A Policy Proposal for Transparent, Standardised, and Consumer-Centric Food Labelling

Decision on FoPL Format

The warning-label approach is the stronger near-term regulatory direction as FSSAI has moved from its 2022 star-rating proposal and towards a red-hexagonal warning-label framework. The Supreme Court is pressing for a scientifically justified and clearly defined timeline for its implementation (Sinha, 2026; Supreme Court of India, 2026). Separately, warning labels are stronger on protection because they directly identify excessive levels of specific nutrients of concern, and are more difficult to manipulate than a composite star rating.

However, this paper argues that a strengthened Indian Nutrition Rating (INR) remains the better long-term instrument for India because in contrary to a threshold-based warning label, it is able to grade the nutritional quality of products across the full range. Although a warning label can identify products that cross a specified threshold, products below that threshold may remain unmarked even when their nutritional profiles differ substantially. A strengthened INR can distinguish these differences and reward incremental improvements in nutritional quality, creating an incentive for manufacturers to improve products even when those improvements do not immediately bring a product below a warning threshold (Sinha, 2026). Its principal weakness is the possibility that positive nutrients may disproportionately offset high levels of nutrients of concern. However, this can be addressed through scientifically justified thresholds and transparent scoring rules.

Abstract

The prevalence of diet-related non-communicable diseases, such as diabetes, obesity, hypertension, and cardiovascular disease, is rising in India. This public health issue is developing at the same time that packaged and highly processed foods are becoming widely available in both urban and rural markets.

Although packaged food labels already contain nutritional information, these labels are located on the back of the package and require consumers to be able to understand serving sizes, grams, nutritional tables, and suggested dietary values. Due to this, while nutritional information may exist in theory, it is not accessible to consumers who hope to make nutritionally informed decisions.

Front-of-pack labelling (FoPL) provides an opportunity to make nutritional information more visible, comprehensible, and usable. In 2022, the Food Safety and Standards Authority of India (FSSAI) proposed an Indian Nutrition Rating (INR) system that would rate packaged foods from half a star to five stars based on their nutritional profile, using nutrient values per 100 g or 100 ml. (FSSAI, 2022). Evidence from an Indian Institute of Management Ahmedabad study involving 20,564 respondents suggests that Health Star Rating-style labels are among the easiest FoPL formats for Indian consumers to identify and understand (Ghosh, Sanghvi, & Sahay, 2023). However, a system like this will only be able to protect and educate consumers if it is mandatory, scientifically grounded, and transparent.

Although FSSAI has subsequently moved towards a warning-label approach, this paper argues that a strengthened Indian Nutrition Rating should remain under consideration as a longer-term national FoPL option. The proposed framework includes ICMR-NIN-aligned nutrient thresholds which are standardised per 100 grams/mL evaluation, criteria which are transparent, restrictions on any misleading health claims, and a uniform label design. The INR should also limit how far positive nutrients can offset excessive sugar, sodium, and saturated fat. By adopting these measures, consumers can meaningfully use nutritional information to make informed decisions.

1. Introduction & Background

1.1 India’s Changing Food Environment

India's food environment has been undergoing a rapid transition with increased consumption of packaged foods, sweetened beverages, biscuits, chips, instant noodles, and other ultra-processed foods, which are heavily marketed and are widely accessible to lower-income individuals due to their appealing nature, convenience, and affordability.

This shift is occurring simultaneously with the increasing burden of diet-related diseases. The ICMR-INDIAB study estimated that in 2021, 101 million people in India had diabetes, with an additional 136 million living with prediabetes, making preventative nutrition policies an urgent public health priority (Anjana et al., 2023).

ICMR-NIN Dietary Guidelines advise Indians against consuming goods high in fat, salt, sugar, and ultra-processed foods, supporting that the issue is not one of individual choice but also of public health communication (ICMR-NIN, 2024).

1.2 The Information Gap

Although nutritional information is already available on packaged foods, consumers are required to interpret multiple nutrient values, serving sizes, and recommended dietary values. This creates an information gap between what manufacturers know about their products and what consumers can understand during purchasing decisions.

Front-of-Pack Labelling can address this gap by presenting simplified nutritional information on the front of packaged foods. Rather than requiring consumers to examine detailed nutrition tables, FoPL can provide a visible signal that can be interpreted quickly.

