Understanding Nutrition Claims under FSSAI Regulations: A Comprehensive Guide

Food labeling plays a crucial role in enabling consumers to make informed dietary choices. Among the most critical aspects of labeling are nutrition claims, which indicate the presence or comparison of nutrients in a food product. These claims are tightly regulated under the Food Safety and Standards (Advertising and Claims) Regulations, 2018 issued by the Food Safety and Standards Authority of India (FSSAI).

This article offers a deep dive into the rules governing nutrition claims, their permitted formats, restrictions, and the technical standards companies must meet to ensure compliance.

What Are Nutrition Claims?

Nutrition claims are defined as any representation that states, suggests, or implies that a food has particular nutritional properties, including energy value and/or content of protein, fat, carbohydrates, vitamins, and minerals.

Under FSSAI’s framework, nutrition claims are categorized as:

  1. Nutrient Content Claims – Statements about the level of a nutrient in a food (e.g., “low in fat”, “high in fiber”).
  2. Nutrient Comparative Claims – Statements comparing the nutrient levels between similar products (e.g., “reduced sugar compared to regular biscuits”).

These claims serve marketing purposes but more importantly guide health-conscious consumers. However, such claims must meet clearly defined legal criteria to avoid misleading the public.

What Does Not Qualify as a Nutrition Claim?

The regulation explicitly excludes certain references from the scope of nutrition claims to avoid misinterpretation:

  1. Ingredient Mentions: Simply naming ingredients in the ingredient list (e.g., “contains oats” or “with almond”) is not a nutrition claim.
  2. Mandatory Nutrient Declarations: The nutrition panel is a compulsory requirement and not considered a “claim” by itself, even if it contains high or low nutrient values.
  3. Required Nutrient Disclosures: If nutrients are declared due to mandatory labelling laws (e.g., presence of trans fats, sodium), these are not claims unless presented as a comparative or value-added benefit.

By clarifying these exclusions, FSSAI ensures that consumers do not confuse mandatory information with promotional or comparative claims.

Legal Conditions for Nutrition Claims

To prevent misuse, nutrition claims are permissible only when made in accordance with specific conditions outlined in the regulation’s Schedules I and II:

Schedule I: Nutrient Claim Conditions

This schedule provides quantitative definitions for terms like “low,” “source,” “free,” and “high” in the context of nutrients. For instance:

  • “Low fat” may only be used if the food contains ≤3g of fat per 100g (solids) or 1.5g per 100ml (liquids).
  • “Source of fiber” is allowed if the product provides at least 3g fiber per 100g or 1.5g per 100kcal.

Key point: If a product does not meet these exact thresholds, it cannot legally use these expressions.

Schedule II: Flexibility in Wording

The regulation allows alternative phrases or synonyms as long as:

  • They do not alter the meaning or interpretation of the claim.
  • They comply with the core condition set in Schedule I.

For example, “light in sugar” might be accepted as a synonym for “reduced sugar” if it meets the prescribed standard.

Comparative Nutrition Claims

Comparative claims (e.g., “25% less sugar than leading brand”) must be handled with additional care.

Conditions:

  1. Comparable Products: The compared items must be:
    • Different versions of the same food (e.g., regular and diet cola), or
    • Similar foods in the same category (e.g., two types of breakfast cereals).
  2. Clear Identity: Both products being compared must be easily identifiable to the consumer. Brand names, product types, or visual labels must make it evident which two items are being compared.
  3. Minimum Difference Threshold:
    • For energy, macronutrients, or sodium:
      • A minimum 25% relative difference is required.
      • Also, the absolute difference must meet the “low” or “source” level defined in Schedule I.
    • For micronutrients (excluding sodium):
      • A minimum 10% of Recommended Dietary Allowance (RDA) difference is required.
  4. Disclosure of Difference: The exact difference must be disclosed in proximity to the claim, either:
    • As a percentage (e.g., “30% less sugar”),
    • A fraction (e.g., “one-third more calcium”), or
    • An absolute value (e.g., “5g less fat”).

Failing to provide this detail renders the claim non-compliant and misleading.

Equivalence Claims

Another permitted category of nutrition claims is equivalence claims. These are used to show that a food product provides a nutrient amount comparable to a natural food item.

Examples:

  • “As much Vitamin C as an orange”
  • “Contains the same fiber as one apple”

Conditions for Equivalence Claims:

  • The reference food (e.g., orange or apple) must be a valid source of the nutrient in question as per Schedule I.
  • The labeled food must match or exceed this amount per 100g or 100ml to qualify for the comparison.

These claims may appear on the label or associated labeling materials (e.g., ads, pamphlets) but must still conform to all regulatory definitions.

Importance of Accurate Nutrition Claims

Food businesses must understand the strategic importance and legal responsibility associated with nutrition claims:

For Consumers:

  • Nutrition claims can influence buying decisions, especially for those managing chronic conditions (e.g., diabetes, hypertension).
  • Misleading claims can result in health risks due to false assumptions.

For Businesses:

  • Accurate claims can build brand trust, increase product appeal, and support positioning in health-conscious markets.
  • Non-compliance, however, can lead to:
    • Fines and penalties
    • Product recalls
    • Reputational damage
    • Legal proceedings under the FSS Act, 2006

Enforcement and Penal Provisions

Section 24 of the Food Safety and Standards Act, 2006 prohibits advertisements and claims that are misleading or deceiving. Violations related to incorrect nutrition claims can attract penalties under:

  • Section 53 – Penalty for misleading advertisements: Up to ₹10 lakhs.
  • Section 52 – Penalty for misbranding: Up to ₹3 lakhs.
  • Section 61 – Penalty for obstructing or misleading the Food Safety Officer.

Additionally, products can be ordered off shelves and licenses suspended or cancelled under Section 32.

Best Practices for Businesses

To ensure compliance and avoid regulatory risks, food businesses should follow these best practices:

  1. Audit Product Claims: Regularly review all marketing and packaging materials to verify that claims meet FSSAI criteria.
  2. Back Claims with Data: Maintain laboratory test reports or nutritional analysis that support the stated nutrient levels.
  3. Consult Legal and Nutrition Experts: Before launching a product, consult compliance advisors to ensure all claims are legally viable.
  4. Use Clear Disclosures: When using comparative claims, explicitly mention the compared product and quantifiable difference near the claim.
  5. Stay Updated: FSSAI periodically updates standards—stay informed to adjust packaging/labeling promptly.

Conclusion

Nutrition claims, while powerful tools for consumer engagement, are tightly regulated to ensure public safety and fair trade practices. Whether it’s a simple “low sugar” label or a comparative claim like “25% more protein than regular cereal,” each must be substantiated, quantified, and presented transparently.

The FSSAI’s detailed framework ensures that businesses promote health truthfully, empowering consumers to make well-informed dietary choices. Non-compliance not only attracts financial and legal consequences but also risks public trust.

For food businesses, compliance is not just a checkbox—it’s a commitment to consumer well-being and product integrity.

Disclaimer: The information contained in this Article is intended solely for personal non-commercial use of the user who accepts full responsibility of its use. The information in the article is general in nature and should not be considered to be legal, tax, accounting, consulting or any other professional advice. We make no representation or warranty of any kind, express or implied regarding the accuracy, adequacy, reliability or completeness of any information on our page/article. 

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