This comprehensive document, recently forwarded to Counterview by Dr. Arun Gupta—a prominent public policy expert who serves as the founder of BPNI, convenor of Nutrition Advocacy for Public Interest (NAPi), and former member of the Prime Minister’s Council on India’s Nutrition Challenges—advocates for a radical shift in how the nation regulates food labeling.
The authors emphasize that the current epidemic is largely driven by the rising consumption of unhealthy diets containing ultra-processed foods (UPFs) and high-fat, sugar, and salt (HFSS) products, fueled by aggressive advertising and misleading labels that often mask the true nutritional profile of products.
Central to their argument is the recommendation that India should abandon the proposed Indian Nutrition Rating (INR), a star-based system adopted from Health Star Rating (HSR), in favor of mandatory front-of-pack nutrition warning labels (WLs). The experts argue that star ratings are fundamentally flawed because they provide weightage to the addition of "positive" nutrients like fruit, vegetables, or nuts, which can mask the negative effects of nutrients of concern like salt or sugar, creating a "health halo" that leads to overconsumption and misleads consumers.
Evidence presented in the study indicates that while consumers may spend as little as ten seconds selecting a food item, simple and clear warning labels—such as those used in Chile, Mexico, and Israel—are significantly more effective than star ratings at altering health perceptions and prompting cautious behavior to reduce the purchase of unhealthy products.
The consensus statement highlights alarming statistics, noting that more than half of Indian children and adolescents between ages 5 and 19 already show biomarkers of NCDs.
Dr. Gupta and his colleagues point to recent data from the Indian Council of Medical Research (ICMR) showing that the prevalence of diabetes in India has reached 11.4%, with hypertension affecting 35.5% of the population, or one in three individuals. They assert that every 10% increase in the contribution of ultra-processed foods to total energy intake corresponds with a 2.7% rise in the risk of all-cause mortality.
The authors further explain that ultra-processing itself may be detrimental to health independent of nutrient content, making clear labeling a matter of human rights and a vital public health intervention. They call for the replacement of the proposed star system with bold, interpretive warning symbols that identify specific nutrients of concern, such as "High in Sugar," "High in Fat," or "High in Sodium," which have been shown to disrupt habitual shopping decisions even when consumers are not actively seeking nutritional information.
Israeli Perspective
The authors further explain that ultra-processing itself may be detrimental to health independent of nutrient content, making clear labeling a matter of human rights and a vital public health intervention. They call for the replacement of the proposed star system with bold, interpretive warning symbols that identify specific nutrients of concern, such as "High in Sugar," "High in Fat," or "High in Sodium," which have been shown to disrupt habitual shopping decisions even when consumers are not actively seeking nutritional information.
Israeli Perspective
Complementing this perspective is a second study led by Michal Gillon-Keren and Ronit Endevelt, also forwarded to Counterview by Dr. Gupta, which details the implementation of a unique labeling system in Israel that utilizes both mandatory red warning labels and voluntary green positive labels. The Israeli researchers argue that a dual-color system is essential because the mere absence of a warning label does not necessarily imply that a product is healthy.
Their study describes a science-based approach where positive labels are reserved exclusively for foods that are in their natural form, undergo minimal processing, and align with the principles of the Mediterranean diet, such as fresh fruits, vegetables, whole grains, and legumes. Gillon-Keren and her team found that by setting strict criteria that exclude ultra-processed items from receiving positive endorsements—even those without warning labels—they could provide reliable information that prevents the "positivity bias" or "health halo" often associated with industry-led labeling schemes.
The Israeli case study emphasizes that successful labeling must be determined by an independent scientific committee without food industry influence to maintain public trust and effectively tackle the obesity epidemic, which in Israel affects 58% of the adult population. Both studies suggest that the most effective way to empower consumers is through interpretive systems that provide evaluative judgments about the healthfulness of a product at the point of purchase.
