The ingredient list on a food label is one of the most vital pieces of information for consumers. It ensures transparency, enables informed decision-making, and safeguards against allergens, dietary preferences, and deceptive marketing. Under the Food Safety and Standards (Labelling and Display) Regulations, 2020, the Food Safety and Standards Authority of India (FSSAI) has laid out detailed guidelines on how food business operators (FBOs) must declare ingredients on pre-packaged food labels.
This article explores the rules, exceptions, and industry implications of the mandatory declaration of ingredients in packaged food, and how FBOs must structure their labelling to remain compliant.
Applicability: When is the Ingredient List Required?
The rule is simple:
Except for single ingredient foods, every pre-packaged food must carry a List of Ingredients on the label.
Single ingredient foods such as plain sugar, table salt, raw rice, or mineral water, are exempt. However, the moment a product is composed of two or more ingredients, this rule becomes mandatory.
(a) Compound Ingredients: How to Declare?
What is a Compound Ingredient?
A compound ingredient is an ingredient made from two or more ingredients. Examples include:
Declaration Options:
There are two ways to list compound ingredients:
(i) Declare the compound ingredient by name, followed by its ingredients in brackets:
Example:
Chocolate Chips (Sugar, Cocoa Butter, Cocoa Mass, Milk Solids, Emulsifier [INS 322])
This method helps retain the recognizability of the compound while giving full disclosure.
(ii) List all sub-ingredients as if they are individual ingredients of the final product:
Example:
Sugar, Wheat Flour, Cocoa Butter, Cocoa Mass, Milk Solids, Emulsifier (INS 322), Baking Soda
This approach is more straightforward but longer.
Exemption Clause:
If a compound ingredient constitutes less than 5% of the final product, its individual components need not be declared, except food additives that serve a technological function.
Rationale:
This allows for label clarity and avoids unnecessary clutter for trace components.
(b) Declaration of Added Water
Rule:
All added water must be declared in the ingredient list.
Exceptions:
“Ingredients of the product when prepared in accordance with the directions on the label.”
Purpose:
This ensures consumers know the product’s true nature, especially when a large portion of the product’s weight is from water.
(c) Quantitative Ingredient Declaration (QUID)
QUID means declaring the percentage or proportion of certain ingredients by weight or volume at the time of manufacture.
When is QUID mandatory?
It is required in two key cases:
Example:
Exemptions from QUID:
QUID is not required in the following situations:
Example: The amount of tomato in tomato ketchup may vary slightly but doesn’t affect its identification.
Fortified Micronutrients:
Ingredients like vitamins, minerals, amino acids, etc., subject to nutritional declaration under Regulation 5(3), are exempt.
Enforcement and Penalties
Failing to comply with ingredient declaration norms may result in:
FSSAI conducts periodic inspections, label audits, and encourages public complaints to identify and act against non-compliant products.
Conclusion
The list of ingredients on food packaging is more than a compliance requirement — it is a tool for consumer empowerment, transparency, and public health protection. FBOs must understand and implement the regulations regarding compound ingredients, added water, QUID, and exemptions precisely and truthfully.
In an increasingly health-conscious market, consumers demand more information and clarity. Ensuring a properly formatted, complete, and honest ingredient label is not just a legal duty — it is also a brand responsibility.
Food businesses should periodically audit their product labels, stay updated on FSSAI amendments, and train their marketing and compliance teams to navigate ingredient declarations responsibly.
Read more about this Regulation: Food Safety and Standards (Labelling and Display) Regulations, 2020
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