1.3 Standardised Reference Values Support Better Consumer Decisions

Although FSSAI requires nutrition information to be displayed per 100 g (or per 100 mL), labels also include manufacturer-defined serving sizes. Consumers often focus on the per-serving values, which may understate the amount of sugar, sodium, or saturated fat consumed if the declared serving is much smaller than what is typically eaten (FSSAI, 2020).

For this reason, any Front-of-Pack Labelling algorithm should be calculated using standardised per-100 g or per-100 mL values. The proposed INR already uses these reference amounts for its calculation, so the policy gap is not the INR algorithm itself using serving sizes. Instead, regulation should prevent manufacturers from using small serving sizes in front-of-pack marketing or other prominent nutritional claims to create misleading impressions about the amount consumed (FSSAI, 2022).

This would make products easier to compare and reduce opportunities for manipulation.

1.4 Health Halo Marketing Can Mislead Consumers

Many packaged foods use positive claims on the front of the package, such as “high in vitamin C,” “source of calcium,” “immunity booster,” or “made with real fruit.” These claims may be technically true, but they can create a health halo if the product is also high in sugar, sodium, or saturated fat.

This matters because consumers may focus on the positive claim and overlook the product’s less healthy aspects. FSSAI has already shown concern about clearer nutrition communication by approving a proposal to display total sugar, salt, and saturated fat in bold letters and larger font size on packaged food labels (FSSAI, 2024a).

A stronger FoPL system should ensure that positive marketing claims do not undermine accurate nutrition communication.

2. Current Front-of-Pack Labelling Landscape

2.1 What Is Front-of-Pack Labelling?

Front-of-Pack Labelling places nutritional information about packaged goods on the front of the packet. Its goal is to enable consumers to immediately comprehend nutritional quality without having to examine detailed information on the back of the packet. It can indicate to consumers which products contain excessive amounts of sugars, total fats, saturated fats, trans fats, and sodium.

FoPL can be in various forms. This includes using warning labels to identify products which are rich in sugar, salt, or saturated fat; traffic light systems to indicate the overall nutritional quality of the product; and Health Star Ratings to convey this overall quality with a summary score, typically represented by stars.

Figure 1. Different Front-of-Pack labelling systems that are being used or proposed globally. Each model has unique advantages and disadvantages and presents nutritional information differently. Understanding these approaches can help provide context for evaluating India's proposed Indian Nutrition Rating framework.

2.2 India’s Proposed Indian Nutrition Rating

The Indian Nutrition Rating (INR) was proposed by FSSAI in its 2022 draft Food Safety and Standards (Labelling & Display) Amendment Regulations and proposed a half-star to five-star rating based on the nutritional profile of packaged foods and also provided for voluntary compliance for 48 months from the date of final notification, followed by mandatory compliance (FSSAI, 2022). However, FSSAI has recently proposed to withdraw the 2022 star-rating draft and conduct further research before finalising a Front-of-Pack Nutrition Labelling mechanism (Sinha, 2026). The INR star-rating system is therefore not currently the active regulatory direction for FoPL in India.

The current regulatory direction has shifted towards Front-of-Pack Warning Labels as the FSSAI has proposed a red-hexagonal warning label for products high in specified nutrients of concern, with a phased approach under which the first phase would cover products which are high in at least two specified nutrients and Highly Sweetened Beverages, while a second phase would extend the approach to products that are high in any one of the specified nutrients (Supreme Court of India, 2026).

2.3 Evidence From Indian Consumer Research

The IIMA study is one of the most important sources on FoPL in India, testing five label formats on Indian test subjects: Health Star Rating, Nutri-Score, Warning Label, Multiple Traffic Lights, and Monochrome GDA. The study used 20,564 face-to-face respondents across major Indian states (Ghosh, Sanghvi, & Sahay, 2023).

The report found that Health Star Ratings and Warning Labels performed strongly overall, with Health Star Ratings performing especially well on ease of identification and understanding. The study also found that summary formats, including Health Star Ratings and Warning Labels, were able to influence purchase intentions compared with more informative formats such as Multiple Traffic Lights, monochrome GDA, and Nutri-Score (Ghosh, Sanghvi, & Sahay, 2023).

Figure 2. The overall performance ranking of five front-of-pack labelling (FoPL) formats tested among Indian consumers. A lower average rank indicates better overall performance. Source: Ghosh, Sanghvi, and Sahay (2023).