The Indian consensus statement also addresses the legislative and economic hurdles to reform, noting that the Food Safety and Standards Authority of India (FSSAI) has previously proposed exceptionally long transition periods of four years and star ratings that may not achieve the intended objective of reducing HFSS food consumption. Dr. Gupta and the co-signatories express concern that trade agreements, such as the recently concluded India-UK Free Trade Agreement (FTA), could risk flooding the market with cheap, unhealthy products like chocolates and soft drinks due to reduced tariffs.
They argue that the Supreme Court of India has upheld the right to health, nutrition, and information as part of the fundamental right to life under Article 21, and that labeling must be viewed as a public health intervention rather than a marketing tool. The experts recommend that thresholds for labeling should be based on the World Health Organization’s Southeast Asia Region (SEARO) Nutrition Profile Model or the ICMR-NIN Dietary Guidelines for Indians 2024.
They also emphasize that positive nutrients should not be weighted to offset negative ones in FOPNL. By citing global success stories like Chile, where sugary beverage consumption decreased by 24% after implementing warning labels and marketing restrictions, the authors present a unified call for India to take decisive action to protect its citizens from the growing burden of diet-related diseases.
Further expanding on the technical necessity of these labels, the authors of the Indian study highlight that misleading titles like "Real Fruit Juice" or "Fresh tomato ketchup" are increasingly used as trademarks, further confusing the public. This is particularly dangerous in an environment where the Indian Academy of Pediatrics has coined the term "JUNCS" foods to describe the wide array of junk, ultra-processed, and nutritionally inappropriate products currently available. The shift towards these foods is seen as a key driver of rising obesity, a concern recently echoed by the Prime Minister of India.
The experts argue that the government should lead a comprehensive public campaign through health systems to educate the population on identifying these risks. The consensus, endorsed by twenty-nine national organizations, serves as an unprecedented opportunity for the Government of India to implement clear warning labels that provide Indian citizens with the same level of protection as those in countries like Canada, Mexico, and the UK.
In the Israeli context, the development of the "green" label was intentionally designed to support the sustainable dimensions of the Mediterranean diet—health, environment, economy, and society. The Israeli Scientific Committee faced significant dilemmas regarding food additives, ultimately deciding to profile foods according to processing levels rather than just nutrient composition. For instance, while plain yogurt is eligible for a positive label, yogurts with sweeteners are not, regardless of their fat content. This approach addresses the fact that the number of nutrients in a product does not always reflect its level of processing or the presence of potentially harmful additives.
The researchers found that roughly 19.8% of food products in Israel were eligible for the positive label, with the majority being fruits and vegetables, dairy, and grains. By allowing the labeling of unpackaged foods like loose fruits and vegetables in supermarkets, the Israeli model ensures that fresh produce is not disadvantaged compared to packaged goods. This holistic approach to the food environment aims to reduce direct and indirect costs associated with obesity, which are estimated at US $173 million per year in Israel alone.
Scientific Evidence
Their study describes a science-based approach where positive labels are reserved exclusively for foods that are in their natural form, undergo minimal processing, and align with the principles of the Mediterranean diet, such as fresh fruits, vegetables, whole grains, and legumes. Gillon-Keren and her team found that by setting strict criteria that exclude ultra-processed items from receiving positive endorsements—even those without warning labels—they could provide reliable information that prevents the "positivity bias" or "health halo" often associated with industry-led labeling schemes.
The Israeli case study emphasizes that successful labeling must be determined by an independent scientific committee without food industry influence to maintain public trust and effectively tackle the obesity epidemic, which in Israel affects 58% of the adult population. Both studies suggest that the most effective way to empower consumers is through interpretive systems that provide evaluative judgments about the healthfulness of a product at the point of purchase.
