Jul 3, 2019

Summary of FSSAI New Draft Regulations for Food Safety and Standards(Labelling and Display)

The much-awaited document is finally here. I went through the English version (starting Page 40) in detail. Glad to read through many of these proposed regulations but my only concern is the timing - WHEN will these be enforced. And also hoping that packaged foods industry leaders don't intervene and "adjust" the thresholds defined as per their convenience.

The part that I'm most interested in is the FRONT label highlighting the nutrition values of added sugar, sodium, saturated fats and trans-fats and the thresholds for color coding high values in RED.

Source: FSSAI Food Safety and Standards (Labeling and Display) Draft Notification

 Though the threshold values seem tight enough, brands are given three years to MARK them as RED in a phased manner if they exceed the thresholds specified

    1. For current year after these regulations come into force - only labeling in the front of the pack, NO color coding
    2. After the 1st year, threshold values + 30% of threshold values are allowed
    3. After the 2nd year, threshold values + 15% of threshold values are allowed 
    4. After the 3rd year, threshold values
High Sugar:
To explain this in simple terms, Let's take the example of Bournvita biscuits
Threshold value specified => For added sugar,  in case the value of energy (kcal) from added sugar is more than 10 percent of the total energy (kcal) provided by the 100 g/100 ml of the product

100 gm of these biscuits contain 30 gm of sugar and provide 457 kCal of energy.
30 gm of sugar contribute 120 kCal (1gm of sugar = 4 kCal)
So the value of energy from added sugar is 26.2%, which is way above the 10% threshold.

For the current year, it won't be marked as RED
After 1st year, the criteria is 10% + 30% of 10% = 13%
Since the sugar level exceeds 13%, starting from 2nd year onwards, these biscuits should show the sugar value in RED.

High Sodium:
Based on Schedule I, I looked at the nutrition thresholds defined for sodium for a few categories
1. Processed cheese - 0.6 gm of sodium per 100 gm of product
Britannia cheese slice contains  1426 mg (1.426 gm) per 100 gm. So this would be color coded RED.
2. Ready to eat breakfast cereals - 0.35 gm of sodium per 100 gm of product
Saffola Masala oats pack doesn't even list sodium in the nutrition facts table, although salt is the third ingredient.
3. Noodles and pasta - 0.25 gm of sodium per 100 gm of product
With this threshold, our nation's beloved(?) Maggi noodles will be color coded RED (100 gm of Maggi contains 1232 mg or 1.232 gm of sodium, way above the 0.25 gm threshold)
4. Ready-to-eat soups - 0.35 gm of sodium per 100 gm of product
100 gm of Knorr vegetable soup contains 4938 mg or 4.938 gm of sodium, way above the 0.35 gm threshold.
Other important points that caught my attention:

1. E-Commerce labeling

When a food product is sold through e-commerce or any other direct selling means, the mandatory requirements of the label as given in these regulations shall be provided to the consumer through appropriate means before sale.

This is such an important regulation if and when it comes into effect. Most e-commerce players neither list the complete ingredients list nor show the screenshots of ingredients and nutrition facts from the packaging. Given that most grocery purchases are shifting online in urban areas, it is imperative that this rule is enforced strictly.

2. Specific names to be printed

In cases where edible vegetable oil or edible vegetable fat is used, the exact names need to be printed on the label (groundnut oil, mustard oil etc)

3. Declare the quantitative value present IF an ingredient is highlighted in the label

Every package of food sold as a mixture or combination shall disclose the percentage of the ingredient (including compound ingredients or categories of ingredients) used at the time of the manufacture of the food, if such ingredient– (i)is emphasized as present on the label through words or pictures or graphics; or (ii)is not within the name of the food but, is essential to characterize the food and is expected to be present in the food by consumers, if the omission of the quantitative ingredient declaration will mislead or deceive the consumer.

This is so required these days, given the predominant marketing of superfoods and other perceived "health" foods. For eg, the label says "potato crisps made with olive oil" but the percentage of olive oil used is not mentioned.

4. Nutritional information table will now contain sodium (mg). McCain Frozen snacks, kindly note this point.

5. Declare omega-3 and omega-6 fatty acids content on the label

every package of edible oils, interesterified vegetable fat, both hydrogenated or partially hydrogenated oils, edible fats, margarine and fat spreads (mixed fat spread and vegetable fat spread) shall declare the quantity of monounsaturated fatty, polyunsaturated fatty acid, omega-3 fatty acid and omega-6 fatty acid content on the label.

All packaged oils that proudly talk about omega-3 in their marketing promos, they will now need to list the exact values.

6. Allowance for variations is +/- 10% on the nutrition values on the label

7. Vegetarian food will have the following identification mark

The symbol shall consist of a green colour filled triangle inside a square with green outline

8. Names of flavoring agents need to be declared

In case of artificial flavoring substances the common name of the flavor shall be declared;

In case of natural flavoring substances or nature identical substances the class name of flavors shall be declared.

9. “Date of manufacture or packaging” and “Expiry /Use by” shall be grouped together and given at one place.

10. Front labeling guidelines

  The front of the pack should contain the nutrition values of total calories, added sugar, saturated fat, transfat and sodium. Per serve contribution of energy, saturated fat, trans fat, added sugar and sodium to RDA as per format indicated

11. Any beverage provides energy less than 80 Kcal/ per serve is exempted from colour coding.

12. HFSS food products shall not be advertised to children in any form
There was just this single statement, but no details mentioned.

13. Food Service Establishments having Central license or outlets at 10 or more locations shall mention the calorific value against the food items displayed on the menu cards or boards.
We would now get to know the calorie value of that Dominos Pizza or the McDonalds burger.

14. The package, label or the advertisement of edible refined vegetable oils and fats shall not use any exaggerated expressions like “Super-Refined”, “Extra-Refined”, “Micro-Refined”, “Double refined,”, Ultra-Refined”.

Do take a look at the complete document as there is more coverage than what I have highlighted here.

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