Introduction
It is now globally well established that front-of-pack-labels (FOPLs) on packaged, processed food items have the ability to direct consumers’ attention towards healthier options. The back of the pack Nutrition Facts Table is rarely used and is difficult to interpret, even by the literate.
Looking them up and comprehending them takes time and cognitive effort. Especially in a country like India that has a plethora of regional languages and where a majority of consumers can read only one or two regional languages, text-heavy nutritional labels are less effective in influencing their behaviour.
Concomitantly, India’s food, health, and nutrition security challenges are no less daunting. Non-communicable diseases (NCDs), including those arising from eating disorders, contribute to around 5.87 million deaths (60 per cent) of all our deaths. One of the leading factors contributing to this is the easy availability of energy-dense foods high in saturated fats, sugars, and salt.
But at the same time, a large section of the population in India consists of the urban and rural poor who have very low literacy and income levels and are malnourished; these sects have no issues with high salt, sugar, or fat. They need all these factors to gain health.
Also, India, being a diverse country, has different food habits and regional tastes. Where north Indians love spicy, salty and ghee laden foods and snacks, south Indians have a taste for sour foods and the west for both sour and spicy foods, Gujarat for sweet and the east for sweet and salty.
And because of this, food regulators in India find it very difficult to introduce such systems. This is either due to a paucity of reliable research or resistance from vested interests or a lack of clarity about an FOPL format that would be easily understandable and also impact choices across different consumer types.
Let’s check global best practices
Globally, the front-of-pack labelling (FoPL) system has been regarded as the best practise to supply ample information on food choices. According to the World Health Organization (WHO), FoPL is defined as “nutrition labelling systems that are presented on the front of food packages in the principal field of vision and present simple, often graphic information on the nutrient content or nutritional quality of products, to complement the more detailed nutrient declarations provided on the back of food packages.”
While some key considerations are taken in developing a FoPL system in a country, the Codex Alimentarius Commission (Codex) has undertaken work on FoPL. Codex is a collection of internationally recognized standards, codes of practice, guidelines, and other recommendations published by the Food and Agriculture Organization (FAO) relating to food, food production, food labelling, and food safety.
Countries like Brazil, Chile, and Israel have labelling laws that stress FoPL in the packaged food industry as an index to fight obesity and non-communicable diseases (NCDs) such as heart disease, stroke, cancer, chronic respiratory diseases, and diabetes. Countries also review the elements of existing systems that are considered to be more effective or less effective in supporting consumers to make informed food purchases and healthier eating choices (using published evidence or primary consumer studies of the usefulness of FoPL system elements, including formats such as design and content).
A global checklist for developing a new FoPL system includes interpretive systems such as the multiple traffic light labelling system (United Kingdom), nutri-score system (France) and warning system (Chile); non-interpretive systems such as percentage reference intakes (European Union); and hybrid systems such as the Health Star Rating (Australia and New Zealand).
India is progressing towards enforcing labels. The Food Safety and Standards Authority of India (FSSAI) will soon start labelling the front of packaged food products with a Health Star Rating (HSR) based on a study conducted by IIM Ahmedabad and one that is easy to understand and induces behavioural changes in Indian consumers.
But health experts are alleging that this move is designed to mislead and confuse consumers. According to them, FSSAI should use simple and interpretive warning labels on the front of packs of products. This will make it easy for consumers to reject unhealthy products. They believe that the food industry is not in favour of disclosing such information to consumers. They are happy with HSR, which is confusing and can be manipulated, and are demanding that the warning labels should be mandatory and not left to the industry as voluntary.
So its Health Experts v/s FSSAI and IIM Ahmedabad
Health experts stress on the warning labels:
With the FSSAI set to implement front-of-pack labelling to discourage consumers from buying packaged foods high in sugar, salt, and fat, public health experts disagree with the country’s apex food standards regulator on the method for doing so.
The FSSAI has proposed implementing a health star rating system (HSR) where the healthier options receive a higher star rating, similar to the star rating of electronics based on their energy efficiency. The system was chosen out of five methods based on an FSSAI commissioned survey conducted by the Indian Institute of Management Ahmedabad (IIM-A) of 20,500 consumers.
