Makes INR (Indian Nutrition Rating) Mandatory on FOPNL of Food Products

The Food Safety and Standards Authority of India (FSSAI) released a Draft Notification on September 14, 2022, amending the Food Safety and Standards (Labeling & Display) Regulations, 2020. These regulations may be called the Food Safety and Standards (Labeling & Display) Amendment Regulations, 2022. It shall come into force on the date of their final publication in the Official Gazette. Compliance shall be voluntary until 48 months from the date of final notification of these regulations and expected to become mandatory thereafter.

Below are the highlights of the amendment.

• The definition of Front-of-Pack Nutrition Labeling (FOPNL) and High Fat, Sugar, Salt (HFSS) food is added to the amended regulation.
• The name of ingredients used in the product shall be listed in the descending order of their composition by weight or volume, at the time of its manufacture; provided that the percentage of fruits, vegetables, nuts, legumes & millets, if present in the food product, shall be declared.
• Dietary fiber (g) shall also be declared for nutritional information per 100g or 100ml or per single consumption pack of the product
• Indian Nutrition Rating (INR) declaration on FOPNL forms a major part of this amendment.
• Below categories explains further how to display the INR
  • Baseline reference values and categories
    • For the purpose of Front-Of-Pack Nutritional Labeling (FOPNL), the baseline reference values for four (04) health risk increasing factors, i.e., energy, total sugars, saturated fat, and sodium per 100 g or 100 ml of the product; and the minimum percentage of positive nutrients viz., Fruit & Vegetable (FV); Nuts, Legumes & Millets (NLM), fiber, and protein are considered in the calculation for the rating of specific solid foods or liquid foods.
    • Further, all processed and packaged food products covered under the extant FSS regulations are classified into three (03) categories:
      • Category-I (Solid foods),
      • Category-II (Liquid foods)
      • Category-III (Exempted from FOPNL)
    • The system of pictorial display format shall be referred to as Indian Nutrition Rating (INR).
  • Pictorial Display Format
    • Every packaged food except those exempted from nutritional information under these regulations shall display the prescribed format (INR) on the front-of-pack calculated based on the contribution of energy (in kilo calories; kcal), saturated fat (g), total sugar (g), sodium (mg), and positive nutrients per 100 g of solid food or 100 ml of liquid food using the below formula:
    • Final INR score = (INR baseline points) – [(INR FV* points) + (INR NLM* points) + (INR P* points) + (INR F* points)]
    • Baseline points, FV points, NLM points, P points, and F points are further elaborated in the draft notification and have to be chosen based on the respective product category.

The INR system rates the overall nutritional profile for packaged food by assigning it a rating from half (½) star (least healthy) to five (05) stars (healthiest). More stars indicate that the food product is better positioned to provide for the daily human need for nutrients.

The format of the logo for INR is as indicated below:

• Generation of INR logo
  • The FBO shall submit their product’s relevant nutrient profile in the FoSCoS system for generating the respective INR score and the logo with or without the optional interpretive information.
• Food products with a milk logo, as specified under Food Safety and Standards (Food Products Standards and Food Additives) Regulation, 2011, shall be exempted from the purview of the HFSS definition.
• FSSAI has further introduced Schedule III and IV guidance on proper INR rating calculation and exempted foods lists.

In a nutshell, Food Business Operators (FBOs) must be prepared to adhere to these regulations for a compliant entry into the Indian market. To know more and talk to our experts, please reach out to us.