A petition filed before the Supreme Court seeking nutrition labelling has come not too late. The petition seeks, among other things, that the Food Safety and Standards Authority of India (FSSAI) examine the ‘health star rating’ system used in the US, Australia and New Zealand.
The Australia New Zealand Food Standards Code currently requires all packaged foods to carry a nutrition information panel (NIP), with the exception of very small packages and those packaged for immediate consumption. Manufacturers typically place NIPs on the back or sides of packaging, which may not be immediately visible to consumers in the supermarket environment.
However, placement of nutrition labels is only a part of the problem. No nutrition labelling system will serve its purpose if it does not take into account the purchasing behaviour at the time of buying the product. Consumer research indicates that information labels can be confusing and difficult to interpret, and objective measures indicate that their use during food purchase is lower than what consumers report.
In India, diet diversity has increased a great deal in the last 20 years or so. Excessive and unbalanced intakes of energy, saturated and trans fatty acids, salt and sugar has led to increased risk of non-communicable diseases such as diabetes, high blood pressure, obesity and growth problems.
The effects of such energy-dense nutrient-poor foods are already visible. According to the fourth National Family Health Survey, the number of obese people doubled in the country in ten years until 2016. Overweight individuals are more likely to develop insulin resistance and cardiovascular diseases at a younger age and have a higher chance of premature disability and death. The WHO estimates that by 2030, 67% of all deaths in India will be due to non-communicable diseases.
Nutrition labelling is an important policy tool to address increased consumption of cheap, ultra-processed, energy-dense, nutrient-poor foods. The question is whether the labels should be written or visualised. Which one could be better? The question is important not because of varying levels of literacy but because consumers tend not to pay attention, or pay inadequate attention, to the label.
In India, the question acquires added importance because it is inconceivable that any one language can fulfill the needs of the country’s enormous demographic diversity.
A visual label – like a star-rating system – therefore makes eminent sense. It overcomes several barriers inherent to written messages and warnings, although not all.
Even so, wily manufacturers and marketers will still find ways to dodge the mandatory FSSAI requirement; we have already seen this in the case of gutka. So any star-rating system must meet five criteria.
First, noticeability: does the label (or the star system) catch the buyer’s attention? To do so, it should appear on the front of the pack.
Second, comprehension: does the buyer understand it? To do so, it should use a colour coding system that people of all ages and backgrounds can understand quickly.
Three, understanding: does it provide adequate and necessary information? A ‘signal’ with red indicating ‘not good for health’ or ‘do not buy’, yellow indicating ‘within tolerable limits’ and green indicating ‘healthy’ would provide both adequate and necessary information.
Fourth, legibility: is it clearly visible? The star system should be of a certain size and appear just below the brand’s name on the front of the pack (the warning on cigarette packets is a good model to follow).
Finally, persuasion: does the star system nudge the consumer to purchase (or not) the product? Once ready, it should be scientifically pre-tested in different parts of the country, across various socio-economic groups.
Moreover, FSSAI, the WHO and NGOs must conduct periodic surveys to investigate the effectiveness of the labelling system and design appropriate campaigns to educate consumers.
The utility of any information system depends on its content and format, and on the nutrient-profiling method used. These elements together influence consumers’ ability to notice and comprehend the information provided, in the context of a busy, information-rich and typically hurried shopping experience.
Pradeep Krishnatray is former director, Research and Strategic Planning, Johns Hopkins Center for Communication Programs, New Delhi.