The health experts, on the other hand, said that a warning label where a symbol is displayed on the front of food packs high in salt, sugar, fat, and various preservatives was found to be second-best as per the IIM survey. The experts have also questioned the IIM survey for ranking the star rating system as the best.
A position paper by organisations such as the Public Health Foundation of India (PHFI), Centre for Science and Environment (CSE), and Indian Academy of Paediatrics (IAP) states that there was a change in consumption patterns in several Latin American countries that implemented such warning labels, with Chile witnessing a 24% drop in sugary drink consumption. It said that a meta-analysis of 100 studies published last year indicated that nutrient warning labels are more effective than traffic lights and nutri-score labels.
Warning labels allow consumers to recognise whether a product is harmful to their health within seven to ten seconds. No other labelling system, such as a star rating or traffic light, accomplishes this…A star is perceived to be positive and it has been associated with an increase in consumption of these foods.
The experts said that the IIM-A survey, which is yet to be peer-reviewed, seems to have various issues with the methodology. “The survey is being analysed by several experts at the moment, but the study is unreliable. For example, it looks at three different consumer groups—a healthy group that has been primed to understand the labelling norm, an unhealthy group that has been primed, and an un-primed group. But then it collapses all the data together to arrive at the conclusion.
Overall, doctors and health experts believe that FSSAI erred in its approach and decision to include a ‘Health Star Rating’ on unhealthy food and drink products, and that decisions on such public health issues should be made without any conflicts of interest, and that the government should first consult with public health experts.
IIM Ahmedabad Research
On the other hand, FSSAI had asked IIM, Ahmedabad to suggest a suitable, representative front labelling format that would be easy to understand and influence purchase intentions for an average Indian consumer. They conducted large scale national Randomised Controlled Trials (RCT) to determine preference ranks among the popular formats of informative nutrient-specific labels and summary ratings.
An RCT is, arguably, the most rigorous method of determining whether a cause-effect relationship exists between the intervention and the outcome with minimum selection, observer, participant, and response or attention bias.
In their study, they covered consumers from all the major states and across all major socio-economic, geographical, and demographic categories. The experiments were conducted face-to-face over a period of three months with innovative app-based spot checks to ensure accuracy and quality of the highest order. Relevant primes and manipulation checks were used to increase the robustness of the data.
Upon analysing the results, it was found that the summary format of Health Star Rating was the most preferred when the measure used is a combination of ease of identification, understanding, reliability, and purchase intention. Informative labels such as Multiple Traffic Lights, monochrome GDA or Nutri Score were ranked lower by the average consumer.
The scientists at IIM additionally did sub-sample tests based on age, literacy levels, health awareness levels, gender, and frequency of grocery shopping, rural-urban habitat, and levels of back-of-pack-label awareness. Results even from these tests were consistent with summary ratings being clearly favoured over the others.
Among the summary ratings, the Health Star was the easiest to understand among those that influenced purchase decisions, leaving behind warning labels. This is very likely because the latter still required some text-reading abilities and awareness about the highlighted nutrient of concern. On the other hand, a simpler star rating made it easier to understand the relative position of healthiness across products in the minds of an average Indian consumer.
However, global experience cautions that whichever format is implemented, its effectiveness will very much depend on how good and consistent the communication strategy and awareness campaign are attached to it.
Simple indicators for the health quotient of packaged foods must be prioritised by all stakeholders, including the FSSAI, industry, and civil society, as a critical first step toward healthy dietary transitions in a fast-paced, diseased society.
If India does this well, we hope that it will inspire consumer confidence and appropriate policy actions in other developing countries. And those decisions on FOPL are based on research and not spin and lobbying.
Editor’s point of view
Things have changed over time and so have the eating habits of people, and believe it or not, flourishing urbanization is significantly altering people’s food consumption patterns as packaged and processed food items are fast becoming everyone’s favourite.
Though in comparison to western countries, especially the United States, India’s consumption is still pretty low, wherein such foods make up for almost 70% of the country’s diet, nevertheless, consumer penchants seem to indicate a growing preference for western packaged foods over Indian foods.
Recently, FSSAI revealed its plan to label packaged foods based on their fat, salt, and sugar content. But has it been forgotten that most of our traditional and indigenous Indian foods typically contain salt, sugar, jaggery, ghee, oil, and spices that are essential for not only their taste but also have elements uniquely required for the Indian climate?
