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PRE PACKAGED FOOD PRODUCTS AND LABELLING REGULATIONS

March 17, 2021

By Lucy Rana and Rupin Chopra

The FSSAI notified the Food Safety and Standards (Labelling and Display) Regulations, 2020 on November 17, 2020[1]. The Regulations have notified a change in the display of nutritional information and calculation of nutrients for the pre-packaged products.

The Packaged Food companies have approached the Food Safety Authority of India (FSSAI) and requested that food items like cookies, confectionaries, juices to be kept out of the front of pack labeling regulations[2] as requested by the companies. The food companies have alleged that packaged food items based on their fat sugar and salt content as proposed in the Traffic Labelling Regulations, 2019 should be delinked from the new FSSAI Labelling Regulations, 2020.

BACKGROUND

Currently, most of the packaged food companies print nutrition details of the contents, including their recommended daily values, at the back of the package.

CHANGES INTRODUCED

The legislation has mandated the packaged food companies to label high fat, sugar and salt contents in the front of the package itself. The food labels will also declare, per serve percentage contribution to RDA (recommended dietary allowance) on the front of the pack.

This can be explained through a comparison drawn considering the various products:

AIM OF THE NEW LEGISLATION:

  • To manage the Recommendatory Dietary Allowance of the products for the consumers. The RDA is ceiling on the amount of fat, sugar, sodium component in the product to maintain the healthy life.
  • The new regulation has under Regulation 3(b)[3] has prescribed the limits of the nutrients, whereby the definite limits act a restraint on the companies to maintain the product as healthy.
  • The display of all types of salt, sugar and fat is the new component given by Regulation 3 (a).
  • The display of sodium and cholesterol which was only claimed in the old regulation of 2011 has been mandatory for the companies.
  • The display of dietary fiber has been made compulsor

THE REGULATION HAS BEEN DEFINED AS FOLLWS:

According to Food Safety and Standards (Labelling and Display) Regulations, 2020[4]:-

S.No. Regulation Provision

 

1. Regulation 3(a) The new regulations have emphasized the division of information into:

 

·         Sugar- means all monosaccharides (glucose, fructose, etc.) and disaccharides (maltose, sucrose, lactose, etc.).

·         Added sugar- means monosaccharides and disaccharides added to foods and beverages

·         Fat- means total lipids including saturated fat, monounsaturated fat, polyunsaturated fat and trans fat.

o   ‘Saturated fats’ means fatty acids without double bonds.

o   ‘Monounsaturated fats’ means fatty acids with one cis double bond.

o   ‘Polyunsaturated fats’ means fatty acids with cis-cis methylene interrupted double bonds.

o   ‘Trans Fat’ means all the geometrical isomers of monounsaturated and polyunsaturated fatty acids having non-conjugated, interrupted by at least one methylene group, carbon-carbon double bonds in the Trans configuration

·         Dietary Fiber (not lower than 3)- means carbohydrate polymers with a degree of polymerization (DP) not lower than three, which are not hydrolysed by the endogenous enzymes in the small intestine of humans and the same consists of one or more of-

·         Edible carbohydrate polymers naturally occurring in the food as consumed;

·         Carbohydrate polymers, which have been obtained from food raw material by physical, enzymatic or chemical means;

·         Synthetic carbohydrate polymers.

·         Nutrients

 

2. Regulation 3(b) Every product shall display the nutritional information for 100 g or 100 ml or per single consumption pack of the product and per serve percentage contribution to recommended dietary allowance which is calculated on the basis of  200Kcal energy as:

 

·         67g total fat

·         22 g saturated fat

·         2 g trans fat

·         50 g added sugar

·         2000 mg of sodium (5g salt) requirement for average ADULT PER DAY.

 

 

STEPS TAKEN BY RENOWNED FMCG COMPANIES

The new amendment makes it mandatory for the companies to display requirement which were not present in the old nutritional information in order to manage its dietary recommendatory allowance which includes-Sugars and Added sugar and Fat, Fatty Acid, Trans Fat, Poly Saturated Fats and all other types of Fats and Cholesterol.
1-Product 1

S.No. Nutritional Information Old Regulations New Regulations Prescribed Limit
1. Energy 523kcal 462kcal
2. Total Carbohydrates

 

Sugar

29g

 

14g

42.81kcal

 

8.08g

50g
3. Total Fat

 

Saturated

 

Monosaturated

Fatty Acids

 

Fatty Acids

 

Polyunsaturated Fatty Acids

 

Trans Fatty Acid

39g

 

 

 

 

 

 

 

28.41g

 

12.58 g

 

3.19

 

 

8.82

 

0 g

 

 

67g

 

 

 

 

 

 

 

 

 

 

 

2g

4. Dietary Fiber 8.86g
5. Proteins 14g 8.86g
6. Sodium 555mg 671mg 2000mg
7. Cholesterol 0mg

 

2-Product 2
The Product 2 has classified nutritional information and showcased the nutrients information in per serving form and also to include the percentage of per serving in it, [7]which is an essential requirement according to new regulation.

S.No. Nutritional Information Old Regulation New Regulations Prescribed Limit
1. Energy 402kcal 427kcal
2. Protein 9.2g 8.0g
3. Carbohydrate

Total Sugar

 

Sugar Fiber

58.9g

1.2g

 

63.5g

 

50g
4. Total Fat

 

Saturated Fat

 

Trans Fat

14.4

 

 

15.7g

6.8g

 

0.13g

67g

 

22g

 

2g

5. Sodium 1172.3mg 2000mg
6. Calcium 160mg
7. Potassium 342mg

GDA- Guideline Daily Amounts of an Average Adult (2000Kcal) pack contains 8 serves.

CONCLUSION

The Regulations providing for mandatory display of details of the sugar content and salt content on food packaging has been raised as a concern by some packaged food companies. However, a detailed display of such ingredients will aid consumers in taking an informed decision.

[1]https://www.fssai.gov.in/upload/notifications/2020/12/5fd87c6a0f6adGazette_Notification_Labelling_Display_14_12_2020.pdf

[2] https://economictimes.indiatimes.com/industry/cons-products/food/packaged-food-companies-request-fssai-to-keep-some-products-out-of-front-of-pack-labelling-regulations/articleshow/81311411.cms?from=mdr#:~:text=Sign%20in-,Packaged%20food%20companies%20request%20FSSAI%20to%20keep%20some%20products,front%2Dof%2Dpack%20labelling%20regulations&text=The%20authority%20in%20December%20notified,panel%20in%20bigger%20font%20size

[3] https://www.fssai.gov.in/upload/notifications/2020/12/5fd87c6a0f6adGazette_Notification_Labelling_Display_14_12_2020.pdf

[4]https://www.fssai.gov.in/upload/notifications/2020/12/5fd87c6a0f6adGazette_Notification_Labelling_Display_14_12_2020.pdf

[5] https://www.amazon.in/Haldirams-Snacks-Bhel-Puri-200g/dp/B01H1WZ5BI

[6] https://www.amazon.com/Maggi-Masala-2-Minute-Noodles-India/dp/B00MXAY92A

[7] Regulation 3(b) of 2020

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