AIFPA urges serving-size-based thresholds for packaged-food warning labels
The All India Food Processors Association has asked the Supreme Court to align FSSAI warning-label thresholds with serving sizes, Indian dietary patterns, food-category differences and Codex practices, rather than per-100 gm/ml limits. The matter is due for hearing on September 10.
What happened
All India Food Processors Association (AIFPA) · AIFPA urged the Supreme Court to base FSSAI’s proposed packaged-food warning-label thresholds on serving sizes,
Key facts
- More than 3 gm of added sugar per 100 gm
- More than 2 gm of added sugar per 100 ml
- Food Safety and Standards (Labelling and Display) Regulations, 2020
- Dietary Guidelines for Indians, 2024
- Two-phase implementation proposed
- September 10
Why this matters
Acquirers should diligence target brands’ nutrient profiles by both per-100 gm/ml and realistic serving sizes, as a revised FSSAI regime could change compliance liabilities and valuation assumptions.
What to watch
- Supreme Court proceedings and any interim observations at the September 10 hearing.
- Whether FSSAI publishes revised draft regulations, technical notes or a consultation timeline for warning-label thresholds.
- Inclusion of mandatory serving-size standardization, category-specific thresholds or dual per-100 gm/ml and per-serving disclosures.
- Public-health interventions opposing serving-size thresholds on grounds of consumer comparability and manipulation risk.
- Final transition periods, stock-depletion allowances and enforcement dates for phased implementation.
- Competitor reformulation announcements, pack-size changes and front-of-pack health claims in high-risk categories.
- Model label exposure under per-100 gm/ml, per-serving and likely category-specific threshold scenarios for every major SKU.
- Audit declared serving sizes against actual consumption data; identify products vulnerable to allegations of artificially small serving declarations.
- Prioritize reformulation of products that trigger warnings under both methodologies, especially high-volume snacks, instant foods, beverages, sauces and children-oriented products.
- Build modular packaging artwork and procurement plans so front-of-pack warning panels can be deployed or revised quickly without excessive obsolete inventory.
- Engage FSSAI, industry bodies and public-health stakeholders with India-specific intake data, category evidence and practical serving-size proposals.
- Monitor retailer private-label portfolios, as they may use cleaner-label positioning to gain share if national-brand warning exposure increases.