Advocacy with Standing Committee on Health and Family Welfare on FOPL

Today PVCHR delegates Mr. Abhishek Pratap ji and Mr. Abhimanyu Pratap met with Dr. Chandrasen Jadon (Ayuvedacharya), Member of Parliament - Firozabad. He is Member, Standing Committee on Health and Family Welfare, Member, Consultative Committee, Ministry of Road Transport and Highways, Member, Standing Committee on Health and Family Welfare and also Member, Consultative Committee, Ministry of Road Transport and Highways. The delegation submitted the memorandum for supporting strong and mandatory FOPL with warning label. He agreed to send D.O letter to Health Minister. He also said for participating in the 16 May event.

 PVCHR already submitted to Prof. Ram Gopal Yadav jee. Please find submission as follows: 

  Prof. Ram Gopal Yadav (MP),

Hon’ble Chairman,

Parliamentary Committee on Health and Family Welfare. 

Bungalow No.8-A, Lodhi Estate,

New Delhi -110003 

Subject: Urgent need of implementing mandatory ‘front of pack health warning labels’ on all the packaged foods in India by FSSAI. 

Dear Prof. Yadav, 

Greetings from PVCHR.                         

 As you know, PVCHR is a leading human right organization headquartered in Varanasi and working for last 25 years on empowerment of the marginalized and vulnerable population, particularly with women and girl children. 

In India the prevalence of Non-Communicable Diseases is at alarming level and the obesity rate is 40 percent. India has the second-highest number of children suffering from obesity in the world, with 14.4 million obese kids. The obesity above 40 years of age is 46 percent and among college educated group obesity is 45 percent. In India diabetes is also on the rise and will increase from 77 million populations in 2019 to 101 million population in 2030. The prevalence of high blood pressure disease is 31 percent in India. 68% of Indian ultra-processed food products have excess salt, sugar and only 32% of food products are within the scientific thresholds recommended by WHO regional standards. Retail value of packaged junk food and soft drinks in India grew by 42 times in just 13 years.

Amidst the above situation, WHO recommends implementation of front of pack health warning labels (FoPL) as one of the ‘best-buy’ measures to control the NCDs, since FoPL readily informs consumers about the harmful food ingredients in the packaged foods product and provides simplified nutritional information in the form of symbols, colors or words. FoPL was at first recommended in 2014 by expert committee constituted by FSSAI in 2013. In May 2018, FSSAI published a draft Food Safety & Standards (Labelling & Display) Regulations, 2018. In 2019, FSSAI issued draft notification Food Safety Standards (Labelling and Display), Regulations, 2019. In 2019 December, FSSAI delinked FoPL from general labelling regulations.

 We hope you are aware that Food Safety and Standards Authority (FSSAI) is currently developing a Front-of-Pack Labelling on the unhealthy food products and has decided to include ‘Health Star Rating’ in the draft regulation as indicated in the minutes of the stakeholders meeting of 15th February, 2022. Being aware that diseases like diabetes, cancers and heart attacks constitute majority of annual deaths in India, and the strong association of ultra-processed unhealthy diet with such diseases, we believe that to minimize the burden of NCDs, the reduction of rising consumption of unhealthy food products is pivotal. The current scientific evidence favours an urgent action on the FOPL front, with an unambiguous preference for warning labels, that too mandatory and not voluntary, particularly in setting like India where the literacy levels are sub-optimal. The evidence does not support adoption of the Health Star Rating FOPL.

 We would like to submit the following key scientific evidence on these issues as below.

• A higher consumption of ultra-processed foods (>4 servings daily) was independently associated with a 62% relatively increased hazard for all cause mortality

https://www.bmj.com/content/365/bmj.l1949

 • A recent meta-analysis of studies on the association between ultra-processed food intakes with all-cause mortality showed that compared to low consumption, high consumption of UPF increased death risk by 29%. 

 https://pubmed.ncbi.nlm.nih.gov/35231930/

 • A meta-analysis of five experiments assessing the effects of Health Star Rating (HSR) labels on sales found no significant effect on calories or sugar consumed; similarly, combined findings from three research indicated no impact on saturated fat or salt purchased.

 https://onlinelibrary.wiley.com/doi/epdf/10.1111/jhn.12758

 • In a systematic review, evidence from interventions on the effect of front-of package (FOP) nutrition labeling on food purchases showed that 3 studies on health star ratings did not reveal an effect on food purchases compared with the control.

 https://pubmed.ncbi.nlm.nih.gov/33517247/

 • The most effective label in reducing perceived healthfulness was HIWL ('High-in' Warning Labels), which communicates clear, non-quantitative messages about high levels of nutrients of concern and demonstrated the greatest efficacy in reducing the perceived healthfulness of a sweetened fruit.

https://pubmed.ncbi.nlm.nih.gov/34726144/

 The FSSAI’s decision is based on a report by IIM using health star rating. However, recent evidence from two more national studies done by IIPS Mumbai, and more than 10 AIIMS, unambiguously found warning labels to be superior in reducing intention to purchase harmful foods. We, therefore strongly recommend the following based on scientific evidence.

 1. Front-of Pack Labeling urgently as a strong measure to curb the consumption of unhealthy food products.

2. Warning labels should be used as preferred and mandatory choice for this purpose and should be included in the relevant FSSAI Regulation.

PVHCR has been part of consistent advocacy for last two years for earliest and consumer friendly FoPL notification by FSSAI.

So this is our humble request to you as a chairman of the Parliamentary Committee on Health and Family Welfare, please look in the matter and ask the FSSAI to present the scientific evidences and scientific threshold limits of Fat, Sugar and halt in the packed foods products, before the parliamentary Committee, so that Hon’ble members can provide the guidance on this issue of public interest.

PVHCR team will be happy to present the matter personally in front of you and your Committee members for your better understanding of the issues and addressing this grave concern of health of common people in India.

 Looking forward for your kind guidance and pro-active steps in this regard

 With regards,

Lenin Raghuvanshi