By equating samosa with burger, industry wants to dilute the regulation on sale of junk food to children
Is samosa really healthier than a vegetable burger?’ This is the headline of an article written by noted journalist and food critic Vir Sanghvi, in the Hindustan Times Brunch magazine in early April (bit.ly/2qQc7Di). Vir wrote this article in reaction to a Centre for Science and Environment (CSE) report, that argued that Indian traditional snacks like samosa score over industrially produced fast food like burgers, even if they have similar levels of fats and salt, and hence should be treated differently. Vir, however, disagrees and has argued in his article, that nutrition is far too complicated for blanket generalisations about one food being healthier than another.
Before I debate Vir Sanghvi’s article, it is important that I put forth the genesis of the discussion around traditional snacks versus industrially produced fast food (from now on junk food). This is also for the benefit of Mr. Sanghvi, because he has ignored the health impacts of junk food and presented a simplistic notion about food and nutrition in his article. It is also important to mention here, that the debate is about samosa and burgers sold in the market and not what people cook at home.
There has been growing concern in India about childhood obesity and the rising incidence of diseases like hypertension and diabetes. Data indicates that obesity in children is increasing rapidly. It is high among the affluent class and children in private schools, compared to low- and middle-income groups. A recent study published in the New England Journal of Medicine estimated that cases of obesity among children and adolescents (<20 years) were the highest in India and China. There is now an emerging body of scientific studies linking junk food with childhood obesity and the diabetes epidemic.
Citing the growing incidence of childhood obesity, Uday Foundation, a Delhi-based NGO, filed a PIL in 2010 before the Delhi High Court, to ban junk food and carbonated drinks in schools. It also pleaded a ban on the advertisement of junk food and the formulation of a comprehensive ‘School Canteen Policy’ to make available wholesome, nutritious, safe, and hygienic food to school children in India.
The High Court entrusted the job of development of guidelines on junk food in schools to the Food Safety and Standards Authority of India (FSSAI). An expert group, comprising health experts, nutritionists, NGOs and industry representatives, was set up to develop the guidelines. CSE was also a part of this expert group.
The biggest dispute in the expert group was on how to classify food into different categories. There should not have been a fight over this issue, as India’s premier nutrition research institute, National Institution of Nutrition (NIN), Hyderabad, had already come out with dietary guidelines for Indians in 2011. The guidelines classified food into four categories:
* To be consumed adequately, including cereals, pulses, milk, etc,
* To be eaten liberally, including fruits and vegetables,
* To be eaten moderately, including oil, fats, meat, fish, eggs, etc, and
* To be eaten sparingly, including burger, pizza, fries, ice cream, chocolate, etc.
From the NIN guidelines, one could have arrived at a straightforward conclusion that junk food should not be allowed in schools. But the industry representatives rejected NIN’s classification.
The industry’s assertion, which is also Vir Sanghvi’s conclusion, was that no food is good or bad when eaten in moderation. Vir writes in his article, “The truth is, except for an actual poison, there is nothing that is always unhealthy. Most foods (in moderation), can be healthy for some people and unhealthy for others, at different stages of their lives.”
Industry also objected to the term junk food, demanding instead that their products be called ‘eat just right’, or ‘eat judiciously’, or ‘eat moderately’, or ‘eat responsibly’, and not be banned in schools. They also included traditional deep-fried snacks like samosa and chholey bhature in this category. Their argument was that these products are also high in fat and salt like burgers, and if there was going to be a regulation on companies selling burgers, there should also be one on samosa-wallahs. This was a brilliant strategy to muddle the debate and dilute the guidelines.
But the non-industry members of the expert committee rejected industry’s proposal and gave a consensus report that recommended the banning of junk foods in schools. Industry members gave their own report in which nothing was banned. FSSAI did the most brilliant thing; it mixed both reports and produced a hybrid draft, full of contradictions, and submitted it to the Delhi High Court in March 2014.
Meanwhile, my colleagues at CSE continued their research on this issue and found an answer to counter the position of the industry. The answer was in the dietary guidelines developed by the Ministry of Health, Brazil.
Brazil had, in late 2014, come out with dietary guidelines that are considered by many global experts as the best in the world. The Brazilian guidelines are similar to those of NIN, except that they introduced the concept of processing in the classification of food. They classified food into four categories; minimally processed food (cereals, milk, eggs, pulses, fruits and vegetables, etc); products extracted from natural food (oil, fats, salt and sugar); processed food (products manufactured with salt, sugar and oil and minimally processed food); and ultra-processed food.
Ultra-processed foods are those produced by industry, and made entirely or mostly from substances extracted from foods like oils, fats, sugar, starch, and proteins, using a large number of additives like flavour enhancers, colour, thickeners, emulsifiers, preservatives, and isolates, to make the product long-lasting and hyper-palatable. Ultra-processed foods are put in the eat-least category food because of their unbalanced nutritional composition and higher risk of diseases.
Based on the aforementioned, CSE reasoned that while Indian snacks like samosa and chholey bhature can be termed as processed food, all junk food like burgers, pizzas, colas, chips, etc, fall under the ultra-processed food category. In addition, junk food is mass-advertised, distributed and marketed, impacting the buying and eating habits of consumers, especially children, which is not the case with Indian snacks. Therefore, while the consumption of processed food should be controlled, ultra-processed food should not be allowed in schools. CSE published this report in 2017.
Once this report was published, many newspapers carried it. The Hindustan Times published an article titled ‘Samosa is “healthier” than burger: CSE report’. The issue was also discussed on social media. According to Vir Sanghvi, he wrote his article because a social media user wanted him to respond to this debate.
Vir did respond to CSE’s report but, alas, didn’t get the facts right. By saying “…nutrition is far too complicated”, he ignored the work done across the world to classify food based on health and nutrition, and to develop dietary guidelines/regulations around it. From Australia to Canada, and from Mexico to South Korea, and the Philippines, countries classify foods, and on this basis, have banned junk food in schools and put regulations to control their marketing to children.
The FSSAI also got it wrong. Its hybrid report has recently been converted into a draft regulation, ‘Draft Food Safety and Standards (Safe and Wholesome Food for School Children) Regulations, 2018, and has been put out for public comments. Under this regulation, it has created a red category of food, which includes both Indian snacks like samosa and chholey bhature, and junk food like burger and cola. Instead of banning these foods, schools have been merely advised not to serve these in canteens. This draft regulation, therefore, has diluted the very purpose of controlling the sale of junk food in schools. This is exactly what the industry wanted; equating samosa with burgers so the junk food industry goes scot-free.
It is critical for India to get this politics of samosa-versus-burgers right. FSSAI can no longer promote weak regulations in the garb of playing neutral. It must ensure that unhealthy food is not sold and marked to children. Else, we risk large public-health gain from the regulation of junk food.