Support for Economic Survey 2024-25 Recommendations to Regulate Ultra-Processed Foods (UPFs) and Address Public Health Concerns
Rejoinder to NHRC Chairperson on behalf of PVCHR in case number case no. 4227/90/0/2021
Subject: Support for Economic Survey 2024-25 Recommendations to Regulate Ultra-Processed Foods (UPFs) and Address Public Health Concerns
Date: 4 February 2025
Dear Honorable Chairperson,
I, Shruti Nagvanshi, on behalf of the People's Vigilance Committee on Human Rights (PVCHR), would like to extend our full support for the Nutrition Advocacy in Public Interest (NAPi)'s commendation of the Economic Survey 2024-25. This survey marks a significant milestone in addressing public health concerns in India, particularly regarding the regulation of ultra-processed foods (UPFs) that are often high in fats, salt, and sugar.
The Economic Survey's recognition of the harmful impact of UPFs on both physical and mental health is a timely and necessary step. As the survey correctly points out, the increasing consumption of UPFs, such as sweetened breakfast cereals, soft drinks, chips, and energy drinks, is contributing to the rising burden of non-communicable diseases (NCDs), including obesity, diabetes, and cardiovascular diseases. More alarmingly, there is growing evidence linking UPF consumption to mental health issues such as depression and anxiety, especially among the youth.
We strongly support the survey's recommendations, which include the introduction of stricter labeling requirements, such as mandatory front-of-pack warning labels (FOPL), to better inform consumers about the high fat, salt, and sugar (HFSS) content of foods. Furthermore, we support the call for restrictions on marketing these products, particularly in advertisements targeting children. As the survey notes, the failure of self-regulation in the industry further emphasizes the need for stronger, more effective government intervention.
The evidence provided in the Economic Survey paints a clear picture of the growing public health crisis caused by UPFs. As outlined in the report, India's consumption of these foods has skyrocketed, with retail sales growing at a compounded annual growth rate (CAGR) of 13.7% from 2011 to 2021. This alarming trend is reflected in both urban and rural household spending on beverages, refreshments, and processed foods, which now account for a significant portion of food budgets.
As PVCHR continues to advocate for human rights and public health, we fully support the following key recommendations from the Economic Survey 2024-25:
Immediate implementation of mandatory warning labels (FOPL) for HFSS foods to ensure consumers are fully informed of the health risks associated with these products.
Strict restrictions on UPF advertisements, particularly those targeting children under 18. This can be achieved through an amendment to the existing Advertisement Code and Norms of Journalistic Conduct 2022.
Adoption of clear definitions for UPFs/HFSS, in alignment with the Dietary Guidelines of the ICMR-NIN, to ensure clarity and consistency in regulation.
Formation of an empowered group to oversee the implementation and monitoring of these recommendations.
Ensuring budget provisions to support these efforts and ensure effective enforcement.
We urge your esteemed office to take proactive measures to translate these findings into immediate regulatory actions. The health of millions, especially our youth, is at risk, and swift intervention is necessary to safeguard public health and prevent the further rise of NCDs linked to ultra-processed foods.
We also encourage all Members of Parliament, members of the Parliamentary Committee on Health, and the Ministry of Health and Family Welfare to come together and act on these recommendations without delay. As highlighted in the Economic Survey, time is of the essence.
For further details, please refer to the following article:
Higher Tax on Ultra-Processed Foods, Economic Survey's Proposal to Curb Health Risks
Sincerely,
Shruti Nagvanshi
Managing Trustee
People's Vigilance Committee on Human Rights (PVCHR)
Shruti Nagvanshi
Co-Founder, Managing Trustee, and Chief Functionary
JanMitra Nyas
Special Consultative Status with ECOSOC of the United Nations
SA 4/2 A Daulatpur, Varanasi - 221002, India
Mobile: +91-9935599330 and +91-9935599333
Website: www.janmitranyas.in
JanMitra Nyas:Pioneering Health Equity at the Grassroots
Wikipedia: Shruti Nagvanshi, People's Vigilance Committee on Human Rights
Date: December 5, 2024
To:
The Chairperson
National Human Rights Commission
New Delhi, IndiaSubject: Supplementary Submission on the Detrimental Effects of Ultraprocessed Foods on Human Health
Dear Sir/Madam,
I am writing to supplement my earlier submission (dated November 28, 2024) concerning the health impacts of ultraprocessed foods (UPFs). Recent disturbing media coverage, along with further research, highlights their role in accelerating cognitive decline and contributing to major health challenges.
According to a report by Hindustan (dated December 5, 2024), research conducted by Italy's Institute of Neurology claims that regular consumption of UPFs leads to premature aging of the human brain. Key takeaways from the report include:
- Neurological Impact: Ultraprocessed foods, particularly those subjected to high heat during preparation, are associated with the creation of neurotoxic compounds that harm brain cells.
- Plastic Packaging Risks: Eating food stored in plastic packaging is linked to increased risks due to the release of harmful substances during heating.
- Systemic Health Effects: Beyond the brain, these foods contribute to poor gut health, obesity, and systemic inflammation, further deteriorating overall well-being.
