The Devil is in the Details

If you were at a McDonald’s lately, accompanying a friend perhaps who insisted on order­ing a meal to go, and you were faced with two options—ei­ther one of their regular burg­ers, or their new multi-millet burger—which one would you go for? A regular burger is of course a regular burger, and it comes with the knowledge we all possess about the unhealthiness of such types of food. But what about the new multi-millet burg­er, sold in an entirely different category in their menu (‘Real Food, Real Good’), one that comes packed with (as their website puts it) “essential vitamins, minerals, and natural dietary fibre, of­fering nutrition and delight”, and one that was co-developed with a premier public institution (the Central Food Technological Research Institute under the Council of Scientific & Industrial Research) and presented by arguably India’s most famous and trusted chef (Sanjeev Kapoor)? If you went with the multi-millet burger, your decision influenced by the promised goodness of the millet in the burger’s buns, you might have fallen for the mirage cre­ated by what is termed as “healthwash­ing”. Here, by trumping up positive at­tributes while downplaying negative ones, a food manufacturer misleads you into believing you have made a healthy choice. The claim may be true, but it doesn’t mean the product is healthy.

“A burger is still a burger. Just adding millet to it does not make it healthier,” says Dr Arun Gupta, a senior paediatri­cian and convener of the public health and nutrition think-tank Nutrition Advocacy in Public Interest (NAPI). “Besides, it is not like you will eat just the buns. You will eat it with the patty and all the other condiments.”

McDonald’s is hardly the only busi­ness indulging in this trend. Our super­market shelves today are increasingly awash with packaged food products that have undergone such spin. Row af­ter row of shelves will scream out from bright and shiny packets a nutritious-sounding ingredient or positive health trait: ‘no added-sugar’, ‘wholegrain’, ‘organic’, ‘high in protein’, ‘cholesterol-free’ or some such characteristic. It’s only when you flip the packet to its back, wade through the abundance of written material till you finally locate the nutritional information listed, usu­ally tucked away in some corner and often in tiny or almost-undecipherable fonts, that you might realise that the no added sugar claim does not mean that the product is entirely free of any added sweetener, but that it comes with some sugar substitute which could be equal­ly unhealthy, or that the ‘wholegrain’ bread you just bought isn’t actually entirely wholegrain, but a little bit of wholegrain mixed into a whole lot of refined flour.

This aspect of the deception prac­tised by many packaged food products and the need to give consumers more information about the food they con­sume came to the fore a few weeks ago when the Union Health Ministry issued an advisory asking schools and work­places to put up information boards that raise awareness about the health risks of consuming snacks with hid­den fats and excess sugar and salt. Some however interpreted the advisory as a directive aimed at having warning la­bels put on popular Indian snacks, like samosas and jalebis, and after an uproar that it wasn’t asking the same of pack­aged food products, the government clarified that it was not being selective towards just Indian snacks and that is was more of a general advisory nudging people towards healthier choices.

Interestingly, this conversation came around the time when the three-month deadline set by the Supreme Court for an expert committee of the Food Safety and Standards Authority of India (FSSAI), the body that regulates the manufacturing, sale and distribu­tion of food articles, to look into food safety norms and the proposal to get packaged food manufacturers to adopt Front-of-the-Pack Nutrition Labelling (FOPL) drew to a close.

FOPL is the practice of getting manu­factures to list the nutritional informa­tion of their products’ contents, as the name suggests, right at the front of the packaging, instead of the back, which shoppers often ignore or which manu­facturers sometimes deliberately make it difficult for a consumer to read. It has been adopted in several countries and studies have shown it influences people’s purchasing decisions. “These labels work because they’re direct, and hard to ignore. Especially in coun­tries with low literacy levels or limited nutrition education, a simple visual cue can make a big difference,” says Dr Shoba Suri, a Senior Fellow at the Observer Research Foundation. “The current system of provid­ing nutritional information can be difficult and complicated to understand for people with low nutritional knowledge. They generally get ignored while purchasing products, at times not readable, and also do not adequately address the growing health concerns on consuming HFSS [high in fat, salt and sugar] products.”

FOPL was first proposed in India by an expert committee of FSSAI in 2014, af­ter the Delhi High Court had asked it do so, but after making a draft regulation of such a practice public in 2022 to seek com­ments from stakeholders and the public, nothing was heard of it, till the Supreme Court picked up the thread earlier this year. At the latest hearing, FSSAI asked for an extension of another three months, which the Supreme Court granted, but with a ‘warning’, NAPI’s Gupta says, that the report must be ready by the end of that extension.

Gupta, whose association NAPI has long been advocating for such labelling, isn’t disappointed by the latest delay. To him, FSSAI asking for an extension be­cause it needs to consult more stakehold­ers is evident that the expert committee is leaning towards something the pack­aged food industry will be averse towards. “I mean even if the expert committee re­port recommends FOPL, it will still have to go through a long route before it gets officially adopted, but it looks like by the end of three months, we will at least see something,” Gupta says.

The push to get FOPL isn’t just to rep­licate the information listed at the back to the front. Most countries that have ad­opted this system also provide some sort of easy-to-adopt cue, either a nutritional scoring system that gives grades, or a mul­tiple traffic lights labelling system that uses colour, or one which gives stars as a form of rating, or some other such system that helps consumers to make healthy choices. In the 2022 draft, FSSAI’s com­mittee had proposed a Health Star Rat­ing system, which has been opposed by nutritionists and public health activists. “Stars can be misleading since ratings are given from ‘least healthy’ to ‘healthiest’. No food product could be categorised as unhealthy that way,” Gupta says.

