Published Aug 17, 2026 | 7:00 AM ⚊ Updated Aug 17, 2026 | 7:00 AM
Energy drinks are popular among adolescents and young adults, marketed to enhance energy levels and physical performance. (Creative Commons)
Synopsis: FSSAI’s 2026 front-of-pack labelling proposal has raised questions over an apparent shift from its 2021 position. Its earlier records favoured total sugars, citing difficulties in verifying added sugar, while the latest proposal uses added sugar. The petitioner has flagged the change, along with differences over serving size and labelling format.
The Food Safety and Standards Authority of India (FSSAI) appears to have changed its approach to measuring sugar for front-of-pack labelling, according to its latest proposal, which replaces the metric of total sugars suggested by its scientific members in 2021 with added sugar.
The shift has been highlighted before the Supreme Court by the NGO ‘3S and Our Health Society’, which challenged the proposed framework for front-of-pack labelling of packaged foods high in sugar, salt and saturated fat.
According to the minutes of an FSSAI stakeholders’ meeting held on June 30, 2021, the regulator’s scientific members had rejected “added sugar” as the preferred metric and favoured “total sugars.”
The minutes state that “energy calculations are based on total sugar and not added sugar” and also record that “added sugar cannot be analytically verified in a laboratory.”
Five years later, however, FSSAI’s compliance affidavit dated August 3, 2026 proposes displaying a daily recommended limit of 25 grams of added sugar, along with 10 grams for saturated fat and 5 grams for salt.
The apparent change raises a key question: what changed between FSSAI’s scientific deliberations in 2021 and its proposal in 2026?
The 2021 minutes are significant because they record the regulator’s own earlier reasoning on how sugar should be measured.
The document cited before the Supreme Court records the scientific members’ preference for total sugar. The reasoning was explicitly linked to energy calculations and the difficulty of determining added sugar analytically.
The petitioner has pointed to the contradiction between the FSSAI’s earlier appraoch to the matter and its current proposal, describing it as a “U-turn.”
The documents placed before the court do not explain why FSSAI changed its position. The scientific, regulatory or technological basis for the shift remains a question for the regulator to explain.
The distinction between total and added sugar is not merely technical when it is used to determine how consumers are warned about packaged foods.
Under FSSAI’s latest proposal, the consumer would see numerical information based on daily recommended limits, including 25 grams of added sugar. The petitioner has argued that numerical disclosure is fundamentally different from a warning label.
A consumer would have to look at the serving size, identify the amount of sugar in the product, compare it with the recommended daily limit and then determine whether the product contains excessive sugar.
The petitioner’s argument is that this defeats the purpose of front-of-pack warning labels, which are intended to provide an immediate and easily understood signal.
The petitioner has also pointed to another apparent difference between FSSAI’s 2021 deliberations and its current proposal: the basis on which nutritional information should be displayed.
The June 2021 minutes record that industry had proposed a per-serving basis.
FSSAI rejected that approach and adopted 100g/ml as the reference unit, stating that it “enables a rational comparison among products.”
The petitioner has argued that FSSAI’s current approach, which incorporates serving-size information, represents another departure from the position reflected in the 2021 record.
Also Read: ‘Are you succumbing to corporate pressure?’: Supreme Court raps FSSAI over food warning labels
The 2021 minutes also contain an assessment of the proposed format of nutritional labelling.
The document reportedly records that “there are no substantive studies to support effectiveness of monochrome GDA”, referring to the guideline daily amount-based approach.
The petitioner has argued that FSSAI’s current proposal nevertheless moves towards a numerical, GDA-style disclosure rather than a clear interpretive warning.
This distinction is at the heart of the larger dispute.
The Supreme Court had earlier asked the Union and FSSAI to consider warning-based front-of-pack labels, with examples such as “High Sodium Level”, “High Sugar Level” and “High Saturated Fat Level.”
The petitioner has argued that simply providing numbers does not tell a consumer immediately whether a product is high in a nutrient of public-health concern.
The petitioner has also cited evidence from within India to support the argument that warning labels are more effective.
A six-State randomised field experiment involving Indian consumers reportedly found that 60.8% of participants correctly identified products as high in a particular nutrient when shown a warning label.
The corresponding figure was 55% when participants were shown a numerical table and 45% when they were shown a star-rating system.
The petitioner has argued that these findings are particularly relevant in India, where consumers have varying levels of literacy and health literacy.
The argument is that a consumer should not have to perform calculations or interpret technical nutritional information to understand that a product contains high levels of sugar, salt or saturated fat.
The issue before the Supreme Court has therefore moved beyond the question of whether India should introduce front-of-pack warning labels.
The documents cited by the petitioner raise a more specific question about how FSSAI arrived at its present proposal.
Why did its scientific members in 2021 say “Total Sugars” was preferable because “added sugar cannot be analytically verified in a laboratory”, while its 2026 proposal uses added sugar?
Why did FSSAI in 2021 reject a per-serving reference and adopt 100g/ml, saying it “enables a rational comparison among products”, while its current proposal incorporates serving-size information?
And why did the 2021 minutes state that “there are no substantive studies to support effectiveness of monochrome GDA”, while the regulator is now proposing a numerical disclosure system?
That explanation to why FSSAI decided on taking a U-turn could now become crucial as the Centre considers its final position on front-of-pack labelling. The Supreme Court has already given the Union two weeks to place its final decision on record.
(Edited by Fayisa CA)
