World Consumer Rights Day 2022: Why India should adopt warning labels on food products

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India is facing a rapidly escalating public health crisis of non-communicable diseases (NCDs) with millions suffering from diabetes, cancer, and cardiovascular disease. In the Comprehensive National Nutrition Survey (2016-2018), more than half of the children and adolescents (5-19 years) had biomarkers indicating a substantial NCDs risk burden. 

Consumption of ultra-processed foods (UPFs), which are intrinsically unhealthy, is rising, and is a central cause of the rapidly escalating burden of obesity and associated NCDs. Robust evidence indicates that the increasing consumption of Ultra-Processed Foods (UPFs) is associated with over-eating, obesity, type 2 diabetes, cancers, cardiovascular diseases, and all-cause mortality. 

The Government of India is working towards policy formulation to address this issue and came up with a decision taken by FSSAI in a meeting of Stakeholders on Front of Pack Labelling (FOPL) on unhealthy food packets based on an IIM-A study. The IIM-A study accepted Health Star Rating (HSR) as the most preferred method of FOPL. 

Countries like Australia and New Zealand have adopted the Health Star Rating (HSR) which is receiving flak within the country and across the globe for its pro-industry nature. According to public health experts and scientists from Australia and world, HSR could be misleading and controversial as it led to providing more stars to foods that don't deserve to be called healthy or are explicitly unhealthy.  HSR is said to be creating a ‘health halo’ which is misleading for the consumer, as the type of food processing that leads to synthetic foods is not considered harmful by it. The HSR modelling, therefore, is fundamentally flawed.

Concerned with this development, the public health experts and scientists from India are opposing the decision of choosing HSR as the FOPL for India. According to them choosing HSR label instead of warning labels will not help consumer choice, and its high threshold levels for salt, sugar and saturated fats leaves unhealthy foods starred as healthy.

On the other hand, 'warning' labels are extensively used around the world since they are straightforward and effective in notifying consumers. Many countries including Brazil, Chile, Canada, France, Israel, Mexico, Peru, UK and Uruguay have initiated actions in this direction and have adopted and implemented Warning Labels as the front of pack labelling (FOPL).

In India, such symbol-based and nutrient-specific warning signs should be implemented to help overcome literacy and language barriers. The HSR system, on the other hand, will do more harm than good if it is adopted. Not only does it have the ability to fool the general population but bad food can be passed off as good food, causing harm to customers and exacerbating the NCD problem.

This discussion can be well framed under the ambit of Consumer Rights in India. The Right to Safety, the Right to be Informed and the Right to Choose and Right to Consumer Education are intrinsic parts of Consumer Rights in India. Front of Pack Labelling should be in line with all these rights. Consumers have the right to know about the short-term as well as long-term consequences of consuming UPFs. Corporations should not be allowed to mislead consumers and make profits by risking their health and wellness. 

There are many laws, including The Consumer Protection Act, 1986 (COPRA) and The Prevention of food Adulteration Act, 1954, in place but many consumers are still not well aware of these legal protections. The ‘Jago Grahak Jago’ campaign has helped put the spotlight on consumer rights in India, mainly through television and radio ads. It even has a dedicated helpline and website to help consumers, but Consumer rights awareness becomes tricky when buying food items without warning labels; this is because the layperson may not be acquainted to understand food products with high sugar, salt and trans fats and may make unhealthy choices. This may lead to irreversible health consequences.

This is where implementing Warning Labels on unhealthy food items, along with conducting awareness campaigns on why certain contents in food are not good for consumption, will help the new generation. It has to be noted that these Warning Labels should comprise easily-readable and understandable text, graphics and images that are prominent. They should not be hidden away in a corner or not be noticeable. India certainly boasts of having a younger population than say countries like Japan, but if India’s youth is not healthy, what is the point?

Therefore, it will be scientific to choose Warning Labels as FOPL in the larger public health interest of curbing consumption of high sugar, salt and fat and ultra-processed to reduce the NCDs burden globally.

Written By Nupur Bidla, PhD Scholar, Social Work, Nutrition Advocacy in Public Interest in India (NAPi) Member