For some years, FSSAI has been advocating for proper explanatory food labels under the package labelling regulations, i.e., marking food items as ‘good-food,” “not-good food,” “one-star food,” “red-marked food,” etc., based on their salt, sugar, and fat content.
Additionally, there have been considerations around recommending higher taxation on foods that have sugar, fat, salt, and front-of-the pack labelling in their endeavour to tackle rising obesity.
But, have policymakers or health experts considered the impact of this step on Indian packaged foods? The food that our forefathers have been consuming for years, and they have evidently remained healthy.
Most of our sweets like Laddoo, Gulab Jamun, Rasgulla, and Mysore Pak will always contain sugar, and many of our Indian snacks like Bhujiyas or banana chips will also carry salt and fat, as well as sweetness. Even summer beverages that are from ancient times proclaimed to be healthy-like e.g., jaljeera, nimbu pani, lassi, and chhaach will have sugar and salt, in them. Food accompaniments like pickle and chutney will definitely have salt and fat content in them.
Also, our daily breakfast or lunch foods such as parathas and thepla may contain salt and fat, so will that be categorized as unhealthy according to the FSSAI labelling format?
Consequently, if one is to anticipate and understand what is in the future, then be ready to see your favourite Indian foods and specialties coming from different states being marked in red and labelled as’ not good food ‘and getting levied a higher tax rate, making them costly and beyond the reach of the ordinary man.
Indian food as a whole is very different from other western countries’ food. We have diverse eating habits according to need and climate… Like in hilly regions, people’s eating habits consist of lots of spices, especially hot peppers and salt, to keep their bodies warm. Due to its extreme climate, North India basically thrives on salt, spices, oils and sugar. Hence, a cursory glance reveals an interesting pattern that shows some correlation between the spiciness of the cuisine and the climate.
Is FSSAI’s solemn attempt to ensure that consumers know what they are eating a practical way to go about it, or will this scare the common Indian people?
I think the most important thing to do at this moment is to create awareness for India’s huge food manufacturing ecosystem that sells packaged Indian foods that are much larger than the big brands as the majority of them are small manufacturers and women’s self-help groups. And if children were the focus, then there are already safeguards proposed by FSSAI and various state governments for food with high fat, salt, and sugar content to not be given to children in school canteens or sold within 50 m of school campuses.
Yes, I agree totally that anything consumed in excess is bad for one’s health, and consumers should ideally know what they are consuming and how much they should.
But in the case of indigenous Indian foods, labelling doesn’t seem to be the apt way to classify them since there are various implications to it. Imagine tourists visiting India to sample the best Indian delicacies, and seeing “red” or “bad food” labelled on them. This could have a serious impact on tourism and the optics of gifting during festivities.
Although no one is against informing and educating consumers and manufacturers, the way of labelling may turn out to be counterproductive if the optics go bad and taxes get levied.
It must also be noted that Indian foods have been traditionally designed and prepared to suit and survive the prevalent climatic conditions of that particular region, besides the genetic composition of its people.
Because of excessive humidity and sweating, people in coastal states, for example, require and consume salty foods and beverages such as buttermilk. Similarly, the farming population in the northern states of Punjab and Haryana consumes foods high in salt and fat to keep them going in the fields for hours, besides managing the extreme weather conditions.
I honestly believe that the practise of going after sugar and salt was originally a foreign idea and there are apparent global lobbies that are either against fat, sugar, salt, or in favour and if scrutinized deeply, one cannot still assess who is right or wrong. Both lobbies have equally deployed a battery of food and health experts to push their case across governments globally.
I agree that it is the duty of FSSAI to ensure that the consumers are informed of what they are consuming, but there has to be a better method of communicating the daily allowed consumption levels instead of a hazardous display route that seems to mimic tobacco.
Regulations like these can also have an adverse effect on village and cottage industries. Women’s self-help groups, small food manufacturers, and lakhs of indigenous food manufacturers and food startups across states whose livelihoods can be put at risk by such rules and potential taxes.
Ultimately, the need of the hour is capacity-building and education besides the pragmatism of food consumption patterns, weather, and tourism views that are equally essential to be considered; otherwise, our indigenous traditional Indian packaged food market will be completely entangled in the risk and predicament of being branded bad and heavily taxed.