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SC Reserves Judgment On FSSAI’s Front-Of-Pack Labels; Gives 3-Day Window For Final Submissions

The Supreme Court on Monday reserved its judgment on the proposed front-of-pack labelling rules for packaged food and beverages, bringing a key regulatory debate over how consumers should be informed about sugar, fat and salt content closer to a decision. The bench directed all parties involved in the matter to submit their final written arguments within three days. The eventual order is expected to have implications for the framework being considered by the Food Safety and Standards Authority of India (FSSAI) for prominent nutritional warnings on packaged products.
The update comes after the apex court sought greater clarity from the Centre and FSSAI on the proposed Front-of-Pack Nutrition Labelling (FoPL) framework, including its implementation timeline, nutrient thresholds and the manner in which products would be brought under the proposed regime.
FSSAI has told the Supreme Court that it proposes a red hexagonal warning label, broadly drawing from the Canadian approach, for packaged food products that meet the prescribed thresholds for nutrients of concern. The regulator has also indicated that it expects to issue and finalise the draft regulations in around four months.
Supreme Court Questions FSSAI Over Implementation Timeline

The Supreme Court had earlier sought a clear and reasonable timeline for introducing the proposed front-of-pack warning system. The Bench also questioned the rationale behind a two-stage implementation plan and wanted the authorities to explain how products would be identified for each phase.
During the proceedings, Justice Pardiwala said, “We are undertaking this exercise for the good of the nation, good of the citizens. Authorities are expected to implement, comply with our order in letter and spirit. Tell us about timeline. Why do you want so much time for implementation two phases etc.”
The court’s questions have now been followed by FSSAI’s proposal for a single-phase implementation rather than the earlier two-phase approach. The regulator has told the court that it would require approximately four months to complete the process of issuing and finalising the draft regulations.
What FSSAI’s Red Hexagon Label Will Indicate

Under the proposal, packaged food products meeting the relevant criteria would carry a red hexagonal warning on the front of the pack. The label is intended to provide consumers with an easily identifiable indication when a product contains high levels of nutrients such as sugar, salt or fat.
The regulator has proposed a design that can identify products as having “HIGH FAT, HIGH SALT or HIGH SUGAR” and also address products where more than one of these nutrient thresholds is met. The proposal is broadly based on a warning-label model used in Canada.
The proposed system is part of a wider effort to make nutritional information more prominent and easier for consumers to interpret while purchasing packaged foods.
The court’s earlier order sought responses from the Union government and FSSAI on 13 specific aspects of the proposed FoPL framework. These included questions around the timeline for implementation, nutrient thresholds, sweetened beverages, the size and colour of the warning label, pictorial representations and the potential impact on food additives.
The court also sought clarity on voluntary compliance and nutritional literacy among schoolchildren. The questions indicate that the proposed framework is being examined not merely from the standpoint of label design but also in terms of how the system would operate across different categories of packaged foods.
Single-Phase Rollout Replaces Earlier Two-Phase Proposal

One of the key changes in FSSAI’s latest response is its decision to propose a single-phase rollout. Earlier, the regulator’s plan had envisaged implementation in two stages, prompting the Supreme Court to seek the basis for dividing products between the two phases.
The latest proposal removes that distinction and instead envisages one implementation framework. FSSAI has indicated that the draft regulations could be issued and finalised within approximately four months.
The precise compliance period for food businesses and the final technical specifications will depend on the regulations that emerge from the process.
What Happens Next in the Food Labelling Case

The Supreme Court’s scrutiny puts the proposed FoPL regime at an important stage. The final framework will determine which packaged foods are covered, what nutrient thresholds will trigger a warning and how the red-hexagon label will appear on products.
FSSAI’s existing regulatory framework already includes the Food Safety and Standards (Labelling and Display) Regulations, 2020, which have undergone multiple amendments, including an amendment notified in March 2026.
With FSSAI now proposing a single-phase approach, the next steps will centre on the draft regulations, their finalisation and the compliance timeline for food manufacturers. The Supreme Court’s intervention has also kept the focus on ensuring that the proposed warning system has a clear and practical implementation roadmap.

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