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Intent of labelling is to communicate product strengths
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Saturday, 28 March, 2026, 15 : 00 PM [IST]
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Sukhada Bhatte
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A colleague bought a protein bar that prominently displayed the claim “High in Protein” on its front panel. However, upon reviewing the nutrition declaration, the protein content was only marginally higher than conventional snack bars and contributed minimally toward daily requirements per serving. The claim was technically permitted by the regulation, but its display gave a strong perception of nutritional superiority than the actual nutrient delivery.
This example highlights an important nuance in food labelling science- no label is necessarily intentionally misleading. The intent of labelling is often to communicate product strengths and help manufacturers differentiate their products in a competitive marketplace. However, the use of prominent claims, selective emphasis, or insufficient contextual information can lead to consumer misinterpretation, particularly when the health literacy of the consumer is limited.
It is safe to assume that the average consumer has limited familiarity with technical labelling guidelines, Recommended Dietary Allowances (RDA), nutrient thresholds or nutrition jargon in general. To add to this, they have a lot of social media influence that drives the selection of a product. Therefore, the effectiveness of food labelling must be evaluated not only by regulatory compliance but also by its clarity, how it is interpreted and potential impact on consumer decision-making.
The Scientific and Regulatory Framework Governing Food Labelling in India
Food labelling in India is regulated by the Food Safety and Standards Authority of India (FSSAI), which establishes mandatory requirements under:
- Food Safety and Standards (Labelling and Display) Regulations, 2020
- Food Safety and Standards (Advertising and Claims) Regulations, 2018 These regulations require that:
- Claims must be truthful, unambiguous, meaningful, and scientifically substantiated.
- Labels must not mislead consumers regarding nutritional quality, composition, or health benefits.
- Ingredients must be listed in descending order by weight, allowing consumers to identify major components.
- Nutritional information must include energy, macronutrients, and relevant micronutrients per 100 g or ml and per serving along with % RDA contribution.
From a regulatory standpoint, compliance is primarily defined by scientific accuracy and factual correctness. However, compliance does not automatically ensure optimal consumer understanding.
Let us understand the gap between scientific accuracy and consumer interpretation. Research in nutrition communication consistently demonstrates that consumers rely heavily on front-of- pack claims and visual cues, rather than detailed nutritional tables or back of the pack disclaimers.
Several factors contribute to misinterpretation:
1. Cognitive Bias Toward Positive Claims
Consumers tend to interpret claims such as “high protein,” “natural,” “clean”, “organic”, or “immunity boosting” as indicators of overall healthfulness, even when these claims refer to only one specific attribute. This gives them a myopic understanding that the product can be perceived as healthy.
2. Limited Understanding of Quantitative Context Consumers may not understand:
What constitutes a “high” level of a nutrient How much a serving contributes to daily needs
The difference between absolute nutrient quantity and relative claim eligibility
For example, a product containing 6 g protein per serving may qualify for a claim but still contribute less than 10–12% of daily requirements for adults or a product may be high in fibre, but also simultaneously be high in calories.
3. Health Literacy Constraints Studies in public health nutrition suggest that many consumers lack familiarity with:
- Percentage Recommended Dietary Allowance (%RDA)
- Ingredient hierarchy
- Nutrient thresholds for claims
Therefore, labelling strategies must be designed assuming lowest reasonable health literacy to ensure equitable access to accurate information. Imagine explaining the label to a 5-year-old, and see how it simplified the information delivery.
Scientific Principles for Presenting Label Information Effectively
If the objective is to ensure both compliance and clarity, labels should be designed based on the following evidence-based communication principles:
- Provide Quantitative Context Alongside Claims: Instead of stating: “High Protein”, a scientifically informative approach would be: “Contains 10 g protein per serving (20% of daily requirement*)” This enables consumers to interpret the claim within physiological context.
- Improve Front-of-Pack Interpretability: Front-of-pack labelling should communicate key nutritional attributes in a simplified format, such as: Protein per serving, Energy contribution, Sugar content, Percentage contribution to daily intake. This reduces reliance on interpretive assumptions. Percentages can be skewed, but factual per gram or per serving delivery is easier to understand.
- Avoid Overemphasis of Single Nutrient Benefits: Scientific evaluation of nutrient function requires consideration of overall nutrient profile rather than isolated nutrients. For example, highlighting protein content without simultaneously indicating high sugar or fat content may create an incomplete perception of nutritional value of a product. Balanced representation improves scientific transparency.
- Improve Ingredient Transparency: Ingredient lists are scientifically robust but underutilised by consumers. A QR code can guide the consumers to a webpage that lists the role of safety of the ingredients used in a product. This will help us move away from the negative connotation that ingredients generally face. It is rather preferred that a manufacturer lists all his ingredients, than misses a few just to show that the product has fewer ingredients and therefore, is more healthy. Further, we can enhance readability through: Standardised font sizes, Use of simple but clever language, Ingredient function descriptions which can help significantly improve consumer understanding.
- Adopt Front-of-Pack Interpretive Labelling Systems: Globally, interpretive systems such as traffic-light labelling and warning labels have demonstrated effectiveness in improving consumer decision-making. Such systems reduce dependence on numerical literacy and improve rapid interpretation. However, they come with their own set of limitations.
The Role of Manufacturers: Communicating Science Clearly: When implemented correctly, labelling becomes a tool for public health rather than merely a marketing instrument. Future improvements may include: mandatory interpretive front-of-pack labelling, standardised claim formatting with %RDA context, enhanced consumer education initiatives and general awareness of the consumer.
Food labelling in India operates within a robust scientific and regulatory framework. However, the effectiveness of labelling must ultimately be measured not only by compliance, but by consumer comprehension. Assuming limited health literacy provides a useful scientific framework for designing labels that are interpretable, transparent, and actionable. The goal is not to restrict manufacturers from highlighting product strengths, but to ensure that claims are presented in a manner that enables consumers to accurately understand their nutritional significance.
(The author is nutrition science specialist- ideation emerging markets and clinical research treasurer, Indian Dietetic Association, Mumbai Chapter)
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