Policy Recommendations:
To address the severe health and human rights implications of UPF consumption, I urge the Commission to:
- Advocate for robust regulation of UPFs to ensure food safety and reduce exposure to harmful compounds.
- Recommend national campaigns emphasizing the dangers of consuming UPFs and promoting healthier alternatives.
- Suggest the inclusion of dietary awareness modules in educational curriculums, particularly focusing on vulnerable populations.
The intersection of diet, public health, and human rights demands immediate and collective action. These findings align with international research, including a recent study published in JAMA Dermatology, further linking UPF consumption to chronic inflammatory conditions like psoriasis.
I respectfully request the Commission to consider these findings in its ongoing efforts to safeguard the right to health and take necessary action to protect the well-being of our citizens.
Thank you for your attention to this matter. I am available to provide further information or clarification if required.
Yours sincerely,
Shruti Nagvanshi
Shruti Nagvanshi
Co-Founder, Managing Trustee, and Chief Functionary
JanMitra Nyas
Special Consultative Status with ECOSOC of the United Nations
SA 4/2 A Daulatpur, Varanasi - 221002, India
Mobile: +91-9935599330 and +91-9935599333
Website: www.janmitranyas.in
JanMitra Nyas:Pioneering Health Equity at the Grassroots
Wikipedia: Shruti Nagvanshi, People's Vigilance Committee on Human Rights
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On Thu, Nov 28, 2024 at 1:45 PM Shruti Nagvanshi <shruti@pvchr.asia> wrote:Date: November 28, 2024
To:
The Chairperson
National Human Rights Commission
New Delhi, IndiaSubject: Submission of Supplementary Information on the Health Impacts of Ultraprocessed Foods
Dear Sir/Madam,
I write to submit additional information regarding the impact of ultraprocessed foods (UPFs) on health, based on recent research published in JAMA Dermatology (November 2024). The findings are relevant to ongoing discussions about public health policies and human rights, particularly the right to health. Link for details: https://www.medpagetoday.com/dermatology/psoriasis/113163
A study conducted using the French NutriNet-Santé cohort has linked the consumption of UPFs—such as soda and frozen pizza—with increased activity in psoriasis, a chronic inflammatory skin condition. Key findings include:
Disease Association: Individuals with active psoriasis were more likely to be in the highest tertile of UPF consumption compared to those who never had psoriasis (adjusted OR 1.36, 95% CI 1.14-1.63, P<0.001 for trend).
Inflammatory Effects: Evidence suggests UPFs promote inflammation beyond their role in contributing to obesity, directly impacting immune system function.
Comorbidities: Participants with active psoriasis showed higher rates of obesity (16% vs. 9% in the never-had group) and associated health issues like cardiovascular disease, diabetes, and inflammatory bowel disease.
Policy Implications: The findings underscore the importance of comprehensive food regulations, public education on nutrition, and reforms in dietary guidelines to mitigate the health impacts of UPFs.
Although the study acknowledges limitations, including reliance on self-reported data and its observational nature, it presents compelling evidence for further investigation and policy action.
Given the link between diet and health, and recognizing the NHRC's mandate to safeguard the right to health, we urge the Commission to recommend:
- Strengthened regulation of UPFs, including better labeling and reduced accessibility.
- Nationwide campaigns to educate the public on the health risks of UPFs.
- Policy interventions to improve nutritional standards in schools and public institutions.
The health implications of dietary habits are intrinsically tied to human rights, and addressing these concerns aligns with the Commission's mission to promote and protect well-being.
Thank you for your attention to this urgent matter. I remain at your disposal for any further information or discussion.
Yours sincerely,
Shruti Nagvanshi
Shruti Nagvanshi
Co-Founder, Managing Trustee, and Chief Functionary
JanMitra Nyas
Special Consultative Status with ECOSOC of the United Nations
SA 4/2 A Daulatpur, Varanasi - 221002, India
Mobile: +91-9935599330 and +91-9935599333
Website: www.janmitranyas.in
JanMitra Nyas:Pioneering Health Equity at the Grassroots
Wikipedia: Shruti Nagvanshi, People's Vigilance Committee on Human Rights
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On Fri, Nov 22, 2024 at 12:50 PM Shruti Nagvanshi <shruti@pvchr.asia> wrote:Supplement to Case No. 4227/90/0/2021
National Human Rights Commission (NHRC)
Subject: Need for Mandatory Front-of-Pack Labelling (FOPL) to Curb Non-Communicable Diseases (NCDs) in IndiaHonorable Commission,
This supplement is submitted to emphasize the urgent need for mandatory Front-of-Pack Labelling (FOPL) on packaged food items in India. It is based on insights highlighted in a report published by The Hindu newspaper, which underscores critical public health concerns associated with unregulated packaged food consumption. Link: https://www.thehindu.com/news/national/should-packaged-food-content-be-labelled-explained/article68891204.ece
Context and Key Findings:
Insights from The Hindu Report (2024):
- The Hindu report references the Global Access to Nutrition Index (ATNi), which reveals that food and beverage (F&B) companies often sell less nutritious products in low-and-middle-income countries (LMICs), including India, compared to high-income countries (HICs).
