Background
The increasing prevalence of lifestyle-related health issues such as obesity, diabetes, and cardiovascular diseases has heightened the global demand for transparency in food labelling. In response to this growing concern, the Food Safety and Standards Authority of India (FSSAI) has introduced robust regulations to promote informed food choices. One of the critical components of these regulations is Clause 5(3)(A) of the Food Safety and Standards (Labelling and Display) Regulations, 2020. This clause outlines detailed labelling requirements for nutritional information on prepackaged food products, aiming to empower consumers with accurate and clear nutritional data.
Importance of Nutritional Labelling
Nutritional labelling plays a vital role in public health. It enables consumers to understand what they are consuming and to make dietary choices in line with their health goals and medical needs. For regulatory authorities, such labelling also helps monitor the nutritional quality of the food supply and encourages the food industry to reformulate products in favor of healthier alternatives. Clause 5(3)(A) of the FSSAI’s regulation is a significant step toward aligning India’s food labelling practices with global standards, providing consumers with the right information in a scientifically structured manner.
Overview
Clause 5(3)(A) mandates that every prepackaged food product must display nutritional information on its label. This nutritional information is defined as a description that informs the consumer of the food’s nutritional properties. The regulation further specifies key nutrients that must be declared and defines each with technical precision. These include sugars, added sugars, fats (with subcategories), dietary fibre, and nutrients in general.
Key Definitions under Clause 5(3)(A)
The clause provides a set of clear and scientifically sound definitions, which are crucial for consistent and meaningful nutritional disclosures. These definitions are as follows:
1. Sugars and Added Sugars
By distinguishing between naturally occurring and added sugars, the regulation helps consumers understand the quality of sugar in their food, thus enabling them to manage sugar intake more effectively.
2. Fats and Their Subtypes
Fat is defined as the total lipids present in the food, encompassing various types of fatty acids.
The regulation further breaks down fat into the following subtypes:
This detailed classification ensures that consumers can differentiate between harmful and beneficial fats and make choices that support cardiovascular and overall health.
3. Dietary Fibre
Dietary fibre is defined as carbohydrate polymers with a degree of polymerization (DP) of three or more, which are not digested by enzymes in the human small intestine. Fibre can be categorized as:
Including dietary fibre in the nutritional declaration is essential, as it plays a crucial role in digestive health, blood sugar regulation, and cholesterol control.
4. Nutrients
The term nutrient encompasses any constituent of food that:
This broad definition includes macronutrients such as carbohydrates, proteins, and fats, as well as micronutrients like vitamins and minerals. By mandating the declaration of nutrients, the regulation ensures that consumers are aware of both the caloric value and the nutritional adequacy of the food products they consume.
Implications for Food Manufacturers
Compliance with Clause 5(3)(A) necessitates that food manufacturers and packagers conduct detailed nutritional analyses of their products. Accurate labelling requires investment in laboratory testing, standardization of recipes, and meticulous label design. However, this also presents an opportunity for brands to showcase their commitment to transparency and health-consciousness, which can significantly enhance consumer trust.
In the long run, the requirement for detailed nutritional information is likely to encourage reformulation of food products to reduce harmful ingredients like trans fats and added sugars. This will help create a healthier food environment in India and potentially drive innovation in the development of nutritious, clean-label products.
Challenges and the Way Forward
While Clause 5(3)(A) sets a high standard for food labelling, its successful implementation depends on awareness, enforcement, and infrastructure. Small and medium enterprises (SMEs), in particular, may face difficulties in compliance due to limited technical and financial resources. Capacity-building programs, subsidized testing facilities, and clear guidance documents from FSSAI can play a critical role in aiding such stakeholders.
Moreover, consumer education is key. Merely listing technical terms on labels is not enough—consumers must be taught how to interpret this information meaningfully. Public awareness campaigns, mobile apps, and simplified front-of-pack labelling can supplement the regulation and enhance its effectiveness.
Penalty for Non-Compliance:
Any person who whether by himself or by any other person on his behalf manufactures for sale or stores or sells or distributes or imports any article of food for human consumption which is misbranded, shall be liable to a penalty which may extend to three lakh rupees.
Read more about the regulation: https://fssai.gov.in/cms/food-safety-and-standards-regulations.php
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