Understanding Health Claims Under FSSAI Regulations: Legal Framework, Scientific Basis & Best Practices

In the modern consumer landscape, health claims are among the most powerful marketing tools used by food businesses. Phrases such as “boosts immunity,” “supports heart health,” or “improves digestion” often influence purchasing decisions. However, these claims must stand on a strong foundation of scientific validation and regulatory compliance. In India, such claims are governed by the Food Safety and Standards (Advertising and Claims) Regulations framed under the Food Safety and Standards Act, 2006 (FSSA, 2006).

This article delves into health claims — what they are, the regulatory requirements, the scientific evidence needed, and how businesses can ensure full compliance while maintaining consumer trust.

What Are Health Claims?

A health claim is a statement on food labels, advertisements, or promotional materials that suggests a relationship between the consumption of a food or one of its constituents (like nutrients or bioactive substances) and health benefits.

Health claims typically refer to:

  • The role of a nutrient or substance in normal physiological functions.
  • A reduction in the risk of disease or a health condition.
  • The overall impact of the food on human health.

Legal Mandate: What FSSAI Requires

Under the Food Safety and Standards (Advertising and Claims) Regulations, FSSAI mandates that any health claim must be clear, scientifically substantiated, and not misleading. Regulation 7 of these rules outlines specific conditions that food businesses must meet before making a health claim.

1. Structure of a Health Claim

Dual Components of a Valid Claim

Every health claim must consist of two parts:

(i) Physiological Role of the Nutrient or Food Substance
This part of the claim explains how the nutrient or food component functions in the human body.
Example: “Calcium helps in the normal development of bones.”

(ii) Product Composition Details
It should specify that the food contains a sufficient amount of the nutrient related to the claimed function. If the claim relates to an entire food (not just a nutrient), then this part may be exempt if the benefit is supported by whole-food-based research.

2. Recommended Dietary Allowance (RDA) Compliance

If the claimed benefit is linked to a specific nutrient for which RDA values exist, the following applies:

  • If increased consumption is recommended:
    The food must be a source of or high in the nutrient as per Schedule I of the regulations.
  • If reduced consumption is recommended:
    The food must be low in, reduced in, or free of the nutrient, again adhering to the thresholds in Schedule I.

Example: A product claiming “low sodium for heart health” must have sodium levels below the defined threshold in Schedule I.

3. Mandatory Label Declarations

Health claims must be accompanied by:

  • Quantity of the nutrient or substance mentioned in the claim, expressed per 100g, 100ml, or per single-consumption pack.
  • Target group identification if the food is intended for a specific population (e.g., children, elderly).
  • Contraindication warnings where necessary (e.g., “not recommended for pregnant women”).
  • Directions for use in the context of diet and lifestyle (e.g., consume with a balanced diet).
  • Maximum safe intake levels, if the nutrient poses risks in high doses.

This ensures informed decision-making by consumers and promotes responsible use.

4. Scientific Substantiation of Claims – Function Claims & Evidence

Nutrient function claims and other health-related function claims must be:

  • Based on current, relevant scientific evidence.
  • Supported by generally accepted reviews of the data.
  • Reviewed and updated by the food business operator as new research becomes available.

Food businesses must maintain a scientific dossier containing:

  • Mechanistic studies
  • Clinical trials
  • Meta-analyses

References from peer-reviewed journals

5. Claims for Edible Vegetable Oils

FSSAI allows nutrient function claims for edible vegetable oils as per Schedule IIA. This includes statements like:

  • “Rich in monounsaturated fats – supports heart health”
  • “Contains omega-3 – helps reduce inflammation”

However, these claims must still meet the dual-part structure and be scientifically verifiable.

6. Disease Risk Reduction Claims

Perhaps the most sensitive category of health claims, disease risk reduction claims can only be made:

  • If they are listed in Schedule III, and
  • If all specified conditions are met.

Such claims must be non-diagnostic, i.e., they can’t say a food treats or cures a disease but may claim to reduce the risk of one.

Permissible example: “Plant sterols may help reduce cholesterol, a risk factor for heart disease.”

Prohibited example: “This food prevents heart attack.”

7. Fortified Foods and Health Claims

Foods fortified as per the Food Safety and Standards (Fortification of Foods) Regulations, 2018 may use health claims listed in Schedule IV.

FSSAI also allows flexibility in wording, provided the meaning remains unchanged. This accommodates regional language variations and creative marketing, as long as scientific integrity is maintained.

8. Product-Level Claims: High Scientific Threshold

When the health benefit is attributed not to a nutrient but the entire product, the bar is even higher.

Such claims must be backed by:

  • Statistically significant human intervention studies
  • Trials conducted by or under the guidance of reputed research institutions
  • Studies that follow Good Clinical Practices (GCP)
  • Published in peer-reviewed journals

This ensures that product-level health claims are credible, reproducible, and scientifically sound.

Common Pitfalls to Avoid

Food businesses must exercise caution. Some of the most common violations in health claims include:

  • Omitting the nutrient quantity or usage directions.
  • Overstating benefits without proper RDA compliance.
  • Ignoring contraindications for vulnerable groups.
  • Referencing medical treatment or implying cure.
  • Using outdated or anecdotal data instead of peer-reviewed evidence.

Penalty for Non-Compliance

Under Section 53 of the Food Safety and Standards Act, 2006:

Misleading advertisements or false claims may attract a penalty of up to ₹10 lakhs.

Other consequences may include:

  • Product recalls
  • Legal proceedings
  • Suspension of license

Irreparable brand damage

Best Practices for Food Businesses

To ensure regulatory compliance and consumer confidence:

  1. Audit Every Health Claim: Check if the nutrient function and product composition match regulatory thresholds.
  2. Keep a Claim Dossier: Maintain all scientific studies, references, and trial results.
  3. Monitor Updates: Regularly review FSSAI notifications, especially changes to Schedules I–IV.
  4. Train Marketing Teams: Ensure that promotional content creators understand the legal boundaries.
  5. Engage Experts: Involve food scientists and legal advisors to vet all claims pre-launch.
  6. Test Products Independently: Use NABL-accredited labs for nutrient validation.

Conclusion

Health claims offer a powerful way to communicate a product’s benefits — but with great power comes great responsibility. The Food Safety and Standards Authority of India ensures that these claims are not only truthful but also based on scientific rigor and public health considerations.

For food businesses, aligning with these regulations is not just about avoiding penalties — it’s about building trust, ensuring transparency, and contributing to the well-being of consumers. For regulators, the structured framework ensures that India’s evolving food market grows responsibly. And for consumers, it offers confidence that the health claims on labels are more than just words — they are promises grounded in science.

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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