HE REASON WHY the packaged food industry is averse to FOPL and health warnings is simple. They be­lieve it will scare away consumers. Inter­estingly, however, a number of packaged food startups have sprung up who have not just voluntarily adopted FOPL, but use it to market themselves as a clean and hon­est brand. Shilpa Khadilkar, a pharmacist who worked with a top MNC, handling its health ingredients portfolio for the Indian market, started a nutraceutical label called ReNewtra last year, where its products come with a multiple traffic lights FOPL system, where not only are nutritional contents listed right at the pack’s front, but also colours are used to grade every nutri­ent, from green being the healthiest to red being the unhealthiest. “I started ReNew­tra and adopted such a system because I realised that, unfortunately, most prod­ucts today are being built in boardrooms by marketing people,” Khadilkar says. “If you just look at the whole scene with pro­tein these days, where everything is being labelled high-protein, where in reality the protein being served will be very low, or they will use the claim of ‘high protein’ to hide other harmful aspects like high-carbs, excess sugar or saturated fats,” she goes on.

Another private firm, a food-tech research and development consultancy in Bengaluru called Thinking Forks, has devised a Goodness Meter, which allows food brands to transparently display how healthy their products are. Here, experi­enced food experts vet and score the prod­ucts of brands that opt for this meter, using guidelines and criteria set by WHO, FSSAI and the health star rating to evaluate them on three parameters of safety, nutrition and ingredients. The products will then be granted a logo and a QR code, which is meant to be used in the packaging so con­sumers can scan it to learn about the certi­fication of the product. “It’s a very holistic nutrition evaluation of the product and based on that you say yes, this is goodness certified. As a consumer, if I see a logo of the Goodness Meter, I know that this product is safe, healthier, and has the right kind of ingredients,” says Rinka Banerjee, the founder and director of Thinking Forks, who previously worked in Hindustan Unilever as the R&D director for its foods business across South Asia.

The meter, Banerjee says, will also help deal with the issue of healthwashing. “We also look at the claims being made, and whether they are credible or not. For ex­ample, I may have a sugar-free product, but it is super high in trans fats, etc. Can I say that it is friendly? Probably not,” she says.

While many food companies know­ingly indulge in healthwashing, quite a few, Banerjee has realised, land up doing so unknowingly. “A lot of startups don’t know the difference between product claims and functional claims. For example, if you say my product is going to help you lose weight, that is a product claim and you need a clinical trial to be able to say that. But if you say that an ingredient in my product has been shown to help lose weight, that is a functional claim,” Banerjee says.

While many believe that it is only once FOPL is made compulsory that this current practice of tricking consumers into thinking something is healthy can be checked, there haven’t been many at­tempts at understanding how an FOPL system would work in an Indian context. Josyula K Lakshmi, currently a professor at the Indian Institute of Public Health in Hyderabad, was part of a team of research­ers from the George Institute for Global Health in Hyderabad that was tasked with conducting a study to look at what type of FOPL would be the most effective across India. Lakshmi and her colleagues first conducted in-depth discussions with 112 adult participants in 16 different focus groups (a paper of which is yet to be pub­lished), followed by a survey administered to 1,270 individuals (which was published at the Food Quality and Preference journal in 2023). These individuals, both in the focus groups and the survey, were drawn from either Hyderabad or the nearby villages in Siddipet, or Delhi or the villages located nearby in Ghaziabad, and hailed from different backgrounds (rural and urban, uneducated and educated, poor and well-to-do, and spoke different languages). “We have unique conditions in India. There are so many languages. We have a huge chunk of the population that cannot read in any language, but then we have a huge chunk that can read only in some local language. But how many languages can you put on a biscuit packet?” she says.

Lakshmi and her colleagues came up with mock FOPLs, 13 at first, which they discussed in their focus groups, which were then tweaked and narrowed into five FOPLs during the survey state. They found that while the various FOPLs performed well, even the health star rating and the multiple traffic lights systems, they also realised how challenging introducing such a system might prove to be.

“Say something like total fat or satu­rated fat. What are the words for that in the local language? You are going to need a PhD in that language to understand the meaning of that word. So you are not really going to reach people by merely translat­ing a word,” Lakshmi says.

They found symbols to be helpful, but only if they were unambiguous. “How to come up with symbols for something like energy, for instance. We put an image of a lightning strike, but many people didn’t get it. If you put powder in a spoon for some­thing else, it’s not clear whether we mean salt or sugar or something else. For oil, we used drops, but people thought it indicated the presence of eggs in the packet. In anoth­er case, where we had a Nutriscore system, where we gave grades to different products, with ‘A’ being the best and ‘D’ the worst, but we had cases where people thought a prod­uct being market D was indicative of the presence of Vitamin D,” she says.

To Lakshmi and her colleagues, FOPL will not achieve its desired aims unless there is also a mass information campaign to make people more nutritionally literate. “Otherwise, there is scope for a lot of confu­sion. You could land up feeling safe when something is not safe.”

FOPLs will probably arrive at some point, although in what form or how effec­tive they will be at checking the tendency of manufacturers to grant themselves health halos is something only time will tell. For now, making a healthy choice demands vigilance.

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