Fssai Targets Misleading “100%” Claims: a Wake-Up Call for Food Brands

By Apalka Bareja, Aishwarya Rajput And Ritvik Kashyap

Introduction

Ever wondered whether that “100% natural” label on your food really tells the whole story? Consumers often see phrases like “100% pure” or “all-natural” on product packaging, and it’s not always clear what these claims genuinely mean. To help ensure truthful commercial representation, encourage fair competition, and improve consumer protection, the Food Safety and Standards Authority of India (FSSAI) has issued an important advisory dated May 28, 2025.

This directive gently reminds food businesses to be more mindful about using unqualified claims such as “100% natural,” “100% pure,” or “100% fruit juice” in their product labelling and advertising. It’s a proactive step to bring more clarity to the marketplace, especially as India’s fast-moving consumer goods (FMCG) sector continues to grow and evolve. The aim is to foster a more transparent environment where consumers can make informed choices about the food products they buy.

Background- The Rise of “100%” Claims and FSSAI’s Response

In recent years, India’s food and beverage industry has seen a significant increase in products advertising themselves as “100%” whether it’s for juices, oils, snacks, dairy items, or nutritional supplements. These “100%” claims are often used in marketing to suggest high quality or purity. However, a key issue is that Indian food law doesn’t actually define what “100%” means in these contexts.

Recognizing this regulatory gap and the potential for consumers to be misled, the FSSAI’s new advisory aims to address the widespread use of such terms. The goal is to curb the use of “100%” claims unless they can be backed up by scientific evidence or verifiable standards. This move highlights the FSSAI’s commitment to ensuring that marketing on food products is accurate and transparent.

Legal Foundations: Scrutiny Under Advertising and Claims Regulations

The FSSAI’s advisory is based on the principles laid out under the Food Safety and Standards (Advertising and Claims) Regulations, 2018, which govern how food businesses may advertise and present claims about their food products. Two key provisions Regulation 4[1] and Regulation 10(7)[2] of the Food Safety and Standards (Advertising and Claims) Regulations, 2018 are particularly relevant in the context of the “100%” claim prohibition.

1. Regulation 4: General Principles for Claims
   Regulation 4 outlines the standards that all food-related claims must meet:
   1. Claims must be truthful, unambiguous, meaningful, and not misleading, and should assist consumers in understanding the nature of the product [Reg. 4(1)].
   2. They should not encourage overconsumption or imply that ordinary diets are inadequate [Reg. 4(2) & 4(3)].
   3. Claims related to the method of preparation must disclose preparation details on the label [Reg. 4(4)].
   4. Disease risk reduction claims must mention the number of servings per day required for the claimed benefit [Reg. 4(5)].
   5. Nutritional or health benefit claims must be scientifically substantiated with validated methods [Reg. 4(6)].
2. Regulation 10(7): Fair Advertising Practices
   Additionally, Regulation 10(7) specifically prohibits food businesses from making claims or advertisements that undermine the products of other manufacturers in an attempt to promote their own goods or influence consumer behaviour.

   Given that terms such as “100%” currently lack a precise statutory or technical definition, their unqualified use could potentially contravene these provisions. Such usage may be construed as constituting misleading or unfair commercial practice, thereby necessitating substantiation by scientific evidence or verifiable standards.

Not the First Warning—A Pattern of Scrutiny Emerges

This latest advisory from the FSSAI is not an isolated incident; rather, it represents an escalating pattern of regulatory scrutiny concerning unsubstantiated claims. This move builds upon a prior directive issued in June 2024[3], where the FSSAI specifically cautioned food companies against labeling beverages with added sugar or concentrate as “100% fruit juice.”

That earlier notice sparked considerable debate within the industry, drawing opposition from major Fast-Moving Consumer Goods (FMCG) players who had long integrated such claims into their brand strategies. The current advisory significantly expands this scope beyond just juices, now explicitly warning against any unsubstantiated “100%” claim, irrespective of the food category. This indicates a broader regulatory intent to ensure accuracy and prevent consumer deception across the entire food product spectrum.

Compliance Expectations for Food Businesses

In light of the FSSAI’s clear stance on “100%” claims, Food Business Operators (FBOs) are advised to take immediate and proactive steps to ensure compliance. The advisory signals a heightened regulatory environment, and FBOs should consider the following actions:

• Comprehensive Review of Marketing Materials:FBOs are expected to undertake a thorough review of all existing packaging, product labels, and promotional materials. The objective is to identify and promptly eliminate any usage of “100%” claims that cannot be substantiated with robust scientific evidence or verifiable standards.
• Avoidance of Unsubstantiated Claims:It is crucial for FBOs to refrain from employing any marketing language that implies superiority, exclusivity, or specific health benefits unless such claims are supported by rigorous scientific validation in accordance with regulatory requirements.
• Enhanced Internal Training and Awareness:Advertising teams, brand strategists, and all personnel involved in product communication should receive comprehensive training on the relevant food labeling and advertising regulations. This is essential to prevent inadvertent non-compliance and to foster a culture of accuracy in product representation.
• Preparation for Increased Scrutiny:FBOs should anticipate that the FSSAI may intensify its monitoring and enforcement efforts. Non-compliance could lead to significant penalties, including fines, product recalls, or other enforcement actions as stipulated under the Food Safety and Standards Act, 2006.

Proactive adherence to these guidelines will be critical for FBOs to mitigate regulatory risks and maintain consumer trust in the evolving landscape of food product marketing in India.

Implications of Non-Compliance with the Advisory for FBOs

Conclusion

The FSSAI’s recent directive on “100%” claims marks a significant shift in India’s regulatory approach to food advertising. It highlights a stricter focus on labelling compliance and reinforces that all marketing claims must be evidence-based, precise, and legally defensible.

For food businesses, this is not merely a guidance note but a clear compliance requirement. Legal teams, compliance officers, and marketing professionals should work in close coordination to ensure that all product claims are both persuasive to consumers and capable of withstanding regulatory scrutiny.

[1] General principles, available at: https://fssai.gov.in/upload/uploadfiles/files/Compendium_Advertising_Claims_Regulations_14_12_2022.pdf

[2] Prohibited claims, available at: https://fssai.gov.in/upload/uploadfiles/files/Compendium_Advertising_Claims_Regulations_14_12_2022.pdf

[3] https://fssai.gov.in/upload/advisories/2024/06/665eb7e80327aAdvisory%20100_percent%20Fruit%20juices.pdf

[4] https://www.indiacode.nic.in/bitstream/123456789/7800/1/200634_food_safety_and_standards_act,_2006.pdf

[5] https://www.indiacode.nic.in/handle/123456789/15256