The FSSAI released a notification for new display and labeling regulations for processed foods, beverages and consumer foods in November 2020, which will be effective from 1 January 2022. The regulations clearly mention the need for overhauling current labeling practices while introducing significant new reforms which would impact the industry on several levels. Some of the key highlights and reforms are emphasized below in order of their impact on the industry:

High Moderate to low
  • Usage of 'use by', 'expiry date' instead of 'best before' date
  • Age category defined as per Juvenile Justice Act
  • Nutritional information to be displayed in bigger font on primary panel
  • Labeling restrictions on foods claiming clinical and medicinal properties
  • Food establishments with central license or more than 10 outlets have to mention calories and calorific value (in kilocalories per serving size)
  • All e-commerce players need to provide information before the orders are placed
  • Tolerance of nutritional information changed to negative 10%
  • Food allergen warning mandatory for additives which can cause allergy
  • Foods high in sugar percentage need to be clearly demarcated
  • Number of serving sizes to be included in nutritional information
  • Bifurcation for fortification and symbols for organic foods
  • Strict guidelines on exaggerated usage of expressions for labeling of edible oils and fats
  • Segregation in symbols for non-vegetarian and vegetarian foods
  • Demarcation for non-consumable processed foods such as diyas, cow ghee, etc.
  • List of ingredients have to be listed in descending order of constituents

Our Comments

The changes bracketed under the 'high' column are expected to have the maximum impact on the industry in terms of revamping packaging, redefining shelf-life, and integration of supply chain to identify and rebrand such products. Additionally, brands will have to realign their marketing and communication strategy, including recalling and repackaging the foods beyond the expiry of January 2022. Claims have to be verified by FSSAI before being labeled, ensuring a collective rethink of core product strategies and communication. For e-commerce players, high IT costs will have to be borne with the onus of customer education on such players. Restaurants and establishments with more than ten outlets or a central license will have to revamp menus, boards, and digitally facelift items for accommodating changes at such a large magnitude. There has been fortification for organic foods, which will give impetus to that market and see a growth in consumption of organic foods. Moreover, no ambiguity is allowed in the expression for labeling of edible oils and fats.

It is evident from the above-mentioned regulatory changes that the food processing industry is moving in the direction of cleaner and greener foods. The government will continue to push for these changes until they are adopted and standardized across the entire industry. With the rise of non-communicable diseases, changing lifestyle patterns, and many other incidences of consumption-related diseases, the government is aiming to make consumer demand more health-friendly via such methods. The industry is expected to objectively consolidate such regulatory changes, which will result in a domino effect as participants from both the organized and unorganized market will have to comply on a large scale under such laws or risk being penalized for non-compliance.

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