All food products sold in India that is prepackaged are required to comply with the Food Safety and Standards (Packaging and labelling) Regulations, 2011. The Food Safety and Standards Regulation, 2011 is a notification issued by the Food Safety and Standards Authority of India under the Ministry of Health and Family Welfare. In this article, we look at the regulations pertaining to food labelling in India.
Applicability of Food Labelling Regulations
The food labelling regulations require all “Prepackaged” or “Pre-packed food” to comply with the labelling regulations in India. As per the rules, prepackaged food means food, which is placed in a package of any nature, in such a manner that the contents cannot be changed without tampering it and which is ready for sale to the consumer.
General Labelling Requirements
The following labelling requirements must be complied with by all prepackaged food sold in India:
The label must be in English or Hindi or Devnagri language. In addition to the above, the label can contain information in any other language, as required.
The label must not contain information about the food that could be deemed to be false, misleading, deceptive or otherwise create an erroneous impression regarding the product.
The label must be affixed to the container in such a manner that it would not easily be separated from the container.
The contents or information presented in the label should be clear, prominent, indelible and readily legible by the consumer.
If the container is covered by a wrapper, then the wrapper must contain necessary information or make the label of the product inside readily legible by not obscuring.
The name of the food must be mentioned along with trade name and description of the food contained. In case the food contains more than one ingredient, then a list of ingredients must be presented in descending order of their composition by weight or volume, as the case may be, at the time of its manufacture;
In addition to the above, there are various regulations concerning labelling that apply to various types of pre-packaged foods. Hence, its important to consult a qualified FSSAI consultant about the label, prior to launch.
Nutritional Information or nutritional facts per 100 gm or 100ml or per serving of the product must be given on the label along with the following information:
energy value in kcal;
the amounts of protein, carbohydrate (specify quantity of sugar) and fat in gram (g) or ml;
the amount of any other nutrient for which a nutrition or health claim is made:
It is important to note that any “health claim” or “nutrition claim” or “risk reduction” claim made in the label will be throughly scrutinized by the FSSAI authorities. Hence, any such claim must be validated by test data. As per the rules the following is the definition for “health claim”, “nutrition claim” and “risk reduction” claim:
“Health claims” means any representation that states, suggests or implies that a relationship exists between a food or a constituent of that food and health and include nutrition claims which describe the physiological role of the nutrient in growth, development and normal functions of the body, other functional claims concerning specific beneficial effect of the consumption of food or its constituents, in the context of the total diet, on normal functions or biological activities of the body and such claims relate to a positive contribution to health or to the improvement of function or to modifying or preserving health, or disease, risk reduction claim relating to the consumption of a food or food constituents, in the context of the total diet, to the reduced risk of developing a disease or health related condition;
“Nutrition claim” means any representation which states, suggests or implies that a food has particular nutritional properties which are not limited to the energy value but include protein, fat carbohydrates, vitamins and minerals;
“Risk reduction” in the context of health claims means significantly altering a major risk factor for a disease or health-related condition;
Veg or Non-Veg Symbol
All packaged food that is “Non Vegetarian” must have a symbol that is a brown colour filled circle inside a square with brown outline. If a food contains only egg as non-vegetarian ingredient, then the manufacturer may provide a declaration that the product contains only egg and add the non vegetarian symbol.
Non Veg Symbol
Packaged vegetarian food should have a symbol that consist of a green colour filled circle inside a square with green.
Information Relating to Food Additives, Colours and Flavours
Food additives contained in the food product must be mentioned along with class titles along with the specific names or recognized international numerical identifications. Addition of colouring matter should be mentioned on the label along with certain statements like “CONTAINS PERMITTED NATURAL COLOUR(S)”, just beneath the list of the ingredients on the label. In case of addition of extraneous flavouring agent, then it should be mentioned in a statement like “CONTAINS ADDED FLAVOUR” just beneath the list of ingredients on the label.
Name and Complete Address of the Manufacturer
The name and complete address of the manufacturer must be mentioned on every package of food. In case of imported food, the package must contain the name and complete address of the importer in India.
All packaged food must carry the bet quantity by weight or volume or number, as the case may be. The net quantity of the commodity contained in the package must exclude the weight of the wrappers and packaging materials.
Lot Number of Batch Identification
A lot number or batch number or code number must be mentioned on all packaged food so that it can be traced while manufacturing and distribution. Only bread and milk including sterilised milk are not required to comply with this regulation.
Date of Manufacture or Packing
The date, month and year in which the commodity is manufactured, packed or pre-packed must be mentioned on the label. In case of food products having a shelf life of more than three months, then the month and the year of manufacture can be given with the “Best Before Date”. In case of products having a shelf life of less than three months, the date, month and year in which the commodity is manufactured or prepared or pre-packed must be mentioned on the label with best before date.
Country of Origin for Imported Food
For imported food, the country of origin of the food should be declared on the label of food. In case a food product undergoes processing in a second country which changes its nature, the country in which the processing is performed should be considered to be the country of origin for the purposes of labelling.
Instructions for Use
Instructions for use, including reconstitution, should be included on the label, if necessary, to ensure correct utilization of the food.