More than 94% of packaged food products analysed in a study could attract at least one front-of-pack warning under proposed nutrient thresholds, according to an analysis cited by former Food Safety and Standards Authority of India (FSSAI) chief Pawan Kumar Agarwal.
Agarwal has urged the Supreme Court to consider a phased rollout of front-of-pack labelling (FoPL), arguing that applying the proposed final thresholds immediately could result in warnings appearing on a very large proportion of packaged foods and potentially reduce their ability to differentiate products based on nutrient concerns.
The analysis, commissioned by Agarwal's Food Future Foundation (FFF) and partly based on work by Hyderabad-based food data company NatFirst, examined the declared nutritional composition of 44,109 barcode records covering packaged branded foods available in India's retail market.
The analysis found that 94.1% of the records exceeded at least one specified nutrient threshold, while 5.9% did not exceed any of the thresholds. Among products classified as high in fat, sugar or salt (HFSS), 85.3% breached two or more thresholds, while 10.4% breached all four.
Agarwal's foundation has proposed beginning with less stringent interim thresholds and progressively tightening them over a period of three to five years, with the complete roadmap notified in advance. FFF has proposed making FoPL mandatory from July 1, 2027, followed by progressively stricter nutrient thresholds.
The intervention also recommends that a packaged food should carry a warning if even one nutrient of concern exceeds the applicable threshold. FFF has supported using added sugar rather than total sugar, while recommending added sodium adjusted for naturally occurring sodium and saturated fat rather than total fat as relevant warning parameters.
On warning design, the foundation has supported retaining red as the warning colour and proposed standardised warnings identifying the specific nutrient exceeding the prescribed limit, such as “High in sugar”, “High in sodium” or “High in saturated fat.” It has also called for separate monitoring of potential increases in preservatives, emulsifiers, artificial sweeteners and other additives that could result from product reformulation.
The issue is currently before the Supreme Court in proceedings concerning implementation of FoPL regulations. In its September 10, 2026 order, the Court asked FSSAI to respond to 12 questions covering issues including the proposed two-phase implementation, nutrient thresholds, sweetened beverages, warning design, warning dimensions, possible reformulation effects and the implementation timeline.
The Court directed FSSAI to file its response within 10 days and listed the matter for September 28, 2026. Therefore, the proposed warning thresholds and rollout timeline should not be treated as final regulatory requirements at this stage.
For dairy and food manufacturers, the proposed framework could have implications for product formulation, nutrition claims, packaging design and labelling compliance, particularly for products containing higher levels of sugar, sodium or saturated fat. Any commercial impact will depend on the final thresholds, regulatory notification and implementation timeline.
The debate illustrates the challenge of designing a front-of-pack system that provides consumers with clear nutritional information while establishing thresholds that can meaningfully distinguish products across India's diverse packaged-food market.
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