visionary entrepreneur. He has been leading the contract, testing, certification, and research business at Arbro and Auriga since 2005 with labs in seven locations. Invented, patented, and commercialized SNEC 30, a scientifically advanced curcumin supplement; Founder of Food Safety Helpline; Founder and Mentor of Lab-Training.com