The Warning Label Needs a Warning

'Eat food. Not too much. Mostly plants.' — Michael Pollan There is something wonderfully optimistic about a food packet. Read the wrapper and you are promised energy, goodness, fibre, vitamins, happiness and even a life-changing experience, sometimes involving chocolate. But what of the inconvenient truth, which is printed somewhere behind all the optimism, in tiny letters and tinier numbers? For years, consumers have been expected to navigate this nutritional minefield on their own. Calories, carbohydrates, fats, sodium, serving sizes, percentages and ingredients compete for attention, while the front of the packet cheerfully announces that the contents are 'natural', 'light', 'zero sugar', 'multigrain' or otherwise virtuous. Now, finally, there may be some adult supervision. The Red Hexagon The Food Safety and Standards Authority of India (FSSAI) has proposed prominent red, hexagonal warning labels on packaged foods high in sugar, salt or fat (HFSS). The move follows months of judicial pressure, culminating in the Supreme Court directive that the Government move on front-of-pack warnings, rather than continue debating the matter. It is a welcome move. But welcome is not the same as unquestionable. To FSSAI's credit, under CEO Rajit Punhani's stewardship, the regulator has shown a welcome willingness to bring greater transparency to a food market that has long been far too comfortable with confusing consumers. The whole point of a front-of-pack warning is to simplify information. A consumer should be able to look at a packet and understand, instantly, whether it contains unusually high levels of something he or she might reasonably want to limit. That is what the red hexagon promises. The Fine Print The problem, as always, lies in the small print. Under the proposal's first phase, a warning would be triggered when a product is high in two or more of the three nutrients of concern. That means a product exceptionally high in sugar could escape a warning if it happens to be below the threshold for salt and fat. The same logic could allow a very salty product to pass without the red flag. This is an odd way to construct a warning system. A danger does not become less dangerous because another danger is absent. The second phase is meant to address this by extending the warning to products high in any one of the specified nutrients. But there is no binding timeline for when that phase will begin. A temporary arrangement is understandable. An indefinite one is not. And there is a larger principle at stake—the purpose of front-of-pack labelling is not to produce more information. India already has plenty of that. Its purpose is to make important information impossible to miss. FSSAI Steps Up FSSAI's Punhani, in a recent interview, was equally measured on palm oil, an ingredient that has become something of a nutritional villain. His point was that palm oil—or any other oil for that matter—when it meets prescribed standards, is not inherently unsafe; what matters is how much is consumed and the nutritional character of the food in which it is used. In Parliament during the Monsoon Session, Union Minister Prataprao Jadhav made essentially the same point, saying palm oil is a standardised edible fat permitted under FSSAI regulations and subject to scientific and Codex-based standards. Manufacturers, he added, must identify the specific edible oil used, rather than hide behind the generic term 'edible vegetable oil'. That is the balance a good labelling regime should seek. Consumers should not be frightened into believing that the mere presence of plant-based oils makes a pack of chips poisonous. Nor should a product escape scrutiny because its packaging is clever enough to make its less desirable nutritional characteristics inconspicuous. The ingredient is not the whole story. The product is. The Consumer Test This is where the proposed red hexagon matters. A consumer buying a packet of biscuits should not need to conduct a forensic examination before discovering that it contains excessive sugar. A parent buying a drink for a child should not have to decipher a table of numbers while standing in a supermarket aisle. A warning label is supposed to do the heavy lifting. Sure, there is a legitimate argument for getting the thresholds right. Industry, meanwhile, will worry about reformulation costs, traditional foods being unfairly caught and the possibility that too many warnings could make the system meaningless. Those concerns deserve a hearing. Regulation works best when it is scientifically defensible, predictable and practical. But there is another stakeholder whose voice must not disappear in the technical debate: the consumer. For years, the packaged-food industry has been remarkably adept at telling consumers what is inside a packet without necessarily telling them what that means. A red hexagon can change that. But only if it is allowed to do its job. If a product is high in sugar, it should say so. If it is high in salt, it should say so. If it is high in fat, it should say so. A warning should warn. It should not make the consumer wait for a second danger before acknowledging the first. India has taken a significant step. It should now have the confidence to make that warning meaningful. Views expressed are personal. The writer is a journalist & communications specialist