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FSSAI Warning Labels For Packaged Foods | The Legal Observer

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FSSAI proposes red warning labels for packaged foods high in sugar, salt and fat after the Supreme Court questioned delays in front-of-pack labelling.

The proposed red hexagonal labels are aimed at helping consumers quickly identify packaged foods containing high levels of specified nutrients.

The Food Safety and Standards Authority of India (FSSAI) has proposed introducing red-coloured hexagonal warning labels on packaged food products high in added sugar, saturated fat and salt. The proposal marks a significant shift in the regulator’s approach after the Supreme Court expressed dissatisfaction over the delay in implementing clear front-of-pack warning labels.

The proposal was placed before the Supreme Court through a six-page compliance affidavit in a Public Interest Litigation seeking mandatory Front-of-Pack Warning Labels (FoPWL) for packaged foods containing high levels of fat, sugar and salt.

Red Hexagonal Warning Labels Proposed

Under the proposed framework, a prominent red hexagonal warning would be placed on products that are high in any two or more of the specified nutrients—added saturated fat, added sugar and salt.

Depending on the composition of a product, the warning could carry declarations such as “HIGH FAT”, “HIGH SUGAR”, “HIGH SALT” or “HIGHLY SWEETENED BEVERAGE”.

The thresholds for determining whether a product falls within the warning category would be based on the Dietary Guidelines for Indians, 2024, issued by the Indian Council of Medical Research-National Institute of Nutrition (ICMR-NIN).

FSSAI has also proposed making the warning more visible than the conventional nutrition information provided at the back of the package. The warning would be displayed in a font size one point larger than the font used in the nutrition information table.

The proposed pictorial format is intended to provide consumers with a simple and easily understandable warning without requiring them to interpret detailed nutritional information.

Two-Phase Implementation

The regulator has proposed implementing the front-of-pack warning system in two phases.

During the first phase, products containing high levels of two or more specified nutrients, along with specified sweetened beverages, would come within the warning regime.

The second phase would expand the requirement to products that are high in any one of the specified nutrients.

According to FSSAI, the phased approach would provide the food industry with adequate time to reformulate products while also protecting consumers’ right to information. The regulator has particularly highlighted the need to facilitate informed food choices among children and other vulnerable sections of society.

Certain Foods Proposed To Be Exempt

The proposed front-of-pack warning requirement would not apply to single-ingredient food products or foods that are inherently rich in fat, sugar or salt.

The affidavit specifically refers to products such as ghee, edible oil, salt, sugar, jaggery and honey. Such products would, however, continue to remain subject to other applicable food safety and labelling requirements.

Supreme Court’s Earlier Criticism

The latest proposal comes shortly after the Supreme Court strongly questioned FSSAI’s earlier approach to front-of-pack labelling.

A Bench comprising Justice JB Pardiwala and Justice K Vinod Chandran had expressed dissatisfaction with the regulator’s failure to introduce an interpretive warning system capable of clearly communicating the levels of sugar, salt and saturated fat in packaged foods.

The Court had earlier questioned whether regulatory authorities were yielding to pressure from the food industry and emphasised the importance of protecting public health, particularly the health of children.

The proceedings arise from the PIL filed by 3S and Our Health Society, which has sought mandatory front-of-pack warning labels for packaged food products. The case is 3S and Our Health Society v. Union of India and Anr., Miscellaneous Application No. 1177/2025 in W.P.(C) No. 437/2024.

The proposed red warning labels could therefore represent a major development in India’s food-labelling regime, placing greater emphasis on making potentially harmful nutritional content immediately visible to consumers.

External reference: The Legal Observer YouTube Channel

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