Introduction
Labelling serves as the first interface between a food product and the consumer. In today’s consumer-driven food industry, the accuracy, clarity, and honesty of food labels play a critical role not only in safeguarding public health but also in building consumer trust. Recognizing this, the Food Safety and Standards Authority of India (FSSAI) has laid down specific General Requirements under the Food Safety and Standards (Labelling and Display) Regulations, particularly applicable to pre-packaged foods.
This article examines the general labelling requirements that food business operators (FBOs) must comply with to ensure lawful and ethical marketing and sale of packaged food products in India, including provisions for e-commerce platforms and multi-layered packaging.
1. Mandatory Labelling of Pre-Packaged Foods
Provision: “Every pre-packaged food shall be labeled with information as required under these regulations unless otherwise provided.”
Significance:
All food items that are pre-packaged — whether manufactured for retail sale or bulk distribution — must carry mandatory information as specified by FSSAI. This includes:
Exception: Any exemption (e.g., for certain small packages or specific categories like proprietary foods) must be explicitly provided for in the regulations.
2. E-Commerce and Direct Selling Requirements
Provision:
“When a food product is sold through e-commerce or any other direct selling means, the mandatory requirements of the label shall be provided to the consumer through appropriate means before sale except:
• Batch number/ lot number
• Best before / Use by date / Expiry date
• Date of manufacturing / packing”
Rationale:
The online purchase environment lacks physical access to the product before sale. Therefore, digital platforms must display essential product details to allow informed consumer decisions.
Important Note: While the above exemptions are allowed, they must still be printed on the physical product at the time of delivery. Platforms like Amazon, Flipkart, and food aggregators must comply by hosting complete product profiles online.
3. Prohibition of False or Misleading Representation
Provision
“Pre-packaged food shall not be described or presented on any label or in any labelling in a manner that is false, misleading or deceptive or likely to create an erroneous impression regarding its character in any respect.”
Examples of Non-Compliance:
Implications:
Any such misrepresentation can result in:
4. Use of Additional Information and Graphics
Provision:
“Any information or pictorial device written, printed, or graphic matter may be displayed on the label provided it is not in conflict with the requirements of these regulations.”
Interpretation:
Marketers can use QR codes, infographics, or quality certification logos (e.g., AGMARK, BIS) to add value — but must ensure they do not contradict FSSAI standards or create confusion.
Allowed: Additional nutritional facts, eco-labels, or product origin info
Not Allowed: Fake endorsements or unverifiable health claims
5. Language Requirements on Labels
Provision:
“The particulars of declaration shall be in English or Hindi in Devanagari script.”
Provisos:
Importance:
This promotes accessibility and understanding across India’s diverse linguistic population. However, consistency across multilingual labelling is critical to avoid misleading consumers.
6. Secure Attachment of Labels
Provision:
“Label on pre-packaged foods shall be applied in such a manner that it will not become separated from the container.”
Practical Meaning:
This ensures traceability and product authenticity from factory to point of sale.
7. Readability and Legibility Standards
Provision:
“Contents on the label shall be clear, unambiguous, prominent, conspicuous, indelible and readily legible by the consumer under normal conditions of purchase and use.”
Key Requirements:
Example: “Contains Artificial Sweetener” must be bold and clearly visible near the ingredients list.
8. Multi-Layer Packaging and Outer Wrappers
Provision:
“Where a package has an outside container or wrapper that is displayed for retail sale, it shall also contain all declarations required on the package, unless the wrapper is transparent and original package is visible.”
Note: In transparent multi-unit packages, label declarations on at least one retail unit must be clearly visible.
Scenario Examples:
Enforcement and Penalties
Failure to comply with general labelling requirements may lead to:
FSSAI has been actively conducting random inspections and deploying the Food Safety Compliance System (FoSCoS) for tracking label compliance digitally.
Conclusion
Labelling is not just a regulatory formality — it is a direct communication channel between food businesses and their consumers. The general requirements outlined under FSSAI’s labelling regulations ensure that consumers receive truthful, complete, and accessible information, empowering them to make informed choices.
As India’s food industry rapidly evolves — with increased health awareness, digitization, and demand for transparency — labelling standards will continue to shape consumer trust and brand reputation. For FBOs, strict adherence to these requirements isn’t just about compliance — it is also a long-term investment in customer loyalty and regulatory goodwill.
Read more about this Regulation: https://fssai.gov.in/cms/food-safety-and-standards-regulations.php
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