India may be nearing an inflection point in the way food products are labelled. Much of the current debate focuses on foods high in fat, sugar or salt, commonly called HFSS foods, and on whether the nutritional information already provided should be made clearer on the front of the pack. But there is a more basic question behind that debate: Should a food label simply disclose accurate information or should it also help the consumer interpret it?
This distinction is important. The Food Safety and Standards (Labelling and Display) Regulations, 2020 currently require detailed nutritional information on pre-packaged foods, including declarations relating to energy, fat, saturated fat, trans fat, added sugar and sodium. The present regulatory discussion is therefore not driven by an absence of information. It is concerned with whether the information is sufficiently prominent, comprehensible and useful at the point when a consumer makes a purchasing decision. A February 2026 response in the Lok Sabha also referred to FSSAI’s label literacy campaign, “#HarLabelKuchKehtaHai” under the “Eat Right India” campaign, reflecting the continuing emphasis on enabling consumers to understand existing declarations.
The evolution of FSSAI’s approach can be traced through two distinct proposals. In September 2022, FSSAI published draft amendments proposing a definition of HFSS food and a front-of-pack labelling system based on an Indian Nutrition Rating. The proposed model would have provided a summary assessment of the nutritional profile of a packaged food, subject to specified exemptions. Government responses in Parliament in 2025 confirmed that the draft was intended to address both the identification of HFSS foods and front-of-pack nutrition labelling.
In February 2025, FSSAI published a further draft amendment suggesting that the per serving percentage contribution to the Recommended Dietary Allowance for added sugar, saturated fat and sodium should appear in bold letters and in a relatively increased font size. This model did not characterise the product as healthy or unhealthy. Instead, it sought to give greater visual prominence to specified elements within the nutritional declaration.
These two approaches do different things. An RDA based declaration gives consumers numerical information and leaves them to assess it. A summary rating applies a nutrient profile and presents the outcome through a comparative indicator. A warning label goes a step further by signalling that one or more nutrients exceed a prescribed threshold. The real policy choice is therefore how much interpretation the regulator should provide rather than leave to the consumer.
The choice of model also affects how a product is perceived. A percentage contribution to RDA can be considered in the context of serving size and the consumer’s overall diet. A front-of-pack rating offers an immediate comparative signal. A warning is more categorical and is likely to have a stronger influence not only on consumer choice but also on product formulation, pack design, advertising and brand positioning.
The discussion has acquired added significance through proceedings before the Supreme Court in 3S and Our Health Society v. Union of India. The petition sought directions for the introduction of front-of-package warning labels on packaged foods to indicate levels of sugar, salt and saturated fat. The Court disposed of the petition after directing that an expert committee be constituted to recommend appropriate amendments to the Labelling and Display Regulations.
The matter did not end there. The Supreme Court further directed the authorities to seriously consider the introduction of front-of-pack warning labels and asked that the response be placed before it. FSSAI has proposed a phased warning-label regime before the Supreme Court: Phase 1 would cover products high in two or more nutrients of concern and specified sweetened beverages while Phase 2 would extend to products high in any one such nutrient. While this is the formal position, public debate may sometimes describe warning labels as imminent, the applicable legal requirements must still be identified from the final regulations as and when notified. A draft proposal, an expert committee report and a submission made in judicial proceedings do not, by themselves, create an enforceable pack-labelling obligation.
The proceedings show that front-of-pack labelling has moved from a general policy debate to a concrete regulatory proposal under judicial scrutiny. The form of the label, the nutrient-profile criteria and the route to final regulations are now before the Court. That makes a transparent, evidence-based process particularly important with meaningful consultation and clear reasons for whichever model is ultimately chosen.
Before deciding what must appear on the front of a pack, the law must identify the products to which the requirement applies. “HFSS” is a fitting policy expression but it does not become a workable legal classification until the regulations specify the relevant nutrients, thresholds, measurement basis, exclusions and method of classification.
This issue is visible in FSSAI’s recent action concerning food in schools. On 11 August 2026, FSSAI published draft amendments to the Food Safety and Standards (Safe Food and Balanced Diets for Children in School) Regulations, 2020 proposing definitions for food products high in added fat, added sugar or salt. The use of the expression “added” is significant. It is not necessarily interchangeable with a system based on total fat, total sugar or the overall nutritional composition of a product. These choices matter. Should classification depend on the total quantity of a nutrient, or only the quantity added to the product? Should it be measured per 100 grams, per 100 milliliters or per serving? If so, how should a serving be standardised? What about foods that require preparation, or nutrients that occur naturally? Scientific evidence will inform the answers but the law must translate that evidence into rules that clearly identify the products covered and can be applied consistently.
Clarity is equally important for enforcement. A front-of-pack requirement should allow a manufacturer, importer and enforcement authority to reach the same conclusion when applying the rules to the same product. Ambiguity at the classification stage is likely to result in inconsistent labels, disputes over product coverage and avoidable reformulation or packaging costs, without necessarily improving consumer understanding. The absence of a clear and consistently applicable and enforceable framework remains one of the most significant gaps in foods law today.
This should not be framed as a contest between public health and commercial convenience. Regulators and food businesses share an interest in labels that communicate material information accurately and clearly. A technically complete label may still be of little use if consumers cannot readily understand it. At the other extreme, an overly simple symbol may strip away relevant context or make a broader judgment devoid of sufficient evaluation on all relevant parameters.
FSSAI’s National Stakeholder Consultation on food labelling, advertising and claims in August 2025 recognised these competing considerations. The consultation focused on truthful and ethical declarations, implementation challenges, consumer protection, public health and alignment with global standards. It also acknowledged the value of implementing label changes in a predictable annual cycle, thereby reducing uncertainty and repeated packaging changes.
Practical implementation will matter just as much if a new front-of-pack model is adopted. Labels are tied to product specifications, laboratory data, artwork approvals, packaging inventories, licensing and registrations, imports and e-commerce listings etc. The final rules will therefore need a realistic transition period, clear treatment of existing packaging material and a consistent approach across physical packs and digital displays. These are not reasons to resist stronger disclosure. They are part of making the regime workable and credible in the long term. FSSAI’s recent actions nevertheless point in a clear direction: greater attention is being paid to whether consumers can readily find and understand information rather than only to whether the prescribed words appear somewhere on a label or platform.
India does not yet have a final HFSS front-of-pack framework. The 2022 rating proposal, the 2025 focus on prominent RDA information, the Supreme Court proceedings and the 2026 draft regulations governing foods supplied in and around schools all show that the issue is being actively considered. The latest Supreme Court filings and hearings suggest that the centre of gravity has now shifted towards an interpretive warning label model, with debate focused on thresholds, label design, phasing, transition and enforceability. That obligation will arise only if and when final regulations expressly create it.
One point is already clear: nutrition labelling is moving beyond the back of the pack. Information about sugar, salt and fat is increasingly expected not only to be accurate, but also to be prominent and easy enough to understand at the point of purchase.
The success of the final framework will depend less on how forceful the chosen symbol looks and more on whether the rules behind it are coherent. The essentials are clear definitions, scientifically sound criteria, proportionate exemptions, workable transition arrangements and consistent enforcement. If these foundations are put in place, front-of-pack labelling can help consumers without turning a complex nutritional assessment into an overly simple verdict.
About the author: Shalini Sinha is the Global General Counsel (Media & Marketing) at The Magnum Ice Cream Company.
The author's views are personal and do not reflect the views of The Magnum Ice Cream Company.
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