The story so far: The Centre for Science and Environment (CSE) unveiled a new study this week which showed that salt and fat in an array of “junk food” was well above proposed regulatory thresholds. The packaged and fast foods analysed were chips, savouries, pizzas and burgers that are widely available in restaurants and other commercial outlets. This is not the first time that the CSE has conducted such research. However, the findings are significant as the Food Safety and Standards Authority of India (FSSAI) is yet to make into law draft regulations on setting limits, and publicising information, about nutrients in fast and packaged foods.
How did the Centre for Science and Environment (CSE) conduct the study?
Its Environment Monitoring Laboratory tested salts, fat, trans-fat and carbohydrates in 33 foods using 14 samples of chips, savouries, instant noodles and instant soup. There were also 19 samples of burger, fries, fried chicken, pizza, sandwiches and wraps, sourced from grocery stores and fast food outlets in New Delhi. The pizza, burgers, chips and snacks to be tested were stored in laboratory conditions and ground to a powder or paste. Then they were chemically analysed to determine the salt, fat, trans-fat and carbohydrate levels. The aim was to find out the levels of these products in actual servings/packets of the foods.
How was it established that these nutrients were above thresholds?
To calculate this, the organisation relied on the concept of the recommended dietary allowance (RDA), a daily ceiling on the amount of salt, fat, carbohydrate and trans-fat. The RDA is based on scientific consensus and has been agreed upon by expert bodies such as the World Health Organization (WHO) and the National Institute of Nutrition (NIN), Hyderabad (in India). It says that, ideally, an adult should consume no more than 5g of salt, 60g of fat, 300g carbohydrate and 2.2 g of transfat every day. Further, the RDA from breakfast, lunch and dinner should not be more than 25% and that from snacks (assumed to be those munched between meals), must be no more than 10%. Thus, a snack should ideally have no more than 0.5g of salt and 6g of fat.
What is the law on disclosing nutritional components?
Current Food Safety and Standards (Packaging and Labelling) Regulations, 2011 only require companies to disclose energy (kilo calories), protein, carbohydrates, total fat, trans-fat and saturated fat contained per 100g or per millilitre or per serve. It is not intuitively easy, without some mental math, to figure out how much is actually contained in your serving. There are also no disclosures on high salt content and added sugar, and no compulsion on companies to disclose nutritional information on the front of the pack. In 2013, the FSSAI, the apex food regulator under the Union Health Ministry, set up a committee to regulate packaged snacks. This committee, which consisted of doctors, nutrition experts, public policy activists and the CSE itself, recommended in 2014 that information on calories, sugar, fat, saturated fat and salt be displayed upfront. In 2018, the FSSAI came up with a draft law, the Food Safety and Standards (Labelling and Display) Regulations, 2018. The draft recommended that a packet should have clear information on how much each nutrient, such as salt, sugar, contributed to the RDA. The draft said salt must be declared as sodium chloride for instance, and that those ingredients which breached the RDA should be marked in ‘red’.
Food companies had reservations mainly because they felt ‘red’ signified danger, fearing that this would give consumers the impression that they were consuming toxic food. The draft regulations never became law. Instead, a third committee was formed, headed by B. Sesikeran, a former director of the NIN. Based on this committee’s recommendations, a new draft (Draft Food Safety and Standards (Labelling and Display) Regulations, 2019) was prepared. This replaced sodium chloride with salt, total fat with saturated fat and total sugar with added sugar, which CSE says, dilutes information on the health harm posed by packaged foods. The new draft also exempts beverages less than 80kcal. In theory, a beverage can breach “added sugar” RDA without informing consumers as long as it is within the energy requirement. The proposed law allows companies three years to adjust to the new laws. However, the contribution of each individual nutrient to the RDA and whether it is breaching safe limits will have to be displayed on the front of the package. Though the draft regulations have been out in the public domain since July, it is yet to become law. The CSE’s calculations are based on recommended nutritional values in the draft versions of these laws.
Why is industry opposed to the proposed laws?
Other than the red labels, the industry says the norms are unscientific and that packaged food is made to cater to the “taste” of people. Moreover, the packaged industry argues, immense quantities of junk food — think samosas or fried food sold on unregulated pushcarts — are consumed in the country with no check on their nutritional status and there is an inherent unfairness in regulating one section alone. Because nutritional information only guides consumers on how to regulate their intake, the industry feels people should be advised on what makes a healthy diet, the role of exercise and consuming appropriate amounts of food. They claim the current regulations only contribute to fear-mongering.
Why has not the Food Safety and Standards Authority of India (FSSAI) moved on the draft?
A top FSSAI official told The Hindu that nearly 700 comments had been received on the 2019 draft and there were thorny issues to be resolved. To brand packaged food in different colours sends out the message that they are unsafe or “toxic”; this would be counterproductive to the larger aim of having a regulated but viable packaged food industry and people being educated about their food choices. Pawan Kumar Agarwal, CEO, FSSAI said he did not agree with the CSE’s analysis and that there was still considerable work to be done on establishing appropriate “thresholds” (for salt, fat, etc) for India. He said regulation is “inevitable” and there would be more scrutiny of nutrient levels but in a way that would give packaged food companies time to adapt to stricter norms.
What is the practice internationally?
The CSE says that the proposed labelling regulations publish too many numbers and an assortment of colour codes. This could potentially confuse people particularly because India has a vast non-English speaking population. Chile, for instance, has a system where a black hexagon in a white border appears on the front of a package. In the hexagon is a phrase that says a product is “high in salt” or “high in trans-fat.” The more the hexagons the less desirable the product becomes for the consumer; surveys suggest that even children are becoming more conscious about the health impact of their favourite snacks and often influencing parents’ buying choices. Surveys undertaken by the WHO show that a vast majority of European countries have some form of front-of-pack labelling, but fewer countries have interpretive systems which explain the health factor of foods.
