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To Regulate Or To Communicate:

Path To Nutritional Well Being

November 4th, 2016

By - Sunil Adsule

Implications of Regulations on HFSS Foods

Disclaimer: All the Images used herein are for representation purpose only
Regulation & Good Regulatory Practices (GRP)
What is Regulation Five Principles of GRP

Any Measure or Good Governance

implemented under Rigorous Impact
Government Authority Assessment
Scientific Basis and
Acts to Control the Proportionality
behavior of Individuals or
Groups that come within Open Consultation
the ambit of that Minimal Restrictiveness

Courtesy: Regulatory Practices: Interpretation and Compliance Dr. B Sesikeran, PFNDAI Conference, Mumbai-2016
How Food Regulations Fare on these principles

FSSA Act Integration of all

regulations - 2011

Proprietary Food 2013-14

Harmonization of Additive
Standards 2011-1016
Food & Beverage Industrys Track Record - Examples

Nutrition Labeling

Pesticide Residue
Standards Carbonated

Addition of Juice to
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 FSSAIs Central Advisory Committee approved the Draft
Guidelines for Making Available Wholesome, Nutritious,
Safe & Hygienic Food to School Children in India-Mar
o March 2015 Court issued order finalizing CACs draft
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

Brain Storming Session on Foods for Health
on 14th November, 2014 at NIN, Hyderabad

Healthy Lifestyle includes Diet based on

Variety &
coupled with regular Physical Activity
commensurate with ones 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
Brain Storming Session on Foods for Health
Consumption Survey by NIN on 14th November, 2014 at NIN, Hyderabad

Sources of Food Intake

o Food Cooked @

o Restaurants / Out of
Home Consumption

o Processed (Packaged
Food Consumption Pyramid and
The Ice Berg

Branded QSRs

Packaged Food

Unbranded Chains, Sweet

Makers, Restaurants, Street

Food Consumption Pyramid and
The Ice Berg

Branded QSRs

Packaged Food

Unbranded Chains, Sweet

Makers, Restaurants, Street


Physical Inactivity ??
o Unhealthy Diets and Physical
Inactivity are among the leading
causes of the major non-
communicable diseases (Ref. WHO -
ACTIVITY AND HEALTH 2004 - Clause 5)

o Physical activity and inactivity

patterns ICMR-INDIAB study
< 10% Indian engaging in Physical

Report Recommends
o EduSports Annual School Health and Schools to raise play hours for children
Fitness survey(2014) Physical activity/sports as an important
part of the curriculum
Covering 1,15,559 students across 287 Mandatory Playground / Sports facility
schools in 85 cities ??
40 % of children dont have healthy
Body Mass Index (BMI) levels
Responsive Ecosystem - Responsible Manufacturer & Consumer

Responsible Manufacturer

Inclusive & Enabling Regulation

Responsible & Discerning


NGOs & Interest Groups:

Balance in building Awareness
FSSAI 10@10 Initiatives - SNF
o Green Book
Safe and Nutritious Food @ Home

o Striking a balance between Regulation and Education in reaching out to

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

ILSI, India Food Consumption Survey Workshop Dec 2015
Highlighted the need for a National
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
Guideline Daily Amount (GDA) labeling
Nutrition information of a Food Energy and other Nutrients

In context to the daily dietary

Informed choices on balancing

Percentage of Energy, Fat, Saturates, Sugars and Salt per portion of
their diet for consumers the Food vis--vis Daily Requirement

by evaluating the energy and nutrient

contribution of a portion of a food
as percentage of daily allowances for
these nutrients
Thank You