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Need, a sensible call on health labels

The Indian government has not taken a call to seal the health star ratings on packaged food to help Indians differentiate between the good, bad and ugly products in a $34 billion market.

This step taken by the government is praiseworthy and sends forth a strong message. The market could touch $150 billion in five years from now.

But the call has not happened, and industry advocates are working overtime to push the agenda against the health star rating (HSR) system that has already been chosen by the Food Safety and Standards Authority of India (FSSAI) as the best mode to understand the health qualities of the products sold in a nation coping with lifestyle diseases.

Some experts in India have opposed the use of the HSR model, arguing consumers might tend to take this as an affirmation of the health benefits rather than as a negative warning of ill effects. It is evident that there is a lack of awareness on star ratings related to consumer products in India. And then, the advocates have also argued that the HSR model, if implemented, will impact sales of certain food products.

But other experts argue that “warning labels” instead have been most effective in various countries. The HSR system adopted in countries like Australia and New Zealand has not resulted in any meaningful behavioural change. Even after eight years of their implementation, there is still no evidence of HSRs having a significant impact on the nutritional quality of people’s food and beverage purchases.

The ratings, which will be the first such in India, is aimed towards pushing the Indian consumers to opt for healthy foods. The HSR format ranks a packaged food item based on salt, sugar, and fat content and the rating will be printed on the front of the package. In India, packaged food has back-of-package (BOP) nutrient information in detail. But the product does not have FoPL which has the ability to nudge healthy consumption behaviour with respect to packaged foods.

The selection of the HSR system has not happened overnight.

The move follows a report by the Indian Institute of Management Ahmedabad (IIM-A) on the impact of front-of-the-pack labelling for packaged and processed foods. The IIM-A study endorsed the HSR format as the best suited to Indians in helping to choose healthier packaged food items under a new policy on Front of Packaging Labelling (FoPL). The IIM-A survey was conducted with samples from over 20,000 people across the country.

The FSSAI, a body under the ministry of health and family welfare (MoHFW) had asked IIM-A to conduct the survey to analyse major FoPL models available across the world and identify one which is easy to understand and can induce behavioural change among Indian consumers.

It was a unique study.

None of the countries in the world has surveyed people at such a large scale. It was after the study was completed and findings tabled, the FSSAI chose the HSR format some months ago.

But a final seal is yet to come from the government.

“IIM-A has recommended HSR as the most preferred format by Indian consumers under proposed FoPL in India. FoPL will bring a transformational reform in the society as it will encourage healthy eating. It will also help to reduce the burden of Non- Communicable Diseases (NCDs) in the country,” says Arun Singhal, Ex chief executive officer, FSSAI.

Countries such as the UK, Chile, Mexico, New Zealand, and Australia have FoPL.

The FSSAI has now sought feedback from industry associations for evaluation by a scientific panel so that the HSR model can be included in the draft regulation formulated by the government.

The food regulator has exempted milk and dairy products from the proposed FoPL, as they were in the earlier FSSAI draft notified in 2019. Also, the scientific panel has recommended voluntary implementation of FoPL from 2023 and a transition period of four years for making it mandatory.

Singhal said FSSAI will analyse the nutritional information present in 100 mg quantities of packaged foods. The FSSAI will issue a HSR certificate wherein a licensee can put in details of their product. Based on evaluation, HSR certificate will be issued for the respective packaged food item.

Over the last year, the apex food regulator has been brainstorming with experts to launch FoPL in India. A petition seeking direction from the government to frame guidelines on HSR and impact assessment for food items and beverages was filed in the Supreme Court in June last year.

Earlier this year, representatives from IIM-A and Dexter Consultancy made a detailed presentation before the FSSAI revealing the findings of the survey. The meeting was attended by members from industry associations, consumer organisations, scientific panel on Labelling and Claims/Advertisement, and the World Health Organisation (WHO).

“Based on the analysis of the data, IIM-A recommended HSR over other models for achieving a careful combination of the dual objectives for the ease of identification and understanding; and change of purchase behaviour of Indian consumers,” said the minutes of the meeting.

Three major decisions were also taken on setting up thresholds and the number of categories, type/format of FoPL, and a time period for transition from voluntary to mandatory. The FSSAI noted that the proposed levels of thresholds are in alignment with ‘FoPL Models’ implemented in other countries and ‘WHO Population Nutrient Intake Goals Recommendations’.

So what is the big issue?

In India, packaged food has back-of-package (BOP) nutrient information in detail but no FoPL. If FoPL is there, it can easily nudge people towards healthy consumption of packaged food and influence purchasing habits. The IIM-A study endorsed the HSR format, which speaks about the proportions of salt, sugar, and fat in food that is most suited for consumers.

This is important, ostensibly because in India, a lot of consumers do not read the information available at the back of the packaged food item. And then, India has a huge burden of non-communicable diseases that contributes to around 5.87 million (60%) of all deaths in a year. Hence, HSR will encourage people to make healthy choices and could bring a transformational change in the society.

So what category of food items will have HSR? All packaged food items or processed food will have the HSR label. This will include chips, biscuits, namkeen, sweets and chocolates, meat nuggets, and cookies. However, milk and its products such as chenna and ghee have been exempted as per the FSSAI draft notified in 2019.

The star star rating system will help consumers in making informed choices. The HSR signature provides a quick, easy to comprehend way to compare similar packaged foods and hence empower the consumers to take the decision aptly about what is right for them. The basic principle is: More the stars, the principle being very simple – “more the stars, healthier the choice.”

Scientists have conducted studies to conclude that HSR takes into consideration, not only the Nutrients to Limit (Saturated Fat, Sodium, Sugar etc.) but also the Nutrients to Encourage (protein, fibre, fruits, vegetables etc.) and hence the ultimate stars on labels represent the overall usefulness score of the product in a very simple understandable way.

Hence, HSR is underpinned by scientific principles of nutrition which considers the holistic composition of the food. This way it has an advantage over formats which are based on only nutrients to limit. Unlike several other FOPL signatures, HSR doesn’t create a caution in the minds of the consumers regarding pre-packaged foods. It summarises the nutritional quality of foods and enables consumers to make informed choices and opt for healthier eating choices.

It is all about the Indian consumers.

In India, consumers are used to comprehending stars as a similar practice. It has worked in the air conditioning industry and other electronic devices for several years. The highest star rating of an air conditioner or any electronic device is 5, and the lowest star rating is 1. This is the same trend that will appear in HSR where star 5 would be the best product to choose, while 1 the least.

Similarly, consumers in India, who even if not used to staying in hotels, use the star rating of hotels in their day-to-day conversation and hence are fully aware of the concept. In short, HSR can be understood by a person who doesn’t know how to read English or any of the languages. On the contrary, for understanding the warnings statements, one must read English and should have acquired prior understanding of what colours, or signs signify.

And then, India is probably the only country where green circle or brown triangle signatures are mandated for all foods already, depicting vegetarian or non-vegetarian nature of these foods.

Having similar signatures additionally like traffic lights with Red, Green and Yellow colour will create confusion amongst the consumers.

The scientists have argued that a large section of Indian consumers may wrongly interpret the red dot of the FOPL sign as non-vegetarian, which will create unnecessary issues.

Can the government take the call quickly and ignore the advocates? Let’s wait and see.

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Disclaimer

Views expressed above are the author’s own.

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