CCPA Penalises ‘100%’ Claims: What India’s Latest Misleading Advertising Ruling Means for FMCG and Consumer Brands

By Lucy Rana and Shilpi Saurav Sharan

Why Every Brand Owner and Marketing Team Should Read This Order

On June 18, 2026, the Central Consumer Protection Authority (CCPA) issued an stating that if a brand’s product label, website, or advertising uses the term ‘100%’ in any claim about composition, ingredients, or naturalness, then that claim must be literally and verifiably true[1].

In this order, the CCPA while imposing a penalty of Rs. 1 Lakh each on Storia Foods and Beverages Pvt. Ltd. and Mrs. Bectors Food Specialities Ltd.[2] (the English Oven Bread brand) for misleading advertisements and unfair trade practices. The companies were also directed to immediately withdraw the impugned claims from all product packaging, official websites, and digital platforms.

Storia Foods: When ‘100% Natural’ Contains a Preservative

The case was taken up suo- motu by the CCPA against M/s Storia Foods and Beverages Private Limited with respect to advertisements on its official website (shop.storiafoods.com), on the packaging of its products, and on third-party e-commerce platforms in relation to the following products:

1. Storia 100% Tender Coconut Water;
2. 100% Natural Tender Coconut Water;
3. Storia 100% Juice-Pomegranate;
4. Storia 100% Juice- Mixed Fruit;
5. Storia 100% Juice -Mango; and
6. Storia 100% Juice – Guava Chilli

In view of its preliminary examination, the CCPA observed that the opposite party had on the front packaging of its product had prominently advertised its coconut water product as “100% Tender Coconut Water” and “100% Natural Tender Coconut Water” while the ingredient declaration on the product label disclosed the composition as “Water and Coconut Water Concentrate (9.6%) (Equivalent to 100% Coconut Water) (Reconstituted)”.

Additionally, the CCPA also observed that the opposite party’s promotional material for coconut water attributed health and therapeutic benefits to the product, without any product-specific scientific substantiation.

‘100% Tender Coconut Water’ — Made from Concentrate

The product marketed as ‘100% Tender Coconut Water’ was in fact made using coconut water concentrate at 9.6%, reconstituted with water. The product was not, therefore, pure coconut water in any literal sense. The term ‘reconstituted’ was printed in fine print on the packaging- adisclosure that the CCPA held was insufficient to alert an ordinary consumer to the material discrepancy between the advertised claim and the product’s actual composition.

The significance of this finding extends beyond the specific product. The CCPA’s holding that fine print disclosure of a material fact does not neutralise a misleading headline claim is a principle with wide application. A brand cannot make an absolute claim in large type on the front of a pack and then qualify it in small print on the back or side. The headline claim is what the ordinary consumer reads and relies upon. If that claim is not literally true, the fine print does not save it.

‘100% Natural’ — Contradicted by Class II Preservative INS 202

Mrs. Bectors: When ‘100% Whole Wheat’ Is 87%

The CCPA examined the promotional material for English Oven bread products made by the opposite party i.e. Mrs. Bectors Food Specialities Ltd. The advertising claims at issue were:

• ‘100% Atta Bread’
• ‘100% Whole Wheat Bread’
• ‘Taste of 100% Goodness’

These claims were prominently featured in the company’s marketing materials. During the CCPA proceedings, the company itself admitted that the bread contained only 87% whole wheat flour. It did not contain 100% whole wheat flour by composition.

The ‘Grain Source’ Defence Was Rejected

Mrs. Bectors during the proceedings attempted to argue that the use of term “100% Atta” or “100% Whole Wheat” in the Bread was only intended to mean that the sole grain source in the bread is wheat flour (Atta), with no refined flour (Maida) or other cereals. The CCPA in this context noted that the opposite party’s argument that the impugned claim of “100% Atta” or “100% Whole Wheat” was intended merely to signify wheat flour as the “sole grain source”, itself indicated the adoption of misleading advertisement for the sale of goods.

The Authority held that consumer perception is the decisive standard in determining whether an advertisement is misleading. An ordinary consumer reading ‘100% Whole Wheat Bread’ or ‘100% Atta Bread’ will understand that the product is composed entirely, or near-entirely, of whole wheat flour. A claim that the ‘atta’ used is of a particular type  rather than that the product itself is composed entirely of atta  is a construction that no ordinary consumer would arrive at from the plain language of the advertisement.

This ruling on the ‘grain source’ defence is one of the most commercially significant aspects of the order. Many FMCG brands use compositional-sounding claims that are intended to refer to a property of an ingredient rather than the whole product. The CCPA has now made clear that such claims will be assessed from the perspective of the ordinary consumer’s understanding  not from the perspective of the brand’s intended meaning.

