E-commerce platforms are required to provide for mandatory labelling of food product

Under the new Regulations when a food product is sold over an e-commerce platform or any other direct selling means, all mandatory declarations in the label are to be provided to consumers through appropriate means before sale except certain variable declarations like batch number/lot number, best before, use by date, expiry date and date of manufacturing/packing.

The Regulations, however, do not prescribe a specific mode of display or insist that these declarations are required to be separately provided in the portal but use the words “provided to the consumer through appropriate means”.

Name of the food to be provided on the front panel of the pack and not just brand name or trademarks alone

The new regulations prescribe that the name of the food which indicates the true nature of the food should be given on the front of the pack.

Allergen details to be provided on the label

According to the new regulations, the Allergen declaration is not required in the case of oils and distilled alcoholic beverages and also when the product by itself is an allergen.

Also, the FSSAI has now mandated food business operators (FBOs) to provide allergen information in the PDP if certain foods or ingredients like peanuts, tree nuts, cereals containing gluten, soybeans, milk, egg, fish, etc., are used during the preparation of the product. The Regulations also mandate a separate allergen warning even when ingredients present in the food could cause cross-contamination.

Contribution of nutrients used in the product to RDA to be given with nutritional information

The new regulations prescribe that an FBO should provide for a per-serve percentage of contribution to RDA of energy, fat, sugar and salt. The FSSAI has also given per day requirement of these constituents and mandates FBOs to calculate the percentage of contribution to RDA on the basis of 2000 kcal energy, 67 gm total fat, 22 gm saturated fat, 2 gm trans fat, 50 gm added sugar and 2000 mg of sodium (5 gm salt).

Introduction of new logos for non-veg food and food items not meant for human consumption

The old logo showing non-veg food items with a square having a brown colour filled circle is now replaced under the new Regulations with a brown coloured triangle inside a square with a brown outline.

In addition to the above, the FSSAI has also introduced a new symbol of a black colour cross inside a square of black outline to be shown in food materials sold in retail but not meant for human consumption.

Date of manufacture and time to be mentioned in meals served in Airlines/Railways and name of the brand owner, expiry date to be declared in packaged foods.

Labelling of packed meals

The new Regulations require packed meals served in airlines, railways and mobile catering units to mention the date of manufacture and time.

Brand owners details made mandatory in packaged food

The FSSAI has made it mandatory in packaged foods to declare the name and complete address of the brand owner.

Expiry date to be declared and best before alone will not suffice

Another major change under the Regulations is the mandatory provision for providing expiry date or use by date.

Restaurants to give calorific value, allergen information etc., in the menu cards

The Regulations stipulate that the foodservice establishments covered under the central licence (typically when operating in multiple States) or having outlets at 10 or more locations are now required to mention calorific value against food items displayed on the menu cards or boards or booklets in kcal per serving.

In addition to the above, these restaurants would have to provide details of allergens, veg/non-veg logo, nutritional information and certain warnings as specified in Schedule 2 to the Regulations.

Labelling of wholesale, industrial and institutional packs

The new Regulations also prescribe for labelling of non-retail packs like packs meant for wholesale, industrial and institutional distribution.

• As per the new Regulations, the FSSAI has prescribed the following eight declarations to be given on all non-retail packs viz.
• name of the food
• net quantity
• FSSAI logo and licence number
• date marking
• lot number
• name and address of the brand owner, manufacturer or packer
• the country of origin (if applicable)
• a statement mentioning that the container is not for retail sale.
• The declarations regarding –
• list of ingredients
• veg/non-veg logo
• nutritional information is to be provided in the non-retail container unless such information is provided in an accompanying document

Labelling of packaged food additives, fortified and organic food logo.

The New Regulations have a separate chapter providing for certain additional labelling requirements for packages containing food additives.

• Few Changes are
• For Nutritional Information on labels, saturated fat and trans fat should be given only if the total fat content is more than 0.5% in the final food and Cholesterol content should be given only for products containing fats of animal origin and when total fat is more than 0.5 %.
• Gum is exempted from mandatory nutritional labelling.
• Wheat-based Glucose syrup including dextrose, Wheat-based Maltodextins, Glucose Syrups based on Barley, Cereals used for making alcoholic distillates including ethyl alcohol is exempted from allergen labelling.
• Mandatory declarations for food articles containing Sweeteners.
• Every package of an admixture of edible oil should contain a declaration in bold stating “MULTI – SOURCE EDIBLE OIL”, in bold font just below the brand name.

The Regulations have also incorporated logos to be given in the label for fortified and organic food.