- Packaged foods in LMICs, including India, scored an average of 1.8 on a health star rating system (out of 5), much lower than the 2.3 average in HICs.
NCD Burden in India:
- According to The Hindu, India faces an alarming rise in non-communicable diseases (NCDs), with 10.13 crore Indians suffering from diabetes and obesity affecting 24% of women and 23% of men (NFHS-5).
- Unhealthy diets account for 56.4% of India's disease burden (ICMR), fueled by the consumption of highly processed foods rich in sugar, saturated fat, and sodium.
Ineffective Voluntary Approaches:
- Despite existing guidelines, voluntary efforts by F&B corporations to provide clear nutritional information have failed to ensure compliance or reduce the public health impact.
- The draft Food Safety and Standards (Labelling & Display) Amendment Regulation 2022 has seen no significant progress in two years, leaving consumers uninformed about the health risks of packaged foods.
Proven Benefits of Mandatory FOPL:
International examples cited in The Hindu report demonstrate the efficacy of FOPL. Countries like Chile and Mexico experienced significant reductions in the consumption of sugary beverages and other unhealthy foods after implementing mandatory warning labels.
Warning labels have proven to be more effective than other systems, such as health star ratings, in helping consumers make healthier food choices.
Recommendations:
Immediate Implementation of Mandatory FOPL:
- The NHRC should recommend that the Government of India and the Food Safety and Standards Authority of India (FSSAI) enforce mandatory warning labels on packaged foods containing high sugar, fat, and sodium content.
Consumer Awareness and Education:
- Support initiatives to educate the public on interpreting FOPL to make informed dietary choices.
Regular Monitoring and Compliance:
- Establish a robust monitoring framework to ensure compliance by F&B manufacturers with FOPL regulations.
Addressing Health Disparities:
- Encourage equitable access to healthier food options for lower-income populations through targeted policies.
Alignment with Global Standards:
- Align Indian food labelling policies with World Health Assembly (WHA) resolutions to combat the harmful marketing of junk foods, especially to children.
Conclusion:
The implementation of mandatory warning label FOPL is a necessary step to uphold the right to health guaranteed under Article 21 of the Indian Constitution. Delays in regulatory action are exacerbating India's NCD crisis, particularly among vulnerable populations.
We urge the Honorable Commission to advocate for immediate and decisive action to protect public health through transparent food labelling practices.
Yours sincerely,
Lenin Raghuvanshi
Senior Advisor, JanMitra Nyas
Editor-in-Chief, Reformist Approaches to Human Rights
Awardee: Global Pluralism Award (2021)Shruti Nagvanshi
Co-Founder, Managing Trustee, and Chief Functionary
JanMitra Nyas
Special Consultative Status with ECOSOC of the United Nations
SA 4/2 A Daulatpur, Varanasi - 221002, India
Mobile: +91-9935599330 and +91-9935599333
Website: www.janmitranyas.in
JanMitra Nyas:Pioneering Health Equity at the Grassroots
Wikipedia: Shruti Nagvanshi, People's Vigilance Committee on Human Rights
This message contains information which may be confidential and privileged. Unless you are the addressee or authorised to receive for the addressee, you may not use, copy or disclose to anyone the message or any information contained in the message. If you have received the message in error, please advise the sender by reply e-mail to shruti@pvchr.asia and delete the message. Thank you.
On Thu, Nov 9, 2023 at 12:40 PM PVCHR Communication <cfr.pvchr@gmail.com> wrote:To,
The Honorable Chairperson
National Human Rights Commission
New Delhi
Honorable Sir,
I am writing in reference to case no. 4227/90/0/2021, which was registered with your esteemed commission concerning the health of children, women, and youth. On 31st May, 2023, the honorable commission requested additional information from THE DIRECTOR, Ministry of Health and Family Welfare, and the Food Safety and Standards Authority of India regarding REGULATORY COMPLIANCE.
In response to this request, the honorable commission ordered that the recommendations made by the scientific panel and IIM, Ahmedabad, be forwarded to the Director of the Regulatory Compliance Division, Food Safety and Standards Authority of India, New Delhi. The commission also requested that these recommendations be taken into consideration, along with all the communications received by the Commission when finalizing the notification. A report on this matter is expected within three months.
Sir, as concerned complainants, we are eager to know the status of the report received from the Director, Regulatory Compliance Division, Food Safety and Standards Authority of India, New Delhi.
In conjunction with this, we are resubmitting a comprehensive study conducted by AIIMS, IIPS, and other relevant studies as a rejoinder to this case. We kindly request that you accept the above-mentioned documents as a part of our plea for implementing robust and mandatory Front of Packet Labelling with the warning symbol.
Thanking you for your attention to this matter.
Sincerely Yours,
Shruti Nagvanshi
Convenor
Savitri Bai Phule Women Forum
&
Shirin Shabana Khan
Program Director
People's Vigilance Committee on Human Rights----
People's Vigilance Committee on Human Rights (PVCHR)
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