The Combined Claims Problem: ‘100% Whole Wheat’ + ‘Zero Maida’

The CCPA also addressed the cumulative effect of multiple claims used together. The combination of ‘100% Whole Wheat’ and ‘Zero Maida’, both used in English Oven’s advertising was held to create a misleading impression that the product was composed entirely of whole wheat flour and contained no other ingredients. The CCPA’s finding is that advertising claims must be assessed not only individually but in their cumulative effect on consumer perception.

This is a point with significant implications for marketing teams. A claim that might be individually defensible, such as ‘Zero Maida’ could be literally true,  may become misleading when combined with another claim in a way that leads ordinary consumers to a false overall impression. The total picture of the advertisement matters, not only the technical accuracy of each individual element.

The Legal Framework the CCPA Applied

Both companies were found liable under the Consumer Protection Act, 2019. The specific provisions applied in this order are worth understanding in their own right, because they define the scope of the CCPA’s jurisdiction and the nature of the conduct it addresses.

Section 2(9) — The Consumer’s Right to Information

Section 2(9) of the Consumer Protection Act, 2019 defines consumers’ rights as including the right to be informed about the quality, quantity, potency, purity, standard, and price of goods — in order to protect consumers against unfair trade practices. The CCPA applied this provision to Storia’s misleading compositional claims: a consumer who purchases a product marketed as ‘100% Tender Coconut Water’ has a right to know that the product is made from concentrate reconstituted with water. Depriving the consumer of that information through misleading headline claims is a violation of this right. Mrs. Bectors was not cited under Section 2(9) — the Section 2(28) and Section 2(47) findings were sufficient on the facts as presented.

Section 2(28) — Misleading Advertisement

Section 2(28) of the Consumer Protection Act, 2019 defines a ‘misleading advertisement’ in relation to any product or service as an advertisement which falsely describes such product or service, or gives a false guarantee to, or is likely to mislead the consumer as to the nature, substance, quantity, or quality of such product or service, or conveys an express or implied representation which, if made by the trader or service provider, would constitute an unfair trade practice. Both companies were found liable under this provision. The false representation of product composition — whether in coconut water concentration or whole wheat flour content — was held to meet the statutory definition of a misleading advertisement.

Section 2(47) — Unfair Trade Practices

Section 2(47) of the Consumer Protection Act, 2019 defines ‘unfair trade practice’ broadly to include a trade practice which, for the purpose of promoting the sale, use or supply of any goods or for the provision of any service, adopts any unfair method or unfair or deceptive practice including the practice of making any statement, whether orally or in writing or by visible representation, which is false and not in accordance with the actual facts. The CCPA applied this provision to both companies’ use of ‘100%’ claims that were not in accordance with the actual composition of their products.

The CCPA Guidelines for Prevention of Misleading Advertisements and Endorsements, 2022

The CCPA also applied its own Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 — a subordinate instrument issued under the Consumer Protection Act that sets out specific requirements for advertising claims, including the requirement that claims be truthful, verifiable, and not deceptive. The Guidelines reinforce and operationalise the statutory definitions in the Act and provide the CCPA with a clear regulatory basis for action against advertising that does not meet these standards.

The aforesaid two cases are factually different but legally unified by a single principle that the CCPA has now stated with precision: ‘100%’ is an absolute and precise numerical expression that leaves no scope for approximation, qualification, or marketing interpretation. For FMCG brands, food and beverage companies, and consumer goods manufacturers operating in India, this order is not a regulatory footnote. It is a direct instruction about how product claims must be formulated, verified, and reviewed before they go to market.

What the CCPA Has Now Established as Binding Principle

Beyond the specific findings on these two companies, the CCPA order establishes several principles that apply to all consumer-facing advertising and labelling in India. These are not matters of interpretation — they are holdings that the CCPA has stated in clear and unqualified terms.

‘100%’ is an absolute numerical expression — not a marketing term.

The CCPA has categorically clarified that the term ‘100%’ is an absolute and precise numerical expression that leaves no scope for approximation, qualification, or marketing interpretation. In the absence of a legal definition permitting a different interpretation, the term must be understood in its literal sense by an ordinary consumer. A product that is described as ‘100%’ of something must be exactly and verifiably 100% of that thing.

Consumer perception is the decisive standard.

An advertisement is misleading if an ordinary consumer is likely to be misled by it — regardless of what the advertiser intended by the claim. The Mrs. Bectors ‘grain source’ defence failed precisely because it asked the CCPA to adopt the brand’s intended meaning rather than the ordinary consumer’s understanding. Courts and regulators assessing advertising claims apply a consumer-perception standard, not an advertiser-intent standard.

Good faith and intent are not defences.

The CCPA ruling establishes that good faith or intent is not a valid defence where consumer perception is likely to be misled. A brand that has used a misleading claim in good faith — believing that its marketing interpretation of ‘100%’ was legitimate — cannot rely on that belief as a defence to CCPA proceedings. The question is whether the consumer was or was likely to be misled, not whether the advertiser meant to mislead.

