This document discusses regulations on HFSS (high in fat, salt, and sugar) foods and possible approaches to promoting nutritional well-being. It notes that food regulations should follow principles of good governance, impact assessment, and scientific basis. While some Indian regulations have integrated food standards, objective data is still needed. Physical inactivity is a major public health issue. A balanced approach is needed that considers risk assessment, national food consumption surveys, consumer education through labeling, and an enabling ecosystem for responsible manufacturers and consumers. Guideline Daily Amount labeling could help consumers make informed choices to balance their diets.

1. To Regulate Or To Communicate:
Path To Nutritional Well Being
November 4th, 2016
Implications of Regulations on HFSS Foods
By - Sunil Adsule
Disclaimer: All the Images used herein are for representation purpose only

2. Regulation & Good Regulatory Practices (GRP)
• Any Measure or
Intervention
implemented under
Government Authority
• Acts to Control the
behavior of Individuals or
Groups that come within
the ambit of that
authority
Courtesy: ‘Regulatory Practices: Interpretation and Compliance’ – Dr. B Sesikeran, PFNDAI Conference, Mumbai-2016
Five Principles of GRP
• Good Governance
• Rigorous Impact
Assessment
• Scientific Basis and
Proportionality
• Open Consultation
• Minimal Restrictiveness
What is Regulation

3. How Food Regulations Fare on these principles
• FSSA Act – Integration of all
regulations - 2011
• Proprietary Food – 2013-14
• Harmonization of Additive
Standards 2011-1016
Examples P F A

4. Food & Beverage Industry’s Track Record - Examples
• Nutrition Labeling
• Pesticide Residue
Standards – Carbonated
Beverages
• Addition of Juice to
Sparkling(carbonated)
Beverages
Examples

5. HFSS Foods
o October, 2010, NGO “Udaya Foundation” filed a PIL in
the Delhi High Court - seeking ban on Sale of Certain
Food Groups
o Rationale given by the Petitioner – From media reports
and citing world wide concern
o FSSAI Set up an Expert Group – Participation from Public
Health Experts, NGOs and Industry
o FSSAI’s Central Advisory Committee approved the Draft
Guidelines for “Making Available Wholesome, Nutritious,
Safe & Hygienic Food to School Children in India”-Mar
2014
o March 2015 – Court issued order finalizing CAC’s draft

6. School Canteen Guidelines – Focus on Products – Ingredients of Concern ??
o Food Groups listed not with respect to ingredients of concern
o Identification : Risk Assessment ?
• Though Scientific Criterion listed in Guideline - Food Group
identification/listing is subjective
o Example of 2.3.10 Ready to Serve Fruit Drink

7. Brain Storming Session on “Foods for Health”
on 14th November, 2014 at NIN, Hyderabad
• Healthy Lifestyle includes Diet based on
– Balance
– Variety &
– Moderation
coupled with regular Physical Activity
commensurate with one’s age, gender and
body constitution
• There are No Good or Bad Foods – but diets
• Build consumer awareness on nutrients to limits
and component to encourage

8. Sources of Food Intake
o Food Cooked @
Home
o Restaurants / Out of
Home Consumption
o Processed (Packaged
Food)
Brain Storming Session on “Foods for Health”
on 14th November, 2014 at NIN, HyderabadConsumption Survey by NIN

9. Packaged Food
Branded QSRs
Food Consumption Pyramid and ……………
Unbranded Chains, Sweet
Makers, Restaurants, Street
Food
Food
Consumed@HOME
…………… The Ice Berg

10. o Unhealthy Diets and Physical
Inactivity are among the leading
causes of the major non-
communicable diseases (Ref. WHO -
GLOBAL STRATEGY ON DIET, PHYSICAL
ACTIVITY AND HEALTH 2004 - Clause 5)
o Physical activity and inactivity
patterns – ICMR-INDIAB study
• < 10% Indian engaging in Physical
Activity
o EduSports’ Annual School Health and
Fitness survey(2014)
• Covering 1,15,559 students across 287
schools in 85 cities
• 40 % of children don’t have healthy
Body Mass Index (BMI) levels
Physical Inactivity ??
Report Recommends
 Schools to raise play hours for children
 Physical activity/sports as an important
part of the curriculum
 Mandatory Playground / Sports facility
? ?

11. Responsive Ecosystem - Responsible Manufacturer & Consumer
Responsible Manufacturer
Responsible & Discerning
Consumer
Inclusive & Enabling Regulation
NGOs & Interest Groups:
Balance in building Awareness

12. FSSAI 10@10 Initiatives - SNF
oGreen Book
• Safe and Nutritious Food @ Home
o Striking a balance between Regulation and Education in reaching out to
consumers

13. Possible Way Forward!
• HFSS Regulation to factor in Risk Assessment
• National Food Consumption Survey
• Objective Data
• GDA Labeling as a tool to educate consumers
• Consumer Education Campaign

14. ILSI, India – Food Consumption Survey – Workshop – Dec 2015
• Highlighted the need for a National
Survey
– May be supported under PPP
• Comprehensive Objective Data to set
Policy Guidelines
• Key Recommendations
– Total Diet Survey – National
– Covering All the six regions of the Country
– Collecting comprehensive data on
• Nutritional status
• Prevalence of deficiency diseases as well as NCDs

15. Guideline Daily Amount (GDA) labeling
• Nutrition information of a Food
/Beverage
– In context to the daily dietary
requirement
• Informed choices on balancing
their diet for consumers
– by evaluating the energy and nutrient
contribution of a portion of a food
– as percentage of daily allowances for
these nutrients
Energy and other Nutrients
Percentage of Energy, Fat, Saturates, Sugars and Salt per portion of
the Food vis-à-vis Daily Requirement

16. Thank You