As the Food Safety and Standards Authority of India (FSSAI) races against a Supreme Court deadline to analyse over 14,000 public comments on front-ofpack food labels (FOPL), Nutrition Advocacy in Public Interest(NAPi) , a leading public health experts’ think tank, has submitted a definitive and ethical framework to ensure the decision is based on scientific evidence and public interest, not on commercial influence.
The framework, termed the Weightage Scale for Stakeholder Comments, was delivered to FSSAI by Nutrition Advocacy in Public Interest (NAPI), a think tank working on evidencebased nutrition policy. The scale provides a clear methodology for the FSSAI’s and the expert committee to evaluate inputs by prioritizing their source and evidence-base, rather than their volume.
This proposal is a direct extension of NAPI’s comprehensive policy analysis (Comprehensive Policy Analysis) submitted to FSSAI earlier, which detailed the urgent need for a strong, warning-label-based system as well as prohibition of advertisements of High Fat/Sugar/Salt (HFSS)/ Ultra processed food products. It is based on global evidence and India’s own health crisis.
This intervention comes amid growing concerns that the landmark policy aimed at combating India’s epidemic of obesity and diabetes could be diluted by intense lobbying from the food and beverage industry. The Honourable Supreme Court has directed FSSAI to finalize the regulations within three months, ending mid-October.
“The FSSAI is at a crossroads,” said Dr. Arun Gupta, pediatrician, former member of the PM’s Council on India’s Nutrition Challenges, and Convenor of NAPI.” It can either be remembered as the regulator that empowered millions of Indians to make well-informed choices, or the one that capitulated to food corporations. This ‘Weightage Scale’ provides a simple, fair, and transparent roadmap for them to choose public health. We urge the FSSAI and its ‘Expert Committee’ to adopt this framework to ensure their analysis is defensible and based on evidence, not the number of comments”.
The proposed Weightage Scale assigns a value from 0 to 10 to different stakeholders.
• Maximum weight (9-10/10) must be given to independent scientific evidence from institutions like ICMR, AIIMS, and national and global public health bodies or science publications. This should be the gold standard.
• High weight (8/10) must be given to consumer rights organisations , WHO and UNICEF who provide evidence and what ordinary people actually understand.
• Low weightage( 3-4) may be given to individuals and MSMEs. MSMEs having vested interest should not dictate what the content of policy or regulation should be but may provide implementation challenges for consideration.
• Minimal weight (0-2/10) should be given to industry associations, lobby groups or food industry representatives. Their submissions, while important for understanding logistical challenges, represent a clear vested commercial interest in suggesting the content of a regulation that can undermine policy’s health goals.
“The number 14,000 is a distraction; the key is to categorize, not count,” added Dr. Gupta.
“This scale allows the committee to cut through the noise and focus on the gold-standard evidence that should form the foundation of this critical public health measure. The world is watching to see if Indian regulation can prioritize people over profits.”
NAPI has urged the FSSAI to adopt this framework to ensure a transparent process and to publish a report justifying its final decision based on evidence and ethics.