Fine print does not cure a misleading headline claim.

The CCPA’s finding on Storia’s ‘reconstituted’ disclosure in fine print establishes that a material qualification to an advertising claim must be prominently communicated to consumers. Burying a material disclosure in fine print — while making a contradictory headline claim in large type — does not satisfy the requirement of truthful, verifiable, and non-deceptive advertising.

Cumulative impression of multiple claims matters.

The combined effect of multiple advertising claims — such as ‘100% Whole Wheat’ combined with ‘Zero Maida’ — will be assessed holistically from the perspective of consumer perception. A claim that is technically accurate in isolation may be rendered misleading by its combination with other claims that together create a false impression.

The Commercial Stakes: Why This Matters Beyond ₹1 Lakh

The monetary penalty of ₹1 lakh on each company is, by most commercial measures, modest. But the commercial significance of this order is not the penalty,  it is everything that accompanies the penalty.

The CCPA’s direction to immediately withdraw the impugned claims from all product packaging, websites, and digital platforms is a far more significant commercial disruption for the brands share w than the fine itself. Withdrawing and redesigning product packaging across a national distribution network, updating all e-commerce listings across multiple platforms, revising website content, and pulling advertising materials involves cost, management time, and operational disruption that is orders of magnitude greater than ₹1 lakh.

The reputational dimension is also significant. A CCPA order finding that a brand has made misleading claims is a publicly searchable regulatory record. For consumer brands — whose commercial value depends substantially on consumer trust, a finding of misleading advertising creates a reputational risk that far exceeds the regulatory penalty. In a market where FMCG brands compete on health and naturalness claims, being publicly found to have misled consumers about composition strikes at the core of the brand proposition.

There is also the precedent effect. This order, and others like it, define the regulatory standard against which all consumer-facing advertising claims in India will be assessed going forward. Brands that are aware of the standard and have reviewed their claims accordingly are in a fundamentally different position from brands that discover the standard for the first time through a CCPA notice.

Which Advertising and Labelling Claims Are Now at Risk

Any consumer-facing brand that uses absolute or near-absolute claims in its advertising or product labelling in any category, not just food and beverage needs to assess those claims against the CCPA’s stated principles. The following categories of claim are particularly vulnerable in light of this order:

• Percentage composition claims: ‘100% [ingredient]’, ‘100% Pure’, ‘100% Natural’, ‘100% Organic’. Any claim using a percentage figure must be literally accurate for the product’s overall composition. A percentage claim about a component of an ingredient rather than the overall product composition will be assessed from the consumer’s perspective.
• Negative composition claims used in combination: ‘Zero [ingredient]’, ‘No [additive]’, ‘Free from [substance]’. Where these claims are combined with positive composition claims, the CCPA will assess the cumulative impression on consumer perception. A ‘Zero Maida’ claim combined with ‘100% Whole Wheat’ will be read as a composite representation about the product’s overall composition.
• Naturalness and purity claims: ‘Natural’, ‘100% Natural’, ‘Pure’, ‘Whole’, ‘Original’. Where a product contains synthetic additives, preservatives, concentrates, or other manufactured ingredients, naturalness and purity claims will be scrutinised against the actual composition. The presence of a Class II preservative in a ‘100% Natural’ product is, on the CCPA’s finding, a direct contradiction.
• Fine print qualifications to headline claims: where any qualification or disclosure is material to the accuracy of a headline claim, that qualification must be communicated with sufficient prominence that an ordinary consumer would see and understand it. ‘Reconstituted from concentrate’ buried in fine print does not qualify a ‘100% Tender Coconut Water’ headline claim.
• Claims about grain or ingredient source rather than overall composition: a claim that describes the type or quality of an ingredient — rather than the overall composition of the finished product — must be framed in a way that makes the distinction clear to an ordinary consumer. A claim that is intended by the brand to refer to the grain source but is understood by consumers as referring to overall composition will be assessed as the consumer understood it.

What Brands and General Counsel Should Do Now

The CCPA’s order creates an immediate compliance imperative for every consumer brand operating in India with claims on its products or in its advertising that use absolute or near-absolute language. The question is not whether the CCPA will act on such claims — this order establishes that it will. The question is whether your brand’s claims can withstand the scrutiny this order defines.

Addressing this question requires legal analysis: mapping each claim against the actual composition of the product, assessing whether the claim is literally and verifiably accurate, identifying any fine print qualifications that may be insufficient to cure a misleading headline claim, and evaluating the cumulative impression created by multiple claims used together.

[1] Case No: CCPA-2/71/2024-CCPA

[2] F.No. CCPA-2/72/2024-CCPA [E-35629]