Published Sep 16, 2026 | 6:16 PM ⚊ Updated Sep 16, 2026 | 6:16 PM
The FSSAI has proposed warnings such as “HIGH FAT”, “HIGH SUGAR”, “HIGH SALT” and “HIGHLY SWEETENED BEVERAGE”.
Synopsis: ICMR-NIN had urged FSSAI to strengthen its proposed front-of-pack warning system, saying even one nutrient crossing the threshold should trigger a red-hexagon warning. It also advised considering sugar, fat and energy thresholds together, using nutrient-specific warnings and ensuring any phased rollout is time-bound.
India’s top nutrition research institute has urged the Food Safety and Standards Authority of India (FSSAI) to strengthen its proposed front-of-pack warning system by ensuring that packaged foods receive a warning even if they are high in just one nutrient of concern, instead of waiting until they exceed thresholds for two or more nutrients.
In a letter dated September 3 and addressed to FSSAI Chief Executive Officer, Dr Bharati Kulkarni, Director of the Indian Council of Medical Research-National Institute of Nutrition (ICMR-NIN) said the institute broadly supported a simple and prominent warning system but raised four scientific concerns over the regulator’s proposed framework, including the use of nutrient thresholds, the two-nutrient trigger and the phased rollout. The Supreme Court also stepped in on September 10, seeking several clarifications while directing the FSSAI to answer 13 questions within 10 days. These centre around label design, exemptions, timelines, and nutrient thresholds.
The intervention is significant because FSSAI, in its compliance affidavit filed before the Supreme Court on August 28, proposed prominent red-coloured hexagonal warning labels carrying declarations such as “HIGH FAT”, “HIGH SUGAR” and “HIGH SALT”, but only for products high in two or more specified nutrients during the first phase. ICMR-NIN had recommended that a product crossing the threshold for even one nutrient should carry the warning.
The disagreement between the regulator, FSSAI, and the country’s premier nutrition institute, ICMR-NIN, could shape the final framework for front-of-pack nutrition labelling, which the SC has been closely monitoring as part of the ongoing public interest litigation on warning labels for packaged foods.
In her letter, Dr Bharati Kulkarni had said the thresholds prescribed under the Dietary Guidelines for Indians (DGI) 2024 should not be selectively adopted without considering the broader scientific framework on which they were developed.
Referring to FSSAI’s proposal to use thresholds for added sugar, added fat and salt, Kulkarni wrote that the DGI 2024 framework was developed by considering multiple nutritional parameters together.
“The thresholds provided in the DGI 2024 for identifying foods high in fat, sugar and salt were developed considering energy density along with added fat, added sugar and salt, and in the context of the recommended upper limits for total fat and total sugar.”
She pointed out that the DGI framework includes an energy threshold of 250 kcal per 100 grams for solid foods and 70 kcal per 100 ml for liquid foods, in addition to nutrient thresholds for added sugar, added fat and salt.
Kulkarni further said the scientific basis of the guidelines should not be reduced to isolated nutrient cut-offs.
“The added-fat and added-sugar cut-offs should ideally not be considered in isolation from the accompanying energy and total nutrient considerations.”
The recommendation assumes importance because FSSAI’s affidavit had stated that its proposed warning labels would rely on thresholds under the DGI 2024. NIN advised the regulator to consider the complete scientific framework underlying those guidelines rather than independently adopting selected nutrient values.
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The strongest recommendation in the letter concerns the threshold for displaying a warning label.
FSSAI’s August 28 proposal envisaged a Phase I rollout in which only products high in two or more nutrients, namely added sugar, added fat and salt, would receive a red hexagonal warning. Products high in only one nutrient would be brought under the warning system during a later Phase II.
ICMR-NIN advised against that approach.
“Warning should be triggered by an individual nutrient of concern.”
Kulkarni said NIN supports a warning system that is simple, prominent and easy for consumers to understand, but cautioned that requiring two nutrients to cross the threshold could allow several unhealthy products to avoid scrutiny.
“The proposed first-phase requirement that a product be high in two or more nutrients before receiving a warning may result in products substantially high in a single nutrient escaping consumer attention.”
She therefore recommended that the proposed red hexagon should appear whenever even one nutrient of concern exceeds the prescribed threshold.
Where multiple nutrients exceed their respective thresholds, Kulkarni said the corresponding warnings could simply appear together on the same package.
The recommendation directly challenged the scientific basis of FSSAI’s two-nutrient trigger and aligns with concerns raised by several public health groups that a product high in sugar alone, for instance, should not escape a warning merely because its fat and salt levels remain below the threshold.
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ICMR-NIN had also weighed in on FSSAI’s proposal to introduce warning labels in phases.
Kulkarni said phased implementation may be justified for operational reasons but warned against allowing the transition to remain open-ended.
“If phased implementation is considered necessary for operational reasons, a time-bound transition with higher thresholds than recommended by us in DGIs, which can be progressively lowered in phases to align with the thresholds, may also be considered.”
She said such an approach would provide food manufacturers sufficient opportunity for product reformulation while ensuring that implementation does not become indefinitely delayed.
“A time-bound transition… may be considered, allowing adequate opportunity for product reformulation while avoiding indefinite postponement.”
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While recommending changes to the trigger mechanism, ICMR-NIN endorsed the broader idea of interpretive warning labels and said nutrient-specific red hexagons would provide clearer information than a single overall HFSS declaration.
Kulkarni suggested that instead of one broad warning, consumers should immediately know whether the concern relates to sugar, fat or salt.
“Rather than relying on a single overall HFSS warning, consideration may be given to separate, prominent red-hexagonal warnings such as ‘HIGH SUGAR’, ‘HIGH FAT’ and ‘HIGH SALT’.”
According to the letter, such a system would help consumers identify the nutrient of concern without requiring them to interpret complex nutritional information or perform calculations based on the nutrition panel printed on the back of food packages.
Kulkarni said this recommendation was also consistent with findings from the ICMR-NIN national study on consumer perceptions of front-of-pack labelling.
“This would let consumers immediately know which nutrient is of concern and avoid requiring them to interpret or calculate information from the nutrition panel.”
The institute noted that simplified and interpretive formats, including warning labels and colour-coded systems, communicate nutrients of concern more directly than numerical information alone.
This is particularly relevant because the Supreme Court has repeatedly emphasised that front-of-pack labels should enable consumers to make informed purchasing decisions at the point of sale rather than requiring them to decode technical nutritional information.
(Edited by Fayisa CA)
