Fiddling around food

Most of us do not usually prefer to make calculations while snacking or eating a sweet. Those who do watch their calorie intake, find it extremely difficult to read the small print of nutritional information mentioned on food or beverage packets.

According to the Food Safety and Standards (Packaging and Labelling) Regulations, 2011, every pre-packed processed food product sold in the country must be labelled with nutritional information.

This helps the consumer make an informed decision about what and how much to eat, which is crucial because the packaged food industry has been globally indicted for peddling ultra-processed foods that are high in fat, salt or sugar and low in fibre and other essential micronutrients.

These foods cause malnutrition and are strongly linked with obesity and diet-related non-communicable diseases, such as type-2 diabetes, hypertension, heart ailments and certain cancers, like that of the colon.

Manufacturers of packaged foods are quite inventive. They provide this crucial information in such cryptic language, tucked away on the back of the overly colourful packets that the consumer either fails to notice or comprehend.

Every time Medhavi Sharma, a food enthusiast in Jaipur, Rajasthan, visits a supermarket, she spends a considerable time trying to locate the nutritional information.

"I need an extra pair of lenses to read the small-sized text. Some products place the information as running text, instead of in a tabular format, which makes it a challenge to comprehend the complex facts."

For Unnati Kapoor, a 12-year-old student in Delhi, the challenge is different. "I never see salt mentioned on the chips packet I am fond of," she says, ignorant of the fact that most companies mention sodium as an alternate term for salt.

Yeshika Malik, a mother of a two-year-old in Delhi, says one needs to have a good understanding of nutrition science to be able to decipher the terminologies and numbers on food packets.

An expert committee set by FSSAI proposed a labelling system in 2014 that would have made the existing regulations robust. The committee recommended labelling of calories and some nutrients of concern on the front of the packs.

The WHO defines FoP labels 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 companies in other countries have acceded to the FoP labelling laws, they are unwilling to do so in India — a country experiencing a dietary shift, with people increasingly consuming more processed and ultra-processed foods.

All evidence shows that by influencing FSSAI, the said companies have not only delayed the implementation of FoP label but have also diluted labelling provision to the extent that it may no longer serve the purpose.

Collusion between food industry and the regulator

In 2015, FSSAI set up a second expert committee to assess the availability of foods high in fat, salt or sugar in the Indian market and to recommend on its regulatory limits and labelling and display requirements.

Two years later, the committee submitted its report, recommending to make nutritional information "easy" to understand and resolve "ambiguities" on the correct serving size of packaged and fast foods.

This left no scope for procrastination and in 2018, FSSAI released the draft Food Safety and Standards (Labelling and Display) Regulations, which for the first-time proposed FoP labelling for packaged food in India.

Despite some limitations in its design, the 2018 draft required food makers to place the information upfront — on the front of the pack —and highlight all the nutrients that exceed thresholds in red.

In August 2018, the then CEO of FSSAI said, "Industry does not want the food to be labelled red which represents danger." And the 2018 draft remained a draft.

Dilution of labelling standards

Within a few months, FSSAI announced a third committee, headed by B Sesikeran, former director of the National Institute of Nutrition.

The recommendations of the committee were never made public. But what followed was shocking. In July 2019, FSSAI released a much-diluted version of the 2018 draft for public comments.

The 2019 draft changed three of the five nutrients of concern that were proposed to be displayed on FoP label: It replaced 'salt' with 'sodium', 'total fat' with 'saturated fat' and 'total sugar' with 'added sugar'.

While changing total sugar to added sugar, FSSAI did not revise the recommended daily allowance (RDA) for sugar, which has been limited to 50 g in the 2018 draft. This meant a higher quota and relaxed limits for added sugar.

In December 2019, the Centre for Science and Environment found in its analysis that it was in the industry's interest that the 2019 draft prescribed the declaration of sodium on food packs, not salt — the ingredient that triggers hypertension.

Similarly, it was in the industry's interest to declare saturated fat instead of total fat. Packaged foods are high in fat but may or may not have high saturated fat.

While saturated fat is strongly linked to heart diseases which typically appear in adulthood, a diet high in total fat can cause obesity and associated health complications among children, who are the major target group of processed foods.

Remarkably, the industry was still not pleased with the diluted 2019 draft and continued to oppose the 'red' colour coding. That was around the time the Environment Monitoring Laboratory at CSE highlighted that most packaged foods and fast-food items popular in the country contain dangerously high levels of salt and total fat.

Still, the FSSAI went ahead to notify the 2019 draft by delinking the FoP label from it, and set up a fourth committee — this time a working group comprising members from the nutrition, medical and scientific communities — to specifically revise thresholds.

The working group proposed revised thresholds, which were shared with stakeholders for feedback in February. It is still uncertain if these thresholds would be accepted by FSSAI. Researchers at CSE have, however, found that the thresholds prepared by the working group gives preference to commercial interests of the packaged food industry over the consumers' right to know and public health.

Unprecedented levels of dilution

FSSAI called its sixth meeting on June 30, 2021. There was a clear attempt to make decisions, and some were taken. But FSSAI also brought some different criteria to the table as a surprise.

On the nutrients to be displayed on the FoP label, it was agreed that 'sodium' would be used for fixing thresholds and 'salt' could possibly be used on the FoP label. 'Saturated fats' were decided instead of 'total fat'.

It was also decided that 100 g or 100 ml will be used as a reference unit for thresholds and not the per serve size. 'Total sugars' would be considered instead of 'added sugar'.

CSE and some consumer groups had been pushing for these. However, there was another twist in the tale and this has many parts to it. First, FSSAI proposed to also consider 'positive nutrients' in the FoP label.

