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Package deal: Current system of food labelling in India makes it tough to decipher facts

While food labelling regulations require all prepackaged food items to display info related to content, nutrition, etc, in a clear and legible way, the current system in India makes it tough to decipher facts

While some key considerations are taken in developing a FoPL system in a country, the Codex Alimentarius Commission (Codex) has undertaken work on FoPL. Codex is a collection of internationally recognised standards, codes of practice, guidelines, and other recommendations published by the Food and Agriculture Organization (FAO) relating to food, food production, food labelling, and food safety.
While some key considerations are taken in developing a FoPL system in a country, the Codex Alimentarius Commission (Codex) has undertaken work on FoPL. Codex is a collection of internationally recognised standards, codes of practice, guidelines, and other recommendations published by the Food and Agriculture Organization (FAO) relating to food, food production, food labelling, and food safety.

For Madhu Tyagi, it is always a Herculean task to decipher the nutritional values or any other information related to content that are imprinted on food packets. Being gluten intolerant, the mother of a two-year-old child particularly looks out for products that have allergy warnings.

“I am not sure how much sugar is in my brown rice flour or salt in my salsa dip,” says the 30 something homemaker, adding: “At times, it’s difficult to comprehend the format or the style of text used; they are not distinctly marked for our (consumer) understanding.”

Tyagi is not the only one complaining. Many consumers find it difficult to figure out the label terminologies or numbers written on food packets. While ‘warning’ or content labels are a simple and effective way to inform or alert consumers, the current labelling system in India somehow fails to meet the criteria. Experts feel there is a need to adopt symbol-based and nutrient-specific warning labels to transcend the literacy and language barriers.

The purpose of nutritional information labels on food helps consumers to determine if the product is suitable / healthy or not. “Salt, sugar and fat levels elevate the taste and texture of the food. But their overconsumption is closely associated with obesity and correlated chronic disorders. And not everyone can understand the information regarding preservatives and chemicals. So, if individuals have allergies, it might be life-threatening in some circumstances,” says Zainab Cutlerywala, faculty at Pune-based Institute of Nutrition and Fitness Sciences (INFS) imparting comprehensive and practical knowledge in health and fitness.

As per Cutlerywala, other countries have opted for measures like traffic light labelling for better understanding of the consumer and levying tax on companies for high sugar content in products. This has forced the companies to reduce the sugar content in food items. However, in India, a simple transparency has not been achieved. “To offer a comprehensive, easy-to-understand label would benefit the customer but not as much as the producer,” adds Cutlerywala.

Global best practices

Globally, the front-of-pack labelling (FoPL) system has been regarded as the best practice to supply ample information on food choices. According to the World Health Organization (WHO), FoPL is defined as “nutrition labelling systems that are presented on the front of food packages in the principal field of vision; and present simple, often graphic information on the nutrient content or nutritional quality of products, to complement the more detailed nutrient declarations provided on the back of food packages.”

While some key considerations are taken in developing a FoPL system in a country, the Codex Alimentarius Commission (Codex) has undertaken work on FoPL. Codex is a collection of internationally recognised standards, codes of practice, guidelines, and other recommendations published by the Food and Agriculture Organization (FAO) relating to food, food production, food labelling, and food safety.

Countries like Brazil, Chile and Israel have labelling laws that stress on FoPL in the packaged food industry as an index to fight obesity and non-communicable diseases (NCDs) such as heart disease, stroke, cancer, chronic respiratory diseases and diabetes. Countries also review the elements of existing systems that are considered to be more effective or less effective in supporting consumers to make informed food purchases and healthier eating choices (using published evidence or primary consumer studies of the usefulness of FoPL system elements, including formats such as design and content). A global checklist for developing new FoPL system includes interpretive systems such as the multiple traffic light labelling system (United Kingdom), nutri-score system (France) and warning system (Chile); non-interpretive systems such as percentage reference intakes (European Union); and hybrid systems such as the Health Star Rating (Australia and New Zealand).

India is progressing towards enforcing labels. The Food Safety and Standards Authority of India (FSSAI) will soon start labelling the front of packaged food products with Health Star Rating (HSR) based on a study conducted by IIM Ahmedabad and one that is easy to understand and induces behavioural changes in Indian consumers.

The FSSAI has also mandated labelling requirements that need to be complied as per the labelling regulations. At the same time, advertisements and claim regulations are in place to ensure compliance by the industry. While the Advertising Standards Council of India (ASCI) is working on identification, reporting and necessary action against misbranding and labelling incidents, the prosecution in case of violations is done as per the provisions of the FSS Act. Further, the FSSAI, from time to time, keeps advising the state food safety departments to ensure regular checks in the market and take necessary action against violations made, if any.

