Supreme Court Gives Centre Three Months to Finalize Nutrition Labels on Packaged Foods
Introduction
In a crucial move toward strengthening consumer health rights, the Supreme Court of India on April 9, 2025, directed the Central Government to finalize regulatory norms for Front-of-Pack Nutrition Labels (FOPNL) within three months. The decision stems from growing concern over India's rising burden of non-communicable diseases (NCDs), many of which are linked to unhealthy food consumption. Transparent, easy-to-understand labelling is seen as a vital first step in helping consumers make better dietary choices.
Case Background
The Supreme Court’s directive arises from a Public Interest Litigation (PIL) filed by 3S and Our Health Society, which sought the implementation of mandatory warning labels on packaged foods. The petition was filed under Article 32 of the Constitution, enabling citizens to directly approach the Court for the enforcement of fundamental rights — in this case, Article 21, which guarantees the right to life, encompassing the right to health and well-being.
The PIL argued that current food labels do not adequately inform consumers of the levels of sugar, salt, and saturated fats, especially in processed and ultra-processed foods. This lack of clarity impairs informed decision-making and contributes to India’s public health crisis.
The case also draws upon the Food Safety and Standards Act, 2006, particularly, Section 16 that empowers the Food Safety and Standards Authority of India (FSSAI) to set food labelling standards, and Section 23 that lays down packaging and labelling requirements for food products.
Supreme Court’s Directive
Acknowledging that FSSAI had already initiated reform — notably a draft notification dated September 13, 2022, proposing the Indian Nutrition Rating (INR) system — the Court expressed concern over the delay in implementation. Accordingly, it issued a clear directive:
- The Expert Committee constituted by FSSAI must submit its final recommendations within three months.
- These recommendations must then be reviewed by the Scientific Committee, and the final draft placed before the Food Authority for approval.
- The matter will be listed again after three months to monitor compliance.
This sequence creates a binding timeline and ensures that the long-pending regulatory framework does not remain in limbo.
During the hearing, Justice J.B. Pardiwala remarked on the lack of clear nutritional disclosure on popular packaged food brands and emphasized the importance of empowering consumers with accurate, visible information. The Court took note of the FSSAI’s proposed amendments, which would require the front-of-pack display of total sugar, salt, and saturated fat content, along with their percentage contribution to the Recommended Dietary Allowance (RDA). These measures are intended to combat the health risks associated with growing consumption of ultra-processed foods .
Our Comments
The Indian Nutrition Rating (INR) System: What Is It?
At the core of the proposed regulation is the INR system, which aims to simplify nutrition labeling by using a star-based rating format. Designed to be easily understood at a glance, the INR would appear prominently on the front of packaged food products, helping consumers assess healthiness without decoding complex nutrition tables. Key features include:
- Rating Scale: From 0.5 to 5 stars, where higher ratings indicate healthier options.
- Criteria: Evaluates both negative nutrients (added sugars, saturated fats, sodium) and positive nutrients (fiber, protein, select vitamins).
- Placement: Displayed near the brand or product name on the front panel of packaging.
Certain items, such as fresh fruits, vegetables, and some milk products, may be exempted from this system. Moreover, critics argue that a star-rating system could oversimplify nutritional risks, and there’s an ongoing debate on whether more interpretive labels (like Chile’s stop signs or Singapore’s Nutri-Grade) might offer stronger deterrents.
Regulatory Framework Supporting FOPNL
In addition to the 2022 draft amendment, FOPNL is supported by broader legal and policy instruments:
- Food Safety and Standards (Labelling and Display) Regulations, 2020: These already mandate nutrition facts panels, including data on energy, sugar, fat, sodium, and protein per serving. However, they lack prominent interpretive front-facing symbols.
- Advertising Standards Council of India (ASCI) Guidelines: These guidelines aim to curb misleading health claims in food advertising, though they remain voluntary and non-binding. In practice, many food ads still use selective or exaggerated claims without regulatory pushback.
- Consumer Protection Act, 2019: Misleading packaging and insufficient disclosures may also qualify as unfair trade practices under this statute, offering another avenue for consumer redress.
Final Thoughts
If executed in line with the directive, these measures could streamline consumer understanding of packaged foods, improve transparency, and align India’s food regulation with global best practices. However, the effectiveness of FOPNL will ultimately depend on whether the INR system is made mandatory and enforceable, how it is integrated with advertising and marketing regulation, and the clarity and accessibility of information provided to all consumer segments. If implemented effectively, this reform could mark a meaningful step toward improving consumer autonomy in India's evolving food landscape.
References
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