Disputes between food manufacturers, the packaging industry, and public health experts have intensified regarding the timelines for implementing mandatory nutritional labeling on the front of packaging (FOPNL) for packaged products high in sugar, salt, and fat, as the Supreme Court reviews this contentious issue.
The Food Safety and Standards Authority of India (FSSAI) proposed a unified FOPNL regime, under which packaged products exceeding established thresholds for any specified nutrient must carry a red hexagonal warning on the front of the package. These thresholds are proposed to be based on the Dietary Recommendations for Indians 2024, issued by the Indian Council of Medical Research – National Institute of Nutrition.
On September 28, the Bench of the Supreme Court, comprising Justices J. B. Pardival and Vinod Chandran, questioned the FSSAI's proposal for a voluntary compliance period of 365 days and demanded an explanation as to why a new round of stakeholder consultations was necessary, given that the issue had been under discussion since 2022.
Public Health Expert Opinion
Health expert Monica Arora, Vice President of Research and Health Promotion at the Public Health Foundation of India (PHFI), stated that the delay in implementing FOPNL since 2022 has postponed a crucial public health opportunity.
She emphasized that it is vital for pre-packaged foods to have clear and easily understandable warnings if they contain high amounts of sugar, salt, or fat, so that consumers can easily identify products that may pose a health risk. Arora also noted that protecting children and youth through such warning labels is a public health imperative that cannot be delayed, especially considering their vulnerability to persuasive marketing of unhealthy foods and beverages.
"Timely implementation of evidence-based labeling policy is a critical step towards creating a healthier food environment and preventing non-communicable diseases (NCDs)", she stated. The Parliamentary Committee also expressed concern over the delays in approving the FOPNL rules. The Committee noted that the draft FOPNL rules were initially notified in 2022, and over 14,000 comments were received from stakeholders. The FSSAI's proposal in 2022 envisioned a star system based on the Indian Nutrition Rating, which has since transformed into the warning sign system presented to the Supreme Court in 2026.
Concurrently, the parliamentary committee pointed out that "more than two years have passed since the draft was notified, and the ongoing delay in final approval of the rules has resulted in the absence of simplified and interpretable information on the front of the package, especially regarding sugar content." It added that "the lack of simple interpretive tools, such as warning signs or color indicators, limits the effectiveness of such disclosure in influencing consumer behavior."
What is FOPNL?
Nutritional labeling on the front of the package aims to provide simple, quickly viewable information about nutrients on packaged products. The main idea is to help consumers determine the food profile of the product and potential health consequences, enabling them to make more informed dietary decisions. The current FSSAI proposal mandates red hexagonal warnings for products exceeding established thresholds for nutrients such as sugar, salt, and fat. The regulator also proposed a separate warning for products containing non-caloric sweeteners.
What is the Position of the Packaged Food Industry?
While health experts insist on faster implementation, the packaged food industry calls for a longer transition period. The Indian Food and Beverage Association (IFBA) believes that a realistic starting point for compliance would be a two-to-three-year transition period from the date of final notification, depending on the final scope and complexity of the requirements.
Dipak Jolly, Chairman of IFBA, told Business Standard that such a timeframe would allow micro, small, and medium enterprises (MSMEs) and other food producers to assess their product portfolios, confirm nutrient classifications, rework packaging and labels, manage existing packaging inventory, and align production and supply chain operations. IFBA stressed that the goal should be time-bound implementation supported by a clearly defined and practical transition period.
Jolly also stated that "the proposed timeline must balance the urgency of providing consumer information with the operational realities of implementation, ensuring that compliance is effective, consistent, and scientifically sound, rather than merely rushed." Although the FSSAI labeling policy provides a minimum transition period of 365 days from notification for amendments to labeling requirements, unless otherwise decided in emergencies, some packaging industry representatives have stated that the financial impact of regulatory changes could ultimately be passed on to customers.
Timmayya Napanda, Managing Director and CEO of rigid plastic packaging company Alternicq, noted that "when rules change, the impact on existing packaging stock is usually manageable, as we typically do not hold large stocks of empty packaging. Non-compliant printed labels or packaging materials may require disposal, the cost of which we may pass on to our client if we procured them on their behalf."
Previously, the All India Food Processors Association (AIFPA) had stated that the proposed threshold values should be finalized after considering available scientific material aligned with international standards, data on food consumption in India, differences between product categories, and input from consumer organizations, public health experts, food scientists, MSMEs, traditional food producers, and industry stakeholders. However, Arora countered that the growing prevalence of overweight and obesity in India, coupled with the expansion of the packaged food and beverage retail market, demands faster implementation. She cited statistics: "Between NFHS-3 (2005–06) and NFHS-5 (2019–21), overweight or obesity among adults increased from approximately 9 percent to 23 percent in men and from 13 percent to 24 percent in women. Among children under five, the prevalence of overweight rose from 2.1 percent in NFHS-4 (2015–16) to 3.4 percent in NFHS-5."
