Supreme Court seeks clarity on food labelling plan.

The Supreme Court on September 10, 2026, sought further information from the Centre and the Food Safety and Standards Authority of India (FSSAI) on its proposal for implementing phased front-of-pack labelling (FoPL) to safeguard the collective health and well-being of people, especially growing children in India.

A Bench of Justices J B Pardiwala and K Vinod Chandran asked the Union government to explain how schools plan to incorporate, through curriculum, initiatives and workshops, the manner in which information provided on packaged food items, including nutritional information and FoPL, should be interpreted. Court also sought details on other aspects of nutritional literacy, "in recognition of the vulnerable position that children are in vis-à-vis impulse or uninformed dietary decision-making".

What is the FSSAI’s proposal for front-of-pack labelling?

In an affidavit filed on August 28, 2026, the FSSAI informed the Court that it has prepared a proposal to provide interpretive labels for nutrients-of-concern i.e. fat, sugar and salt on the front of food packages in pictorial form, as a ‘red hexagon’.

The FSSAI said the label would constitute a "simple, prominent and easily comprehensible warning to consumers regarding food products which are high in specified nutrients of concern".

"We acknowledge that significant progress has been made by the FSSAI on the matter. However, we would be remiss not to point out that several aspects or specificities anchoring the practical implementation of the FSSAI’s proposal still remain ambiguous and need further clarification," the Bench said.

Court was hearing a PIL filed by NGO 3S And Our Health Society.

The petitioner submitted that compliance with the FoPL model, once finalised as a regulation, must be made mandatory and uniformly enforceable for all covered food products, without leaving its implementation to the discretion of food business operators.

When does the FSSAI plan to implement the two phases of FoPL?

Among the questions posed by the Court to the Centre and the FSSAI was what would be a reasonable and fixed timeline for implementing the two phases currently proposed.

Court also asked as to what was the basis for the FSSAI’s proposal to include food products high in ‘two or more’ nutrients-of-concern and specified sweetened beverages in Phase I, and food products high in ‘any one’ nutrient-of-concern in Phase II.

"How does the FSSAI propose to identify the specific sweetened beverages which fall under Phase I of the proposal? Additionally, what are the threshold levels of the specific nutrient(s)-in-concern for such beverages," Court asked.

How will the threshold levels for fat, sugar and other nutrients be decided?

The Bench sought to know whether, while calculating the threshold levels for each nutrient-of-concern, the FSSAI would account for the difference between food categories 2 and 3 under the FoPL.

It also asked whether the FSSAI would account for the difference between food groups B which is moderately processed with no additives, and C which is excessively processed with additives, while calculating the threshold levels.

The Bench further asked whether the threshold limits for fat and sugar would be calculated on the basis of ‘Total’ Sugar and ‘Saturated Fat’, as indicated in the stakeholders’ meeting conducted on October 29, 2021. It also sought clarity on how trans-fat levels would be factored into calculations of fat content for the purpose of FoPL.

Why has the FSSAI chosen a red hexagon for FoPL?

Court questioned the FSSAI’s choice of colour and design for the proposed label.

"Considering that an average Indian consumer is habituated into associating the colour red with non-veg ingredients, would it be necessary for the FSSAI to revisit the choice of colour for the FoPL?" the Bench asked.

It also sought to know the dimensions of the proposed ‘red hexagon’, and whether these would have standardised specifications or be calculated in proportion to the area of the package.

The Bench further asked whether the font size used for the FoPL would be relative to the dimensions of the hexagons and sought details on the manner and method of their placement on food packages.

Will the FoPL be easy to understand for all consumers?

Court also raised questions about whether the proposed labelling system would be sufficiently comprehensible to consumers with different levels of literacy and understanding.

It asked how, in the absence of distinct pictorial representations for each nutrient-of-concern, the FSSAI proposed to cater to the diverse levels of comprehension, literacy and reading capability of the consuming population.

"Why has the FSSAI suggested a combined/composite/singular hexagon for two or more nutrients-of-concern instead of separate/distinct/individual hexagons for each nutrient-of-concern?" Court asked.

The Bench also sought to know how the FSSAI would regulate the potential increase in the use of artificial preservatives, emulsifiers and other such ingredients that may result from implementation of the FoPL.

Will there be a voluntary period before FoPL becomes mandatory?

The Bench asked whether, after the final regulations making FoPL mandatory are notified, the FSSAI envisages a voluntary period for compliance. If so, it sought to know its proposed duration.

Court also returned to the issue of nutritional literacy among children and asked how the Union government proposes to incorporate, through curriculum, initiatives and workshops at the school level, information on how packaged food labels, including nutritional information and FoPL, should be interpreted.

It also sought details on other measures proposed to improve nutritional literacy among schoolchildren.

The Bench directed the Centre and the FSSAI to respond to the questions by way of an affidavit within 10 days and posted the matter for hearing on September 28, 2026.

Case Title: 3S And Our Health Society Vs Union of India & Anr

Bench: Justices J B Pardiwala and K Vinod Chandran

Date: September 10, 2026

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