FSSAI’s nutrition labelling mandate sends FMCG brands back to the design & packaging drawing board

The Food Safety and Standards Authority of India (FSSAI) passed a rule on July 7, 2024, directing fast-moving consumer goods (FMCG) organisations to write the sugar, salt, and fat content in a larger font and in bold.

In an official statement, FSSAI announced it has approved “a proposal to display nutritional information regarding total sugar, salt, and saturated fat in bold letters and relatively increased font size on labels of packaged food items.”

The change to the Food Safety and Standards (Labelling and Display) Regulations, 2020, regarding nutritional labelling was approved during the 44th meeting of the Food Authority, led by Apurva Chandra, chairperson, FSSAI.

The decision was lauded by Revant Himatsingka, also known as Foodpharmer on social media. He took to LinkedIn and shared that this change will make it easier for Indian consumers to spot junk foods and not fall for marketing gimmicks.

The amendment will help consumers understand the nutritional value of the products they buy so they can make healthier choices, according to the regulator. The draft notification for the change will be made public to get feedback and objections.

This move also emphasises the importance of balancing consumer information with brand image. Usually, ingredients are listed on the back of the package, while brand imagery is shown on the front. Some brands make the back of the package transparent, but not all brands use this space effectively for branding.

Talking about strategies that brands can adopt to comply with the new labelling requirements without negatively impacting their identity, Gaurav Manchanda, founder and managing director, The Organic World, an Indian organic and natural retail store, shares that a critical strategy for FMCG companies and even retailers is to get a sense of what is in the consciousness of consumers at this stage. This is something that consumers are interested in and not something that has been pushed on them. What consumers are looking for is trust in their food.

“The food should truly be what it says. If trust is with consumers, it only helps the brand and its profit. So it is in line with what consumers want at this point and adhering to those needs,” he says.

Shekhar Badve, founder and director, Lokus Design, a design consulting company, adds that this is a great chance for brands to showcase products’ strengths or efficacies more boldly.

"How creatively one uses that space and how the packaging graphics could be done differently is something that design companies can explore," he comments.

Atul Garg, managing director, GRM Overseas, a basmati rice exporter company, emphasises utilising creative layouts, such as infographics, icons, and QR codes as they help present information clearly and attractively, ensuring essential details without overwhelming the consumer.

“Brands should leverage technology to enhance the balance between information and visual appeal. By incorporating digital elements like QR codes, consumers can easily scan to access detailed nutritional information and health claims online. This approach allows the physical label to remain clean and visually attractive while still providing comprehensive product information,” he adds.

Will new packaging bring loss in business?

With the new mandate and labels comes a new packaging style. This also imposes a responsibility on brands to adopt new styles of labelling and packaging to ensure transparency in providing information.

Deepti Karthik, founder, Decision Pinnacle, a marketing consultancy firm, states that all packaging procurement will be at a halt until the guidelines become clearer.

This could lead to supply chain pressures across the board, and companies may face missed opportunities due to blackout in some areas.

“Most companies will opt for phased rollouts targeting modern trade, quick commerce, and urban areas first, followed by tier-2 and tier-3 towns, with rural areas being the last priority to ease pressure on the supply chain,” she says.

On the other hand, Garg explains that introducing a new style of packaging to comply with labelling requirements may involve initial costs, but it does not necessarily mean brands will incur huge losses. This transition presents an opportunity for brands to enhance their image, build consumer trust, and potentially attract a broader market segment.

“The investment in packaging redesign can be seen as a strategic move towards long-term sustainability and consumer satisfaction, creating a unique brand identity in the overcrowded market,” he adds.

Font size

The font size needed to describe essential elements on the packet has not yet been shared by the regulator. Brand and design experts believe that the font size should be around 3-4 points to highlight areas such as calories, sugar, fat, and other key macro elements of a product.

Manchanda suggests that a reasonable minimum font size should balance visibility and practicality for packaging design. Considering factors such as the size of the packaging and the amount of information to be displayed, a minimum font size of around 8.5 to 10 points is appropriate.

Karthik adds that fair practices are necessary to allow consumers to make informed choices about which product they want to buy, and manufacturers should be held accountable for transparency. She also advocates for a standardised font size of 8 points across all pack sizes by brands.

She calls for a standardised font size of 8 points across all packaging sizes by brands and highlights the necessity to introduce a system similar to Europe's Nutri-Score in India.

"As per Wikipedia, Nutri-Score is a five-colour nutrition label and nutritional rating system, aimed at simplifying the nutritional rating system to demonstrate the overall nutritional value of food products. It assigns products a rating letter from A (best) to E (worst), with associated colours from green to red. It is high time we implemented this in our country," she remarks.

While the mandate is yet to open to suggestions, brands are already anticipating what is in store for them. Manchanda says that there might be considerations in terms of cost and declarations. Certain products and brands would need a much longer time cycle to exhaust their stock, refresh their inventory, and introduce new packaging.

“To move in the right direction, we will have to take some of these steps and need to get all the stakeholders around the table to conduct pilot studies so that everything is clear and we can make long-term plans,” he shares.

Badve adds, “Most brands might have concerns over the format and sizes of packaging. They would likely provide feedback and attempt to reason with the FSSAI rather than negotiate.”