As shown in Figure 2, the five tested formats differed in their overall performance, demonstrating that the design of FoPL matters for consumer response.

Figure 3. The mean ease-of-identification and ease-of-understanding scores for five front-of-pack labelling formats among Indian consumers. Scores are averaged across chips and biscuits on a 1-7 scale. Source: Ghosh, Sanghvi, and Sahay (2023).

As shown in Figure 3, Health Star Ratings performed especially strongly on ease of identification and understanding.

This evidence indicates that FoPL can influence consumer behaviour in India, and that a Health Star Rating-style system has strong potential and further shows that the design of the label matters (Ghosh, Sanghvi, & Sahay, 2023).

Figure 4. Mean purchase intention for chips and biscuits under no-FoPL, Health Star Rating (HSR), and Warning Label conditions following a healthy-food prime. Purchase intention was measured on a 3-point scale. Source: Ghosh, Sanghvi, and Sahay (2023).

As shown in Figure 4, HSR and Warning Label FoPLs were associated with lower purchase intention for both chips and biscuits compared with the no-FoPL control under the healthy-food prime (Ghosh et al., 2023).

2.4 Evaluating INR Against Warning Labels

The choice between a summary star rating and a warning label is central to the effectiveness of India's FoPL framework.

The first test is simplicity. INR provides a single summary signal that allows consumers to compare products without interpreting several individual nutrient values. The IIMA study found that Health Star Ratings performed especially strongly on ease of identification and understanding. Warning Labels are also highly visible and understandable, but they communicate specific nutritional risks rather than an overall assessment (Ghosh, Sanghvi, & Sahay, 2023).

The second test is protection. Warning Labels have an advantage because they directly identify products that are high in specific nutrients of concern. A star rating can potentially present a high overall score even when a product contains excessive levels of a particular nutrient if positive nutrients contribute enough points to offset those negative points. This concern is relevant to evidence that nutrient-profiling systems can produce ratings that do not always align with food-based dietary recommendations (Lawrence et al., 2018).

The third test is resistance to manipulation. Warning Labels have a structural advantage because their triggering criteria can be based directly on thresholds for nutrients of concern. A star system requires a transparent algorithm and limits on positive-point offsets to prevent manufacturers from obtaining a favourable rating through the inclusion of nutrients that do not adequately compensate for excessive sugar, sodium, or saturated fat (FSSAI, 2022; Lawrence et al., 2018).

Therefore, Warning Labels perform more strongly on the protective and anti-manipulation tests, while INR performs more strongly on the simplicity and overall-comparison test. INR is recommended because its principal weakness can be addressed through algorithmic safeguards, while its simplicity and ability to communicate overall nutritional quality are valuable for consumers.

This choice should not be understood as evidence that warning labels are ineffective. The Supreme Court of India has specifically considered Front-of-Pack Warning Labels in 3S and Our Health Society v. Union of India, and recent proceedings have considered the scientific basis, thresholds, appearance, and implementation of FoPL (Supreme Court of India, 2026).

3. Policy Recommendations for Strengthening India's Front-of-Pack Labelling Framework

Through this evidence, we can evaluate that India should not just implement FoPL, but should design a system which is simple enough for consumers to understand, strong enough for public health, and difficult for industry to manipulate.

This white paper proposes six recommendations.

3.1 Revive a Strengthened National Indian Nutrition Rating

The Indian Nutrition Rating is not currently the active regulatory pathway for Front-of-Pack Labelling in India, as FSSAI has recently proposed to withdraw the 2022 star-rating draft and has moved towards a warning-label approach. However, this paper still recommends that FSSAI reconsider and revive the Indian Nutrition Rating as a longer-term national FoPL option, subject to substantial strengthening of its algorithm and safeguards (Sinha, 2026).

A revived INR should be mandatory rather than dependent on selective adoption by food businesses. Its design can do this by incorporating scientifically justified nutrient thresholds and limits on positive-nutrient offsets. Consistent requirements for label placement and presentation should additionally be implemented. The positive-point component should therefore be reviewed and strengthened instead of being treated as a feature which will require introduction, since the 2022 INR draft already incorporated limits on positive points (FSSAI, 2022). This would allow the system to retain and maintain the simplicity of a summary rating, while also addressing the principal concerns which are commonly associated with star-based systems.