However, experts from Australia (using HSR) and Chile (using warning labels) believe how such labels have an extensive evaluation of the impact. Mark Lawrence, professor of public health nutrition at the Institute for Physical Activity and Nutrition, Deakin University, Australia, while speaking at a recently organised webinar by the Breastfeeding Promotion Network of India (BPNI) in association with Nutrition Advocacy in Public Interest in India (NAPi), highlighted the need to look at the science to guide adoption of labels and thresholds so that they do not result in unintended consequences.

According to Marcela Reyes Jedlicki, a public health expert and assistant professor at the Center for Research in Food Environments and Prevention of Chronic Diseases Associated with Nutrition (CIAPEC), Public Nutrition Unit, University of Chile, the Chilean Law (published in 2012) had included the specification of warning labels after several years of discussion (the act was first presented in 2007 with traffic light labels).

“During the discussion, qualitative data suggested the population did not understand the idea of traffic lights applied to food: participants had problems interpreting when different colours were present (eg, a food with 1 red label + 1 green label vs a food with 1 orange label). Thus, policymakers decided to simplify and use the warning labels. For such implementation, the health authorities need to decide on the format and text of warning labels, but could not change the warning nature of labels,” she says.

There is a plethora of scientific evidence that clearly points towards using the warning labels on unhealthy food products with high sugar/salt or fats for a meaningful outcome. In a 2020 study published in research journal PLOS, it is estimated that warning labels effectively reduced obesity and obesity-related costs after implementing warning labels in Mexico followed by Chile, Peru and Uruguay.

However, the decision to choose a label should be kept free from commercial interest to avoid any conflicts of interest. “The choice of the label should be based on science and public health interest must be at the centre of debate. Industry loves HSR as it does not reflect the nutrients of concern, misleads people who think that food products are healthy because of stars and aggressive marketing tactics,” says Arun Gupta, central coordinator of BPNI and convener of NAPi.

Packaged food products are usually projected as healthy using HSR as they receive ½ to 5 stars, which give an impression of being good and more stars means healthy, which is misleading. This way consumption of substantially unhealthy food could increase and defeat the very objective for which FoPL is being designed. HSR can be confusing for consumers, if packaged food labels show any ‘health claim’ by using positive nutrients. “Warning labels are the need of the hour to curb the consumption of unhealthy and ultra-processed packaged food. Children are falling prey to demons of NCDs and this must stop,” says author-activist Vandana Shiva, director of Navdanya, an NGO which promotes biodiversity conservation, biodiversity, organic farming, the rights of farmers, and the process of seed saving.

Analysis using the Australian HSR Calculator reveals biscuits or chips of various brands with the sugar content range from 21 to 38 grams, energy levels ranging from 454 kcal to 513 kcal or sodium levels ranging 643 to 1,080 mg per 100 grams (all more than the FSSAI proposed thresholds), and the product is still getting 1, 2 or 1-and-1/2 stars without identifying the key nutrients of concern. “Where is the provision in the HSR to give a zero score if any of the nutrient of concern goes higher than the threshold?” asks professor HPS Sachdev, an eminent epidemiologist and researcher, as he feels the presence of protein or fibre in food does not take away the risk of high sugar/salt or the food being ultra-processed.

Common food allergens

Eggs: An egg allergy is the second most common cause of food allergy.

Tree nuts: A tree nut allergy is an allergy to some of the nuts and seeds that come from trees. People with a tree nut allergy can sometimes also be allergic to food products made with these nuts, such as nut butters and oils. Tree nuts include:

  • Almonds
  • Cashews
  • Macadamia nuts
  • Pistachios
  • Pine nuts
  • Walnuts

Wheat: A wheat allergy is an allergic response to one of the proteins found in wheat. Those with celiac disease or non-celiac gluten sensitivity avoid wheat and other grains that contain the protein gluten.

Soy: Soy allergies are triggered by a protein in soybeans or soybean-containing products. Common food triggers of soy allergy include soybeans and soy products like soy milk or soy sauce.

Fish: Fish allergy can cause a serious and potentially fatal allergic reaction. The main symptoms are vomiting and diarrhoea, but, in rare cases, anaphylaxis can also occur.

Shellfish: A shellfish allergy is caused by your body attacking proteins from the crustacean and mollusk families of fish, also known as shellfish. Some examples of shellfish are

  • Shrimp
  • Prawns
  • Crayfish
  • Lobster
  • Squid
  • Scallops

Some less common food allergies include

  • Linseed
  • Sesame seed
  • Peach
  • Banana
  • Avocado
  • Kiwi fruit
  • Passion fruit
  • Celery
  • Garlic
  • Mustard seeds
  • Aniseed
  • Chamomile

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