The Supreme Court on Thursday pulled up the country’s apex food regulator for not implementing a front-of-pack warning label in the months since its previous direction in February. “Are you taking the court for a toss? …. Will you do it on your own or should we pass an order?” Justice Pardiwala asked.So, what is this front-of-pack warning label? It is essentially a red or black coloured graphic — perhaps in combination with words such as ‘high in fats, sugars, and salts — that can inform a consumer at a glance whether the product they are buying is healthy or not.For nearly six years, the Food Safety and Standards Authority of India (FSSAI) has been trying to implement some form of front-of-pack label to inform people whether a food is healthy or not. And, in a 2022 draft notification, it proposed a health star rating. It was meant to be similar to the ones seen on electrical appliances indicating whether they are energy efficient. The unhealthiest food products would receive the lowest star ratings, while healthy ones would get higher ratings of up to five stars. The health experts challenged this method, stating that a simple, objective graphic that can immediately warn a consumer against an unhealthy product would be much better at preventing consumption.First, what is happening at present?The lack of consensus on the type of graphic that should be used — and consequent indecision and delays — has meant that these labels have not made it to the food packets yet. The 2022 draft notification made the star-rated front-of-pack label mandatory four years after implementation. That deadline has passed, but the front-of-pack label continues to be in limbo.The food safety regulator had, as part of the ongoing court case, proposed implementing a label that showed daily recommended limits for added sugar, added saturated fat and salt in a tabular format. The health activists rejected this, stating that the whole point was to ensure that consumers could make an instant and informed choice. With such a table, the onus would still be on the consumer to do the calculations before purchasing an item, defeating its purpose.Now, the court has directed the apex food regulator to come back in two weeks and inform the court what is being done.What are likely to be the next steps?The process of implementing the front-of-pack warning label can go one of two ways:Story continues below this adFirst, the food safety regulator can completely overhaul its 2022 draft notification and go back to the drawing board — hold stakeholder consultations and formulate a new policy. This process is likely to take a year, considering that the regulator would have to meet with stakeholders, issue a draft notification, incorporate possible suggestions, and then issue the final notification.Also read | ‘All luxury litigations’: SC declines to hear PIL on packaged drinking water standardsTwo, it can just make changes to its previous 2022 draft notification. “Stakeholder consultations have already been held for the 2022 notification — there is already a consensus on most aspects of the notification such as the definition of HFSS foods (high fat, sugar, salt foods) and exemptions of single ingredient foods such as whole milk or whole cereals,” said Dr Arun Gupta, Convener, Nutrition Advocacy for Public Interest (NAPi). He added: :The regulator will just need to replace the health star rating with a warning label — whether they use a red symbol or a black one, I don’t think stakeholders would have a problem against it. Using a small message stating ‘ high in fats, sugars, and salts’ in two languages will be more effective.”He said that there would also need to be a change in the time-frame for mandatory implementation. “The previous notification gave the industry four years to mandatorily introduce the front-of-pack label. That time has now already passed. So, we hope that the regulator now shortens this window to say six months or a year.”What are the different types of front-of pack labels?There are several ways in which the nutritional information can be provided on the front of a pack:Story continues below this ad· Daily Intake Guide — A panel that says what proportion of the daily recommendations of nutrients is present in one serve of the pre-packaged food.· Nutrition Information Panel – A panel that provides the quantity of each of the main nutrients present in the food.· Traffic Light Labelling – A panel that not only shows the amount of fats, salts, sugars, and other nutrients present in a serving of the packaged food, but also colours it red, orange, or green based on how healthy it is.· Warning Label – A colour-coded or written label that shows whether the quantity of salts, sugars, and fats is high, without providing any details of the quantities in the food.Story continues below this ad· Star rating – A label that provides say one to five starts based on how healthy the product is, with five being the healthiest. It doesn’t provide a break-up of the nutrients.Which type of front-of pack label is the most effective?Globally, front-of-pack labels have emerged as a way to ensure that consumers choose healthier packaged foods, with at least 44 countries introducing such a policy and at least 16 making it mandatory.Countries such as Australia and New Zealand use a health star rating; others such as Netherlands, Czech Republic, and Singapore use symbols on products that are the healthier choice, UK uses a traffic light method where the amount of salt, sugar, and fats are mentioned along with the colour coding of red, yellow, or green; and countries like Chile use a black stop signal to prevent people from buying unhealthy products.A position paper by organisations such as Public Health Foundation of India, Centre for Science and Environment, and Indian Academy of Paediatrics states that there was a change in consumption pattern in several Latin American countries that implemented such warning labels, with Chile witnessing a 24% drop in sugary drink consumption. It said that a meta-analysis of 100 studies published last year indicated that nutrient warning labels are more effective than traffic lights and nutri-score labels. This paper has been quoted by the expert committee as well as the economic survey in drawing its inference.