HFSS Food Labelling: Towards Healthier Food Choices

Context
The Food Safety and Standards Authority of India (FSSAI) is moving towards defining foods high in fat, sugar and salt (HFSS) and introducing prominent Front-of-Pack Labelling (FOPL). The objective is to help consumers, especially children, identify foods that should be consumed less frequently.

Why Regulation is Needed?

• Excessive intake of fat, sugar and salt contributes to obesity and non-communicable diseases (NCDs).
• Ultra-processed foods (UPFs) often contain refined carbohydrates, fats, salt, sweeteners and additives that can increase their palatability and encourage overconsumption.
• However, HFSS and UPF are not synonymous.
• A traditional samosa may be high in fat but not necessarily ultra-processed, while some breakfast cereals may be ultra-processed yet relatively low in fat, sugar and salt.

FSSAI's Proposed Approach

• Proposed HFSS thresholds for solid foods include more than:
• 4.2 g added fat/100 g
• 3 g added sugar/100 g
• 0.625 g salt/100 g
• Phase 1: warning labels for foods exceeding two or more nutrient thresholds.
• Phase 2: proposed extension to foods exceeding even one threshold.
• Restriction of HFSS food availability within 50 metres of schools is also proposed.

Key Concerns

• A two-nutrient threshold could allow products extremely high in only sugar or salt to escape warnings.
• Regulation should apply on the basis of nutritional characteristics rather than whether food is manufactured by a large company, MSME, restaurant, street vendor or household.
• Excessive regulation of traditional foods could unintentionally affect livelihoods and India's diverse food culture.

Way Forward

• Base thresholds on ICMR-NIN's Dietary Guidelines for Indians, 2024.
• Apply FOPL warnings when even one nutrient of concern exceeds the prescribed threshold.
• Adopt a phased reduction in thresholds to give manufacturers time for reformulation.
• Develop a dual-axis framework combining:
• Nutrient composition → HFSS
• Degree of processing → UPF
• Use simple warning labels and colour-coded systems rather than complex numerical information.
• Complement labelling with public awareness and periodically evaluate its impact on consumer behaviour and product reformulation.

Conclusion
India needs a nutrition policy that protects public health without unnecessarily undermining traditional food culture or livelihoods. A scientifically grounded HFSS definition, clear FOPL warnings and a future framework integrating both nutritional composition and food processing can make food regulation more effective and consumer-friendly