Flawed Beginning Of A New Public Health Regulation

There is enough scientific evidence to say that increased consumption of ultra-processed unhealthy food/drink products (UPFs) is associated with high risks of NCDs.

Image used for representational purpose only.

CAN we really call all unhealthy packaged food products that lead to volumes of sickness, as healthy? INDIA is facing a public health crisis of rising obesity, diabetes, cancers, hypertension and cardiac diseases (Non-Communicable Diseases (NCDs). In India, it is estimated that nearly 5.8 million people die from NCDs every year out of total deaths of about 9 million.

NCDs also cause a huge negative impact on socio-economic development of the country. More than half of the 5-19 year olds show blood tests that point to futureNCDs- a ticking time bomb.

There is enough scientific evidence to say that increased consumption of ultra-processed unhealthy food/drink products (UPFs) is associated with high risks of NCDs. A new 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%.

 UPFs are industrially processed and usually high in sugar, salt, or bad fats, and contain several chemical additives. This combination is detrimental to health. These are aggessively promoted and sold as pacakged.

The WHO Southeast Asia regiona has provided guidance on the cut-off levels for nutrients of concern like total sugar, salt/sodium and saturated fats per 100 GMs/MLsof a food product beyond which food/drink could be labelled unhealthy and restricted for marketing. There are 5 types of labels, currently the debate is between the two, ‘Health Star Rating(HSR)’ or a Warning Label’.

What is the flawed beginning?

The FSSAI is currently working on the front of the pack label (FOPL) that should convey whether a food product it’s healthy or unhealthy. A “decision” has taken by the FSSAI on 15 February,2022  “… HSR may be incorporated into the draft regulations and the stakeholders may provide their comments on the same as per due procedure.”   FSSAI’s decision is based on a IIM Ahmedabad report.

Pic of Product from Mexico shows it gets 2 warning on Calories and Sugar.

What is the problem with this decision and HSR?

The HSR creates a ‘health halo’,it is deceptive in nature as it unfortunately assumes all unealthy pacakged food products to be healthy, which may vary with number of stars it receives.

A consumer cannot identify from HSR label whether the food/drink product has a high sugar content(for a diabetic) or salt ( for a hypertensive) or saturaed fat ( for heart patient).

The HSR uses a higher cut off limits of nutrients of concern than recommended by WHO, which are 2-3 times higher for sugar for example.

HSR does not provide a zero or no star to a product that has crossed any one of the limits of unhealthy nutrients of concern.

HSR allows adding fiber, protein, nuts, fruit and vegetables, which actually helps increase its Star value. The food products intrinsically harmful to our health become healthy. HSR is therefore confusing. This is big gain for marketing campaigns to project unhealthy products as healthy. It is feared that if we go by HSR it may increase the consumption of unhealthy food products and so the health care costs will go up as well.

Reports suggest that HSR can be manipulated to get more stars. The food regulator decided in favour of HSR in September 2021, in its brief to IIM- Ahmedabad (RTI Information) to address positive nutrients in the study to find out which label would work better. A bias was thus created, which throws warning labels out of the window. Four independent experts say the reportis not fit for purpose and question the report methods, findings and interpretation.

What goes in favour of warning labels?

The globalscientific evidenceshows that warning labels work better and health stars are worse.

A new study from India published on 6th May “Which Front-of-Package Labels Help Indian Consumers Identify and Reduce Unhealthy Food Purchases? A Randomized Field Experiment” The results suggest that warning labels are the most effective FOPL to help Indian consumers identify and avoid unhealthy foods.

Twenty-four (25) public health, patient groups and consumer organisations, which represent the people of the country, opposedthe decision of food regulator and vouch for warning labels through endorsing a position statement.

Warning labels speak the truth, are an honest expression of the contents and simple to communicate. Common sense is applibale. On googling this is what you get “Warning is a statement or event that warns of something or that serves as a cautionary example.”

In conclusion, Warning on the front of pack of unhealthy food product is the way forward to protect people’s health. Government of India’s Food safety regulator is duty bound.  And for people to prevent these diseases it is necessary for the Government of India to inform which foods are safe to consume and which are not.

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