A strengthened INR could also help differentiate products across the broader range of nutritional quality. This is unlike warning labels, which are designed primarily to identify products that cross specified thresholds, meaning that products below those thresholds may remain unmarked even when their nutritional profiles differ. A graded rating allows labels to distinguish these differences and create an incentive for incremental product improvement. This includes improvements that do not immediately bring a product below a warning threshold (Sinha, 2026).

Implementation should occur through the regulatory machinery established under the Food Safety and Standards Act, 2006, which provides the statutory framework for FSSAI and for regulating the manufacture, storage, distribution, sale, and import of food (Food Safety and Standards Act, 2006).

3.2 ICMR-NIN-Aligned Nutrient Thresholds

An implemented Indian Nutrition Rating system should be based on India-specific nutritional guidance.

ICMR-NIN’s 2024 Dietary Guidelines recommend restricting foods high in fat, salt, sugar, and ultra-processed foods, meaning that sugar, sodium, and saturated fat should receive strong weightage in the scoring system (ICMR-NIN, 2024).

A product should not receive a high rating simply because it contains added vitamins or minerals while also being high in sugar or salt. This is the central technical safeguard required for a star-based system.

The proposed INR already includes limits on the contribution of positive nutrients within its scoring framework. The policy recommendation should therefore be to review and strengthen these limits so that the presence of fibre, protein, fruits, vegetables, nuts, legumes, or millets improves a product's score only within defined limits and cannot effectively cancel out excessive levels of nutrients of concern (FSSAI, 2022).

Scientific credibility requires that the system reflects India’s dietary guidelines rather than industry-friendly scoring methods. The multidisciplinary expert committee proposed in this paper should review the existing positive-point caps and recommend scientifically justified limits using ICMR-NIN guidance.

3.3 Standardised Per-100 g and Per-100 mL Evaluation

The proposed INR algorithm already uses standardised per-100 g or per-100 mL reference amounts for its calculation. Therefore, the policy recommendation should focus on ensuring that manufacturers do not use smaller serving sizes in prominent front-of-pack marketing or other consumer-facing nutritional information to create misleading comparisons (FSSAI, 2022).

Per-100 g and per-100 mL values allow products to be compared using the same reference amount. This approach also improves regulatory enforcement, as a fixed reference amount makes it easier for regulators, researchers, and consumers to compare products objectively.

3.4 Restrictions on Misleading Health Claims

Products with poor nutritional profiles should not be allowed to display claims which create a misleading impression of healthfulness. For example, a high-sugar drink should not be marketed mainly as an “immunity booster” due to the addition of vitamins and minerals.

This recommendation does not ban all nutrition claims. Instead, it ensures that claims are contextual and do not contradict the product’s overall nutritional quality. This would reduce health halo effects and improve consumer protection against false claims.

FSSAI already regulates food advertising and health claims through the Food Safety and Standards (Advertising and Claims) Regulations, 2018. These regulations require health claims to have scientific substantiation and place conditions on claims relating to healthy diets. The remaining policy gap is ensuring that individual positive claims are not considered in isolation from the product's overall nutritional profile (FSSAI, 2018).

3.5 Standardised Design and Placement

The Indian Nutrition Rating should appear in a fixed position on the package with consistent size, colour, and design. The FSSAI draft already requires the Indian Nutrition Rating logo to be displayed near the product or brand name on the front of the package (FSSAI, 2022).

This should be strengthened into a clear design standard. If companies can alter the label’s size, placement, or visibility, the system may lose effectiveness as standardisation builds familiarity and trust with consumers.

The design should also be sufficiently prominent to remain comprehensible across different literacy levels and purchasing environments. This is particularly important given the Supreme Court's current consideration of the visual appearance and comprehensibility of FoPL (Supreme Court of India, 2026).

3.6 Transparent Algorithm and Periodic Review

The star rating algorithm should be publicly available and reviewed by independent experts. This matters because a rating system affects consumer trust and the behaviour of manufacturers.

The algorithm should clearly state the contribution of nutrients of concern and positive nutrients, including the maximum extent to which positive nutrients can offset negative points.

Periodic reviews should be implemented to allow the system to evolve as nutrition science changes, and to allow policymakers to evaluate whether the system is improving consumer understanding, changing purchasing behaviour, and encouraging healthier reformulation.

