Understanding Non-Addition Claims under FSSAI Regulations: A Comprehensive Guide

In today’s health-conscious market, consumers are increasingly aware of what goes into their food. Labels bearing phrases like “No Added Sugar”, “No Added Salt”, or “Free from Additives” have become common on packaged foods. However, such claims are not just marketing tools — they are strictly regulated under Indian food laws to ensure truthfulness, transparency, and consumer protection.

The Food Safety and Standards Authority of India (FSSAI), through its regulations under the Food Safety and Standards Act, 2006, governs such “Non-Addition Claims”. This article explains in detail the provisions related to non-addition of sugars, salt, and additives, as well as additional disclaimer requirements to ensure clarity for consumers.

1. What are Non-Addition Claims?

Non-addition claims are label statements that suggest a food product does not contain certain ingredients, such as sugar, salt, or food additives — either because they were never added or are not present due to formulation. These claims directly influence consumer choices, especially for those with medical conditions (e.g., diabetes, hypertension) or those pursuing clean-label diets.

To prevent misleading information, FSSAI has laid down detailed conditions for making such claims in a truthful and verifiable manner.

2. Non-Addition of Sugars

2.1 Claim Definition

A claim like “No Added Sugar” may only be made if all the following conditions are met:

  • No sugars of any type have been added to the food. This includes:
    • Sucrose
    • Glucose
    • Honey
    • Molasses
    • Corn syrup, etc.
  • The food does not contain any ingredient that includes sugar as part of its composition. Examples:
    • Jams and jellies
    • Sweetened chocolates
    • Sweetened fruit pieces
  • The food does not include ingredients that substitute for added sugars. For example:
    • Dried fruit pastes
    • Non-reconstituted concentrated fruit juice
  • The natural sugar content has not been increased by any technical processing.
    • For example, enzymatic hydrolysis of starch to release glucose is not permitted under such claims.

2.2 When Natural Sugars Are Present

Even if the food naturally contains sugars (e.g., in fruits or milk), a “No Added Sugar” claim may still be made, provided the label also clearly states:

CONTAINS NATURALLY OCCURRING SUGARS

This ensures that consumers are not misled into assuming the product is entirely sugar-free when sugars occur naturally.

2.3 Practical Example

A pack of 100% pure orange juice made from fresh oranges (without added sugar or concentrate) may carry the claim “No Added Sugar”, but must also bear the “Contains Naturally Occurring Sugars” disclaimer.

3. Non-Addition of Salt (Sodium Chloride)

3.1 Claim Definition

Claims such as “No Added Salt” or “Salt-Free” may be used only if:

  • The food has no added sodium chloride (table salt).
  • The food does not include ingredients that themselves contain added salt.

Disallowed Ingredients:

  • Sauces (e.g., soya sauce)
  • Pickles
  • Pepperoni
  • Salted fish
  • Fish sauce

These rules prevent food companies from hiding salt content through indirect sources.

3.2 Importance for Public Health

High sodium intake is linked to hypertension and cardiovascular disease. Non-addition claims serve as vital guidance for consumers managing their salt intake. Therefore, these claims must be truthfully presented and backed by accurate formulation data.

4. Non-Addition of Additives

4.1 Claim Definition

A claim that a food product has “No Additives”, “No Preservatives”, or “Free from Artificial Colors” can be made only if:

  • The specific additive in question:
    • Has not been added to the food directly.
    • Is not present in any of the ingredients used.
    • Is ordinarily permitted in that category of product under the FSSAI Food Additives Regulations, 2011.
    • Has not been replaced with a different additive offering the same functional effect.

4.2 Ensuring Fair Representation

This regulation ensures that food businesses do not mislead by omitting one additive while secretly substituting it with another having similar chemical or functional properties.

Example:

If a soft drink claims “No Artificial Preservatives” but contains another chemical additive acting as a preservative, this would violate the regulation.

5. Additional Conditions and Disclaimers

5.1 Role of Disclaimers

When making non-addition claims, food businesses must ensure that:

  • Additional explanatory statements or disclaimers are used to aid consumer understanding.
  • These statements must be:
    • Conspicuous (clearly visible)
    • Legible (appropriate font size, contrast, placement)

5.2 Why Are They Important?

Even truthful claims can mislead if not properly contextualized. For example:

  • A cereal claiming “No Added Sugar” may still be naturally high in sugars due to dates or raisins.
  • A soup with “No Added Salt” may still be high in sodium due to cheese or soy ingredients.

Disclaimers help bridge this understanding gap by setting the right consumer expectations.

6. Regulatory and Business Implications

6.1 For Food Businesses

Making non-addition claims without meeting these regulatory conditions may result in:

  • Penalties under Section 53 of the Food Safety and Standards Act, 2006
    → Misleading advertisements can attract a fine of up to ₹10 lakhs
  • Legal actions, product recalls, or suspension of license
  • Loss of consumer trust and brand value

6.2 For Consumers

These rules ensure that consumers:

  • Are protected from deceptive labeling
  • Can make informed food choices

Rely on scientifically supported and legally validated product claims

7. Best Practices for Compliance

Food businesses can adopt the following strategies:

  • Label Audits: Regularly check that label content complies with latest FSSAI standards.
  • Ingredient Traceability: Ensure no indirect sugar, salt, or additive sources sneak in.
  • Scientific Justification: Maintain records of lab tests, ingredient specifications, and absence of processing that may alter sugar/salt levels.

Disclaimer Review: Ensure any additional information is clearly visible and easy to understand.

Conclusion

Non-addition claims are more than just marketing language — they are regulated health claims with real implications for public health and consumer trust. By defining strict conditions for when and how such claims can be made, FSSAI has ensured that food labelling in India remains credible, transparent, and science-backed.

For food businesses, it is imperative to understand and comply with these rules to avoid penalties, maintain market reputation, and serve consumer interests. For consumers, these rules offer a safeguard — a reliable reference when choosing healthier options.

As the demand for clean labels and low-sodium/sugar products continues to grow, compliance with non-addition claim regulations will be a key pillar of responsible food 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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