The Indian consensus statement also addresses the legislative and economic hurdles to reform, noting that the Food Safety and Standards Authority of India (FSSAI) has previously proposed exceptionally long transition periods of four years and star ratings that may not achieve the intended objective of reducing HFSS food consumption. Dr. Gupta and the co-signatories express concern that trade agreements, such as the recently concluded India-UK Free Trade Agreement (FTA), could risk flooding the market with cheap, unhealthy products like chocolates and soft drinks due to reduced tariffs.
They argue that the Supreme Court of India has upheld the right to health, nutrition, and information as part of the fundamental right to life under Article 21, and that labeling must be viewed as a public health intervention rather than a marketing tool. The experts recommend that thresholds for labeling should be based on the World Health Organization’s Southeast Asia Region (SEARO) Nutrition Profile Model or the ICMR-NIN Dietary Guidelines for Indians 2024.
They also emphasize that positive nutrients should not be weighted to offset negative ones in FOPNL. By citing global success stories like Chile, where sugary beverage consumption decreased by 24% after implementing warning labels and marketing restrictions, the authors present a unified call for India to take decisive action to protect its citizens from the growing burden of diet-related diseases.
Further expanding on the technical necessity of these labels, the authors of the Indian study highlight that misleading titles like "Real Fruit Juice" or "Fresh tomato ketchup" are increasingly used as trademarks, further confusing the public. This is particularly dangerous in an environment where the Indian Academy of Pediatrics has coined the term "JUNCS" foods to describe the wide array of junk, ultra-processed, and nutritionally inappropriate products currently available. The shift towards these foods is seen as a key driver of rising obesity, a concern recently echoed by the Prime Minister of India.
The experts argue that the government should lead a comprehensive public campaign through health systems to educate the population on identifying these risks. The consensus, endorsed by twenty-nine national organizations, serves as an unprecedented opportunity for the Government of India to implement clear warning labels that provide Indian citizens with the same level of protection as those in countries like Canada, Mexico, and the UK.
In the Israeli context, the development of the "green" label was intentionally designed to support the sustainable dimensions of the Mediterranean diet—health, environment, economy, and society. The Israeli Scientific Committee faced significant dilemmas regarding food additives, ultimately deciding to profile foods according to processing levels rather than just nutrient composition. For instance, while plain yogurt is eligible for a positive label, yogurts with sweeteners are not, regardless of their fat content. This approach addresses the fact that the number of nutrients in a product does not always reflect its level of processing or the presence of potentially harmful additives.
The researchers found that roughly 19.8% of food products in Israel were eligible for the positive label, with the majority being fruits and vegetables, dairy, and grains. By allowing the labeling of unpackaged foods like loose fruits and vegetables in supermarkets, the Israeli model ensures that fresh produce is not disadvantaged compared to packaged goods. This holistic approach to the food environment aims to reduce direct and indirect costs associated with obesity, which are estimated at US $173 million per year in Israel alone.
Scientific Evidence
Ultimately, both sets of researchers arrive at the same conclusion: public health policy must be guided by overwhelming scientific evidence rather than industry interests. The Indian consensus statement concludes that the amendment of the 2022 Food Safety and Standards Regulations to include "warning labels" in symbols or "high in" text is an immediate necessity to curtail NCDs.
Similarly, the Israeli study advocates for a mandatory approach if voluntary use of positive labels does not gain sufficient industry traction. As Dr. Gupta and his colleagues note, the current absence of clear information on food packets leaves consumers unaware of what they are feeding themselves and their children. Decisive regulatory action, including the restriction of marketing targeting children and the imposition of health taxes on HFSS foods, is required to reverse the tide of this public health crisis.
Similarly, the Israeli study advocates for a mandatory approach if voluntary use of positive labels does not gain sufficient industry traction. As Dr. Gupta and his colleagues note, the current absence of clear information on food packets leaves consumers unaware of what they are feeding themselves and their children. Decisive regulatory action, including the restriction of marketing targeting children and the imposition of health taxes on HFSS foods, is required to reverse the tide of this public health crisis.
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