The industry, as expected, supported it. Most consumer organisations objected as 'positive nutrients' will mask the negative impact of high fat, salt and sugar in the food and the industry will use it to mislead the consumer.

Scientific members also emphasised that the purpose of FoP label is to inform consumers about negative nutrients. CSE was clear that as such, there were hardly any 'positive' nutrients in junk foods and even if some get added, it will not turn these bad foods into good foods.

This idea of 'positive nutrients' had clearly much more to it than depicting 'positive nutrients' in addition to negative nutrients. It had a bearing on both the design and thresholds.

Only a few FoP label designs include positive nutrients and these are called summary indicators suggesting summary of good and bad in a food. One is the 'Health Star' rating system (adopted in Australia and New Zealand) and the other is 'Nutri-score' system (adopted by France and Belgium).

It is not known to be consumer friendly. For example, it does not tell which negative nutrient is high and by how much. It is rather known to favour the industry.

Then, there is the second twist in the tale. FSSAI proposed to set thresholds for two broad categories — solids / liquids or foods / beverages — in addition to possibly a few other categories like dairy.

Reference was made to countries that use such broad categories and have 'Health Star' and 'Nutri-score' rating systems. Most industry members welcomed this proposal. This system was diametrically opposite of the threshold limit set for different products, something which the food industry has particularly agitated against since January.

The last twist in the tale was related to the design of the FoP label that India is to adopt. Some members of the industry suggested adopting the Guideline Daily Amounts (GDA) in monochrome, which is essentially the information on amount of energy and nutrients with percentages of daily reference intake exhausted on consumption as per serve size.

While most consumer groups maintained their view on the need for 'warning labels', FSSAI emphasised on the need for an India-specific study and decided to commission another survey — this would be to analyse major FoP labelling models with the objective to identify ease of understanding and behavioural change of Indian consumers on a national level.

Another study may help, but why did FSSAI not do it earlier? It was always clear that design is linked with thresholds and nutrients.

All these questions and confusions mark the end of the journey that started in 2014 to ensure that consumers in India should know about nutrients that make their food injurious to health. It was a journey of one-step forward and two-steps backwards.

What is clear is that the industry will keep doing what suits them. It's the regulator that has to take a strong action and show that it cares for citizens.

Warning labels are better

When compared, no other label system has shown the impact that is manifested among all population groups and across the education-level spectrum.

For instance, studies suggest that the GDA system is difficult and consumers did not use this system in making their food choices.

Even the 'traffic lights' format — once a big breakthrough in nutrition labelling — has been found to confuse consumers in cases where a product has both green and red colours.

'Health Star Rating' and 'Nutri-score' have also been found confusing. First, these provide an ordinal rating from 0.5 to 5 or A to E, and not a clear indication of healthy or unhealthy. Second, consumers think of stars as being more related to the product quality rather than healthiness.

Here are a few recommendations made by CSE to make India's FoP labelling robust.

Design to warn

The FoP label must have a warning and be simple to read and act upon, as its purpose is to inform consumers about the unhealthy nutrients in junk foods.

India definitely needs 'warning labels' on front-of-pack, but this must be a symbol-based label with no text and numbers. This is because:

✻Junk foods have high levels of unhealthy nutrients.

✻ Warning labels are easy to notice and understand.

✻ Warning labels are the global best practice now.

✻ Warning labels are best suited for India as they do not include numbers unlike many other FoP labels.

✻ FSSAI has experience of successfully implementing symbol-based FoP labels.

✻ It is important to note that the FoP label proposed in FSSAI's 2018 and 2019 drafts has too many numbers and duplicates information at the back of the pack.

✻ Summary indicators should not be considered.

Play up nutrients that harm

FoP labels must include information on nutrients that make food injurious to health. This should be distinct from the details on the back-of-pack. FoP labels should aim to inform the consumer, while the back-of-pack label serves the purpose of scientific compliance and enforcement.

Factors that need to be considered while designing FoP labels include the level of consumer awareness, larger message that shapes up overall dietary habits, evolving science, local context and effective space utilisation.

FoP labels should have information on 'total sugar' and not 'added sugar'. There is no analytical laboratory method to differentiate 'added sugar' from total sugar and quantify it.

The threshold for 'total sugar' should be based on a daily upper limit of no more than 50 g. This was proposed by FSSAI in its 2018 draft, but in 2019, the limit was used for 'added sugar', which is actually a subset of 'total sugar'.

The National Institute of Nutrition, Hyderabad, also suggests to cap 'added sugar' intake at 25-30 g. Most junk foods contain a much higher proportion of added sugar than intrinsic sugars.

'Salt' should be labelled on the front of the pack instead of 'sodium', which is already required at the back. 'Salt' will help the consumer, whereas 'sodium' will help the industry. Salt is better known than sodium. Moreover, the conversion is difficult.

This is the reason public health messages of health agencies are given in terms of salt. FSSAI also mentions namak (salt), not sodium, in its Aaj se thoda kum, the eat right movement.

Fix salt, sugar and fat

The thresholds for the quantity of salt, sugar, and fat in food have to be health-based and not designed for the convenience of industry.

The ultra-processed food industry is powerful and uses its substantial market share and influence to dilute the thresholds so that consumers can be nudged into consuming unhealthy products.

FSSAI in its 2018 draft had proposed thresholds that were appropriate and can be adopted. These are based on the WHO-South East Asia Region nutrient profiling model, aligned with the Indian dietary habits, population nutrient intake goals and according to the recommendations made by the Indian Council of Medical Research-National Institute of Nutrition, Hyderabad.

India needs to move ahead for protecting consumer health, particularly in times of COVID-19, when we have learnt that those with obesity and comorbidities like hypertension and diabetes are more likely to get severely ill from the disease. DTE

Views expressed are personal