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Allow consumers to correctly identify products containing excessive sugars, fats, sodium


Consumer organisations unanimously demanded for immediate notification of FoPL Regulations in the interest of public health. A note:
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In a bid to allow consumers to correctly, quickly, and easily identify products that contain excessive amount of sugars, fats, and sodium, consumer organisations across the country unanimously adopted an eight point Charter of Demands in the National Consumer Convention (CCC), held at Gandhi Peace Foundation, New Delhi on December 19, 2021. The Charter will be submitted to the Food Safety and Standards Authority of India (FSSAI).
National Consumer Convention was organised by Consumer Protection Association Agartala in partnership with Consumer Coordination Council (CCC) of India, an apex body of consumer organisations in the country. CUTS facilitated a session on FoPL. 30 Consumer organisations from 20 States attended th convention.
This charter highlighted immediate steps to be taken for the earliest notification of Front of Package Labelling (FoPL) regulation that has been long pending. It also specifically demanded to adopt simple, interpretive ‘high in’ style warning labels that has been established as the most reliable FoPL format that improves public health and aids all consumers regardless of their age, literacy proficiency or socio-economic strata to make healthier choices. It also highlights the need to reduce the risk for diet related non-communicable diseases, with a format based on nutrient profile model with scientific threshold limits and WHO SEARO Model.
George Cheriyan, Director, CUTS International, while making a presentation on FoPL during the National Consumer Convention, said that Right to Information and Right to Choose are fundamental consumer rights. FoPL is a tool which provide consumers information and alert about unhealthy ingredients, and help to choose healthy products. The regulators in India need to cautiously move forward but at a more rapid phase while choosing an ideal label for packaged food products for consumers in India. FSSAI have already spent number of years discussing and consulting stakeholders, it is high time to move fast without any further delay and come out with a strong regulation.
He further informed that most of the countries have started to reap the benefits from positive consumer behaviour since the implementation of the FoPL. It has helped those governments to save money from direct and indirect healthcare costs. At the same time, he acknowledged that no single action will change the consumer’s preference for unhealthy diets and the growing NCD crisis in the country, multiple actions needs to be taken by the government in close cooperation with the stakeholders. A regulation for a strong, simple, mandatory FoPL without any further delay is a must.
In India FoPL was first recommended in 2014 by an expert committee constituted by Food Safety and Standards Authority of India (FSSAI) in 2013. After years of consultations, in May 2018, FSSAI published a draft Food Safety and Standards (Labelling and Display) Regulations, 2018. In 2019, FSSAI issued draft notification Food Safety Standards (Labelling and Display), Regulations, 2019. In 2019 December, FSSAI delinked FoPL from general labelling regulations. Thus, the country is yet to bring in some regulation regarding FoPL, though some active discussions are happening over time.
The charter was presented during the inaugural session of the National Consumer Convention (CCC), held at Gandhi Peace Foundation, New Delhi on December 19, 2021 by George Cheriyan, Director, CUTS International and was released by Shri Prasanta Kumar Panda, Chairman, Consumer Coordination Council (CCC), an apex body of consumer organisations in the country in the presence of Amrit Lal Saha, President, Consumer Protection Association, and former president, CCC, Agartala (Tripura) and Chair Prof. Suresh Mishra, CCS, IIPA, New Delhi.
In the national convention around 100 representatives of 30 leading consumer organisations of the country across the states from Rajasthan, Tamilnadu, Tripura, Uttar Pradesh, Odissa, West Bengal, Delhi, Haryana and others participated.

What is FoPL?

According to the WHO definition, FoPL refers to nutrition labelling systems that:
  • Present on the front of food packages (in the principal field of vision) and can be applied across the packaged retail food supply;
  • Comprise an underpinning nutrient profile model that considers the overall nutrition quality of the product or the nutrients of concern for non-communicable diseases (NCDs) or both; and
  • Provide graphical information on the nutrient content or nutritional quality of products to complement the more detailed nutrient declarations usually given at the back of food packages.
A significant number of countries have implemented FoPL but in different formats to date. Besides, there is no global consensus on a particular type of FoPL.

Why do we Need a FoPL?

The purpose of FoPL is to alert consumers about unhealthy ingredients and allow consumers to correctly, quickly, and easily identify products that contain excessive amounts of sugar, fats, and sodium. This will also protect consumers from the top risk factors for mortality, i.e., high blood sugar levels, high blood pressure and overweight/obesity, harming people’s health and development. Addressing such a health crisis has become vital during the ongoing COVID-19 pandemic, and persons living with such NCDs are at greater risk of becoming severely ill or dying from COVID-19.

Which type of FoPL is ideal for Indian consumers?

Scientific evidence shows that octagon-shaped front-of-package nutritional warnings indicating if a product is “HIGH IN” on or more critical nutrients is the best performing system to allow consumers to correctly, quickly, and easily identify products with unhealthy nutritional profiles. Countries including Chile, Israel, Peru, Mexico, Brazil and Uruguay have adopted a warning label system and several more countries plan to adopt it in the coming months.

What are the Policy Interventions on FoPL in India?

In 2013, in India, an Expert Committee constituted by the Food Safety and Standards Authority of India (FSSAI) first recommended the FoPL in 2014. After years of consultations, the FSSAI published a draft Food Safety and Standards (Labelling and Display) Regulations in May 2018. It issued a draft notification on Food Safety Standards (Labelling and Display), Regulations in 2019. In December 2019, FSSAI delinked FoPL from general labelling regulations. Though some active discussions are underway, the country is yet to bring in some regulations regarding FoPL.

Why do Consumer Organisations in India Need to take a Common Stand on FoPL?

Across the globe, the Food and Beverage Industry strongly and extensively opposes such warning labelling regulations. Experience till now in India is quite similar. Companies in India, like most MNCs, prefer to opt for Guideline Daily Amount (GDA), which includes hard-tounderstand numbers that can easily mislead even a diligent consumer and does not support consumers in making health-conscious choices. Besides being based on portions, the smaller the portion, the healthier a product looks.

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