Understanding Claims Related to Dietary Guidelines and Healthy Diets under FSSAI Regulations

In the era of heightened health consciousness and increasing prevalence of lifestyle-related diseases, consumers are seeking food options that align with healthy eating patterns. To meet this demand, food businesses often market their products as part of a “healthy diet” or “balanced lifestyle.” However, to prevent misleading or exaggerated claims, such statements are governed by strict regulatory frameworks under India’s Food Safety and Standards Act, 2006 (FSSA).

Regulation 8 of the Food Safety and Standards (Advertising and Claims) Regulations outlines the criteria for making claims related to healthy diets and dietary guidelines. These rules ensure that such claims are scientifically backed, aligned with national dietary standards, and do not mislead consumers by oversimplifying or exaggerating health benefits.

This article provides a comprehensive overview of this regulation, its implications for food businesses, and its role in protecting consumer interests.

What Are “Healthy Diet” Claims?

Claims related to a healthy diet refer to statements or representations that link a particular food or food product with a nutritionally balanced dietary pattern. These claims may use phrases like:

  • “Part of a healthy lifestyle”
  • “Supports a balanced diet”
  • “Nutritious choice for everyday meals”

Such claims often influence consumers who are trying to adhere to nationally recommended dietary practices. However, without regulation, they may be used loosely or misrepresent actual nutritional value. Hence, FSSAI ensures these claims are made only under clearly defined criteria.

1. Reference to ICMR Dietary Guidelines

Requirement

Any claim about a food being a part of a “healthy diet” must be in accordance with:

  • The Dietary Guidelines for Indians issued by the Indian Council of Medical Research (ICMR)
  • The Nutrient Requirements and Recommended Dietary Allowances (RDA) for Indians

The label must also clearly state the connection between the food product and the ICMR-recommended dietary pattern.

Rationale

ICMR’s dietary guidelines are developed by medical and nutritional experts based on scientific research, population health trends, and nutritional needs across different age groups in India. Aligning food claims with these guidelines ensures:

  • Nutritional accuracy
  • Public health alignment
  • Standardized benchmarks for food businesses

Example

A ready-to-eat millet-based breakfast may carry a label saying:

“Millets are recommended as part of a healthy diet rich in fiber and whole grains – as per ICMR guidelines.”

This kind of claim must be backed by the food’s composition and aligned with national dietary policy.

2. Holistic Nutritional Evaluation: No Cherry-Picking

Provision

Foods described as part of a “healthy” or “balanced” diet must:

  • Not be based on selective nutrient features (e.g., high in fiber but also high in sugar)
  • Meet the criteria for all major nutrients, especially:
    • Fats (saturated and trans)
    • Sodium
    • Sugar
    • Protein
    • Micronutrients

The product must reflect a well-rounded nutritional profile, consistent with ICMR guidelines and Recommended Dietary Allowances (RDAs).

Issue with Selective Claims

Many brands highlight one positive attribute while ignoring harmful ones:

  • A breakfast cereal may advertise “high in iron” while being high in sugar.
  • A snack bar may claim “rich in fiber” while containing excessive saturated fat.

Such cherry-picking of nutritional benefits is prohibited under this regulation.

Business Implication

Before positioning a product as “healthy,” businesses must conduct a full nutritional assessment and ensure compliance with ICMR thresholds across the board.

3. Foods Should Not Be Depicted as Singularly Health-Giving

Provision

A food product must not be described as “healthy” or represented in any way that implies that it alone will impart health benefits.

This provision reinforces that:

  • No single food can be responsible for an individual’s health.
  • Health outcomes are a result of overall dietary patterns, lifestyle choices, and individual needs.

Prohibited Representations

Claims such as:

  • “This drink will boost your immunity”
  • “This snack keeps you fit”
  • “Eat this for good heart health”

…are not allowed, unless supported by substantial scientific evidence and regulated under specific health claim provisions.

Permitted Language

Acceptable claims might include:

  • “Can be enjoyed as part of a balanced diet”
  • “Supports a diet rich in whole grains and low in saturated fats”

Such language places the food in context of a broader eating pattern, rather than exaggerating its individual benefit.

4. Flexibility in Wording Permitted

Provision

FSSAI allows flexibility in phrasing as long as the essence of the claim is consistent with:

  • The Nutrient Requirements and RDAs for Indians
  • The ICMR Dietary Guidelines

This flexibility accommodates:

  • Cultural variations in communication
  • Regional language adaptations
  • Marketing creativity—as long as it remains scientifically accurate

Examples

Acceptable variations may include:

  • “Good for everyday nourishment” (if justified by overall nutrition)
  • “Inspired by ICMR-recommended eating patterns”

However, even flexible language must be truthful, not misleading, and based on evidence.

Key Objectives of This Regulation

  1. Promote Nutritional Honesty
    Prevents businesses from using vague or deceptive “healthy” tags.
  2. Prevent Consumer Misinformation
    Helps ensure consumers don’t assume one food item can replace a balanced diet.
  3. Encourage Industry Alignment
    Pushes food businesses to reformulate products to meet ICMR standards.
  4. Uphold Public Health Goals

          Aligns marketing strategies with India’s nutrition and wellness objectives.

Regulatory Challenges

While the regulation sets a clear standard, several challenges persist:

  • Evolving scientific data: ICMR updates guidelines periodically. Businesses must stay up to date.
  • Cross-category foods: Some fusion or fortified foods may not fit neatly into dietary models.
  • Consumer perception: Even compliant claims can be misunderstood if not communicated responsibly.

Compliance Strategy for Food Businesses

  1. Nutritional Validation
  • Compare product composition with ICMR RDA thresholds
  • Avoid nutritional imbalances (e.g., high protein with high sugar)
  1. Evidence-Based Labelling
  • Ensure all health or diet claims are backed by scientific studies
  • Cross-reference with Schedule I and IV where applicable
  1. Responsible Language
  • Avoid using the term “healthy” as a standalone label
  • Include qualifiers and context to prevent misrepresentation
  1. Legal Review
  • All packaging and promotional content must be vetted for regulatory compliance
  • Document claim rationale and scientific basis
  1. Consumer Education
  • Use websites, QR codes, or packaging space to explain the science behind the claim
  • Encourage balanced diets rather than promoting a single product as the solution

Penalties for Non-Compliance

Violating these rules may result in:

  • Monetary fines up to ₹10 lakhs (under Section 53, FSSA, 2006)
  • Corrective actions, such as label withdrawal or product recall
  • Legal prosecution in extreme cases of repeated violations
  • Loss of consumer trust and market value

Conclusion

The regulation of claims related to dietary guidelines or healthy diets under the FSSAI framework plays a vital role in shaping transparent, science-backed, and consumer-friendly food labeling.

By ensuring that “healthy” claims are not used loosely or misleadingly, FSSAI promotes a responsible food ecosystem where businesses align with national nutrition goals and consumer protection principles.

For food businesses, this presents both a challenge and an opportunity—to innovate responsibly, meet consumer demand for healthier products, and build lasting trust by adhering to the principles of truthful and informed marketing.

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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