4. Expected Policy Impact

A strengthened FoPL framework would not solve India’s nutrition crisis alone. However, it could become an important component of preventive public health policy.

First, it would improve consumer understanding by translating complex nutrition data into a visible and simple rating. Second, it would reduce information asymmetry between food companies and consumers. Manufacturers understand the nutritional profile of their products, but consumers often do not. FoPL helps close this gap.

Third, it could encourage reformulation. If products with high sugar, sodium, or saturated fat receive lower ratings, companies may have an incentive to improve their formulations. Fourth, clearer labels could support healthier purchasing decisions, especially among consumers who do not regularly read back-of-pack nutrition tables.

The IIMA finding that summary FoPL formats, particularly Health Star Ratings and Warning Labels, can influence purchase intentions suggests that front-of-pack information can influence consumer behaviour in India (Ghosh, Sanghvi, & Sahay, 2023).

5. Implementation Challenges

A strengthened FoPL system will face challenges. Food companies may oppose mandatory labelling due to concerns about compliance costs, reformulation pressure, or reduced sales for lower-rated products. However, public health regulation often requires balancing commercial concerns with consumer protection.

Consumer education will also be necessary. Even a simple star rating requires public understanding. FSSAI and public health organisations should run awareness campaigns explaining what the rating means and how consumers can use it.

Enforcement is another major challenge. A mandatory system requires monitoring, audits, and penalties for non-compliance. Without enforcement, labels may become inconsistent or unreliable.

Implementation can build on the existing enforcement machinery of the Food Safety and Standards Act, 2006, including licensing, Food Safety Officers, inspection, sampling, testing, and enforcement procedures. FSSAI already operates a national regulatory and enforcement structure, meaning that FoPL enforcement can be integrated into existing food-safety systems rather than requiring an entirely separate regulatory institution (Food Safety and Standards Act, 2006).

Funding should similarly be anchored within FSSAI's existing regulatory budget and annual planning processes. FSSAI's published budget data demonstrates that the Authority already operates with substantial annual allocations for its regulatory functions. Additional FoPL-specific costs should therefore be identified within its implementation budget for consumer education, monitoring, laboratory verification, and enforcement (FSSAI, 2024).

These challenges are manageable, but they show that FoPL must be implemented as a full regulatory framework, not merely as a packaging symbol.

6. Conclusion

India’s nutrition labelling challenge is not simply that consumers lack information. The deeper issue is that existing information is often difficult to access, interpret, and use during real purchasing decisions.

As packaged foods become more common and diet-related diseases continue to rise, India needs a labelling system that communicates nutrition clearly and reliably.

A mandatory Indian Nutrition Rating-based FoPL framework offers a promising path forward, especially because Indian evidence suggests that consumers can identify and understand star-based labels. However, the system must be strengthened through scientific thresholds, limits on positive nutrient offsets, standardised evaluation, restrictions on misleading claims, transparent scoring, and consistent design.

Warning Labels provide a stronger signal for specific nutritional risks and are harder to manipulate, but INR provides a stronger overall summary signal and performs particularly well on ease of identification and understanding. A strengthened INR can therefore combine the simplicity of a summary rating with safeguards addressing the principal weaknesses of star-based systems.

The goal of FoPL is not to remove consumer choice. Its purpose is to make choice more informed.

Strengthening India’s FoPL framework is therefore not just a labelling reform. It is a consumer protection measure, a public health strategy, and a step toward more transparent food environments.

7. Call to Action

FSSAI should establish a multidisciplinary expert committee to strengthen India’s Front-of-Pack Labelling framework before nationwide implementation. This committee should include nutrition scientists, public health experts, consumer protection specialists, behavioural scientists, and civil society representatives.

Its mandate should be to finalise a mandatory, transparent, and scientifically grounded Indian Nutrition Rating system that improves consumer understanding while reducing opportunities for industry manipulation.

The committee should specifically evaluate the INR algorithm against the three criteria of simplicity, protection, and resistance to manipulation; establish scientifically justified nutrient thresholds using ICMR-NIN guidance; review and strengthen the existing limits on positive nutrient offsets; define standardised design and placement requirements; and establish mechanisms for monitoring and periodic review.

A stronger FoPL framework can help India move beyond simply displaying nutrition information toward ensuring that consumers can actually use it.

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