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Front-of-Pack Labelling: Designing Regulation for a Healthier Food Environment
The conversation around front-of-pack labelling (FoPL) has moved beyond the question of whether consumers need more information on nutrition. The discussion should focus on designing a regulatory framework that positively influences both consumer behaviour and the food environment.
Non-communicable diseases (NCDs) account for a substantial share of mortality in India. Diets high in salt, sugar, saturated and trans fats are associated with increased risk of NCDs. To increase awareness among the population, the Food Safety and Standards Authority of India (FSSAI) has proposed a front-of-pack warning label for packaged food products that exceed the threshold for nutrients of concern. The proposed warning labels would be red and hexagonal in shape, displaying warning signs “HIGH FAT”,”HIGH SUGAR”, “HIGH SALT”.
A warning label system is more like a binary signal, which gets triggered only when the defined threshold is crossed. The conventional back-of-pack nutritional information puts the burden on the consumer to locate, read and interpret nutritional information while purchasing the product. In this scenario, a front-of-pack label reduces the cognitive burden on customers. Nevertheless, the Supreme Court has questioned certain aspects of this intervention, given India’s linguistic and literacy diversity. It has also requested for clarity on the size, placement and visibility of the label.
FSSAI’s original proposal envisaged a two-phased roll-out process. The first phase would target the products, which exceed the specified threshold for at least two nutrients of concern. In the second phase, the warning labels will be added to any packaged good that contains at least one nutrient of concern exceeding the threshold. After the Supreme Court raised concerns about the rationale behind such an implementation process, FSSAI indicated openness towards single-nutrient warning labels without waiting for the second phase.
FoPL influences food environment through two very distinct mechanisms:
- Demand-side effect: Visible warnings can act as a behavioural nudge and influence consumers’ purchasing decisions.
- Supply-side effect: Anticipation of potential losses can incentivise manufacturers to reformulate the products to avoid displaying warning labels.
Thus, FoPL can serve as an intervention that aids informed decision making and encourages reformulation of packaged products by reducing nutrients of concern.
Since 2016, Chile has used black octagonal labels to identify products with high calories, salt, sugar and saturated fat content. A systematic review by Pan American Health Organisation (PAHO) shows that warning-label policies have shown positive changes in consumers’ purchasing behaviour and reformulation of products. Singapore’s Nutri-grade also provides a strong example of linking front-of-pack labeling with reformulation incentives. This system assigns grades from A to D on prepackaged products, with beverages graded C or D must display the Nutri-Grade label. A 2026 study found that after implementation of Nutri-Grade household sugar purchase dropped by 18% and average sugar content in packaged food products also declined by 21%.
This positions implementation design as a factor that shapes commercial determinants of health. Three parameters that are particularly important for this are, threshold (determines the affected products), size and placement (determines whether the warnings are noticeable or not), timeline (determines when the reformulation incentive takes effect). A longer transition time gives the manufacturers more time to repackage and reformulate the goods. At the same time, it delays the regulatory pressure on the manufacturers.
There are several questions that remain unanswered. These questions include whether there should be a specific threshold on total sugar or added sugar, how saturated and trans fats should be treated and whether the size of the label should change according to the size of the package. Furthermore, questions also remain around whether text-based warnings should be accompanied by pictorial symbols and how the labelling requirements should apply to packaged foods sold on e-commerce platforms. These concerns raise questions that are central to effective policymaking. The effectiveness of FoPL does not just depend on the addition of the warning labels. The effectiveness depends on the design and implementation of the policy as well. A warning label is effective only when it is scientifically justified, visually prominent, easy to understand to the consumers. Frances’s Nutri-Score is one such example. Nutri-score is a five-category system (ranging from A to E). It combines nutrients associated with health risks, as well as positive components.
FoPL, by itself cannot resolve India’s NCD burden. Dietary behaviour is shaped by many factors, which includes income, prices of products, availability of products, marketing, accessibility, culture among other things. That said, by making nutrition information more accessible and visible to the consumers, FoPL can address an important component of the wider food environment.
The Supreme Court proceedings provide an opportunity to get the regulatory and policy framework right. The question in discussion has shifted from what the front-of-pack warning label should look like to whether India’s food regulatory apparatus can deliver meaningful consumer information and create continuous pressure on product reformulation simultaneously.