The new labeling norms in India

A very basic checklist for you to compare against your current labelling practices

What’s changed:

1. Mandatorily display use by or expiry date instead of “best before date”
2. Present nutritional information on the principal display panel in bigger font sizes 
3. Ensure that name of the food and vegetarian and non-vegetarian classification symbol is on the front of the pack with effect from January 1, 2022
4. FSSAI has defined the age of children for the food industry as below 18 years for the first time
5. The mandated requirements have to be displayed on eCommerce sites except batch number/ lot number, best before, use by date, expiry date, date of manufacturing/ packing

A contour of what your labeling checklist should carry:

• the name of the food on the Front-of-Pack
• list of ingredients – in descending order of their weight or volume
• additives
• specific titles for the ingredients. For eg: edible vegetable oil should be specified as mustard oil or groundnut oil or as the case may be.
  • Vegetable fat should be specified as interesterified vegetable fat, fractionated fat, hydrogenated oils, partially hydrogenated oils, or as the case may be.
  • Sucrose should be called sugar.
  • Cocoa solids to communicate cocoa beans or powder.
• percentage of ingredients by weight or volume
• nutritional information per 100 grams or 100 milliliters or per single consumption pack of your product – protein, carbs, sugars, added sugars, fats, sodium, vitamins and minerals if any
• number of servings
• percentage contribution to our recommended dietary allowance of 2000kcal
• declaration of vegetarian or non-vegetarian.
  • Brown color triangle inside a brown outlined box
  • Vegetarian is a green-filled circle with a green outlined circle. The specifications are outlined below

• FSSAI logo and license number of the manufacturer
• license number of the marketer or packer
• Organic logo, if applicable
• Fortified food logo, if applicable
• Net Quantity
• Retail Sale price
• Consumer Care details
• Batch number / Lot number
• Dates
  • of manufacturing
  • Expiry / Use by / Best before
  • to be communicated using DD/MM/YY format for products with a shelf life of up to 3 months
  • can be just the month and the year if shelf life extends beyond 3 months. Month to be in capital letters and should have at least the first three letters mentioned
• Storage conditions
• If imported
  • address of the importer
  • country of origin
• Instructions for use
• Food allergen declarations as “Contains…”
  • Cereals
  • Crustaceans
  • Milk
  • Eggs
  • Fish
  • Peanuts
  • Soy
  • Sulphite
• Use “May contain …” in case ingredients are bound to be present from cross-contamination
• Principal Display Panel should cover
  • 40% of the width and height if its a rectangular package
  • 40% of the height and average circumference if it’s cylindrical
  • 20% of the total surface area for any other shape
  • width of the letter or numeral shall not be less than 1/3rd of its height
  • these are the required heights of any numeral or letters that go onto the panel :

• Mandatory declarations like MSG, common salt, aspartame, and others mentioned in Schedule II of these regulations shall not be less than 3mm
• Products free of gluten should be labeled Gluten-free and closely placed near the brand name
• Organic logo bearers have to keep in mind the following requirements

The changes have to be adapted to from Jan 1, 2022

The earlier proposed key provisions, however, regarding color-coded labels to classify food products that are high in salt, fat and sugar and front-of-the-pack labelling are still not finalised.

How much of an impact are the new regulations going to create on your labels?

What challenges do you think you’ll face while adopting the new rules?

And how are you going about addressing them?

Credits: Taxguru.in | The Hindu Business Line