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NotificationHigh impact3 weeks ago

FSSAI notifies front-of-pack nutrition labelling regulations

Star rating disclosure becomes mandatory on packaged food with a two-year implementation window and specified display requirements.

FSSAI has notified the front-of-pack nutrition labelling regulations, requiring a star rating on the principal display panel of most packaged foods, with effect from 1 July 2028.

What is required

Products in scope must display an Indian Nutrition Rating in the form of a star rating from half a star to five stars, calculated using the prescribed algorithm based on energy, saturated fat, total sugar and sodium content per 100g or 100ml, with positive adjustments for fruit, vegetable, nut, legume and fibre content.

Display specifications govern size relative to the principal display panel, placement and contrast.

The two-year window is a formulation window

The instinct is to treat this as an artwork change and schedule it accordingly. That reading misses the commercial point.

The rating is calculated from composition. A brand unhappy with its rating has one substantive remedy: reformulate. Reformulation involves recipe development, stability and shelf-life testing, consumer acceptance testing, supplier qualification for new ingredients and manufacturing trials — a two-year programme for a portfolio of any size, not a two-year buffer before an artwork run.

Companies that spend 2026 and 2027 planning artwork and 2028 discovering their ratings will have no remaining options.

What to do in sequence

  1. Calculate the rating for every SKU using the notified algorithm, now
  2. Identify SKUs where the rating is commercially problematic in their category context
  3. Assess reformulation feasibility and cost for those, with realistic development timelines
  4. Decide portfolio by portfolio: reformulate, accept the rating, or reposition
  5. Schedule artwork last, once composition decisions are final

Step one takes a few weeks and is the input to every decision that follows. Very few companies have completed it.

Competitive dimension

Ratings are comparative in effect if not in design. A three-star product beside a four-star competitor on the same shelf has a commercial problem irrespective of whether either is nutritionally adequate.

Category-level competitive analysis of likely ratings is worth doing alongside the internal calculation, because the decision on whether a rating is acceptable depends on what sits next to it.

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This analysis is provided for information only and does not constitute legal advice. Read it alongside the primary source it cites. Where a source reference is given (F.No. Std/SP-05/A/FSSAI-2026), that is the authoritative text.

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