HEXAGONS & HALF-MEASURES: FSSAI’s LABEL DECLARATIONS WERE IN A
SHAPELESS STUPOR, TILL THE SUPREME COURT STEPPED IN
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Jawahar Lal, Managing Partner,
Shubhangi Singh, Associate,
Aastha Sachdeva, Associate
Background:
“Should India remain as an underdeveloped country?” With this observation, the Supreme Court on 13.08.20261 expressed its disapproval of the Union Govt.’s stand that India could not align its food-labelling standards with international standards.
India has a diverse history, religion, culture, language, geographical terrain and our cuisine differs drastically between regions & States. In Kerala, coconut is integral to every dish, while it is unheard of, north of Vindhyas. Gujarat sweetens everything (water excluded), we have food which is bland or almost banal, delicately balanced foods which nourish the body and mind, and spicy foods which scorch the tongue and even the soul!!! Due to the wide divergence in food habits, our grains, pulses, condiments, everything vary vastly.
Till Prevention of Food Adulteration Act, 1954 (“PFA, 1954”) came into force, we did not have a Central law on food, and there was no common definition, including for adulteration & standards. We had multiple State laws providing its own set of definitions, standards, penalty for adulteration, Rules etc. A standard permitted under a State Act was considered ‘adulteration’ in another, leading to utter chaos.
Hence, Parliament placed ‘food’ in the Concurrent List of the Constitution of India, and PFA, 1954 was brought into force, providing a comprehensive procedure to regulate the food sector. The PFA, 1954 provided for definition of adulteration, standards for ingredients, permitted colours, preservatives, basic requirements etc. Packaged foods were practically unheard of, hence the mandatory declaration on packaged food, dealt only with basic declarations like ingredient name, net weight, expiry date etc. Labelling disclosure for food additives was made mandatory for added colours, flavours, animal-origin ingredients, nutritional fortification etc.
International Standards – Codex:
In November, 1961, the Food and Agriculture Organization (under the UN), recognising the need to “protect consumer health and promote fair practices in food trade”, passed a Resolution to create Codex Alimentarius (“Codex”). In October, 1963, the Codex Alimentarius Commission (“CAC”) was formed “to guide and promote the elaboration and establishment of definitions and requirements for food, to assist in their harmonization and, in doing so, facilitate international trade”2 and India became a signatory in 1964.
In 1969, CAC released food standards, and over the decades, updating international standards, codes of practice, guidelines for products, food additives, contaminants, residues, labelling, inspection & certification systems, analysis, sampling methods, etc.
Food Safety & Standards Act, 2006
In 1998, based on the Joint Parliamentary Commission’s recommendation, the Law Commission was advised to develop a comprehensive law on food. Many years thereafter, the Food Safety & Standards Bill, 2005, was notified incorporating the salient features of the PFA Act,1954 and “based on international legislations, instrumentalities and Codex Alimentarius Commission (Codex)”.3
Hence, the Codex standards (released in 1969) were recognized by India, after 37 years & adopted (with modifications to suit Indian conditions) as the Food Safety and Standards Act, 2006 (“FSSA, 2006”) from 23.08.2006, replacing the PFA, 1954 and other legislations.
Following the FSSA, 2006, the Regulator - Food Safety and Standards Authority of India (“FSSAI”), framed Regulations governing food standards, additives, labelling, contaminants etc., largely leaning on Codex standards with modifications, to suit Indian conditions.
The FSSA, 2006 recognises this approach and Sections 16 (3) (m) and 18 (2) (a) require FSSAI to have regard to relevant international standards, while framing domestic food standards, taking into account Indian conditions and requirements.
In its April 2016 Newsletter4, the FSSAI expressly recognised Codex standards and guidance texts as the relevant international standards, and recorded that Indian food standards were being reviewed and harmonised with Codex “to the extent possible taking into account our needs”. The exercise covered, inter alia, standards relating to food additives and other food products, with the objective of bringing the domestic regulatory framework, closer to internationally accepted standards.
However, the measures of Govt. of India and the FSSAI, to adopt labelling Guidelines of CAC (formulated in consumer interest, including in relation to nutrition claims/disclosure), were half-hearted.
To elaborate, the CAC in 1964 , formed Codex Committee on Food Labelling (“CCFL”), recognising “the importance of labelling in protecting the health of consumers and ensuring fair practices in food trade”. Over time, CCFL developed a large number of standards/ guidelines including for labelling, nutrition claims etc., and stressed the importance of nutrition disclosure. By 2017, the draft Regulation of Front of Pack Labelling (“FoPL”/ “FoP”) nutrition disclosure was released by CCFL/CAC, to be adopted by member countries, with suitable modifications.
India had initiated steps towards a comprehensive food labelling framework in 2010; however, the process underwent several revisions, modifications and abrupt stops, over the years. Even today, the FSS Regulations do not fully address consumer interest relating to FoP disclosure of nutritional information, particularly sugar, salt, saturated fat etc., excessive consumption of which, may adversely affect consumer health.
The draft FSS Labelling Regulations, introduced in 2010 was finalized as FSS (Packaging and Labelling) Regulations, 20115 (notified on 01.08.2011). However, on 11.04.2018, the FSSAI proposed to segregate the labelling framework from packaging and circulated the draft FSS (Labelling and Display) Regulations, 2018, for comments from stakeholders.
In 2018, the journey of FSSAI towards prescribing FoP nutritional labelling started, when it proposed FoPL specifying nutritional labelling in the draft FSS (Labelling and Display) Regulations, 2018. The draft Regulations, proposed declaration on the FoPL regarding nutritional values i.e., energy, total fat/trans-fat, total sugar & salt, and contribution to Recommended Daily Allowance (“RDA”) etc.
On 25.06.2019, a fresh/formal draft titled as draft FSS (Labelling and Display) Regulations, 2019 was published. The FSSAI in a Press Release dated 25.06.20196, stated that it is undertaking a comprehensive revision of the FSS (Packaging and Labelling) Regulations, 2011 to make it more robust and effective. Further, it proposed to segregate Regulations for packaging, labelling, and advertisement and claims, “intended to provide consumers clearer information about food composition and enable more informed and healthier choices”7.
The labelling framework was ultimately finalized as the FSS (Labelling and Display) Regulations, 20208, notified on 17.11.2020. However, the FSSAI backtracked by stating that the FoP labelling component would be dealt with separately. Hence, though the FSS (Labelling and Display) Regulations, 2020 were notified, they did not contain the requirement of Front-Of-Pack-Nutritional-Value (“FoPNL”)
By draft FSS Labelling Regulations 2022 (notified on 13.09.2022), the FSSAI proposed a specific FoP Nutrition Labelling regime, introducing the Indian Nutrition Rating (“INR”) i.e., a star-rating system, with a higher star rating indicating a healthier product, to assist consumers to compare the star rating of products, and make an informed choice. The rating is based on factors such as energy content, sugar, salt, saturated fats, and beneficial components like protein, vitamins, minerals and fibre. The INR model integrates critical nutrients (such as added sugars, sodium, and saturated fats), and positive components (like fibre, protein, and certain legumes and nuts) in its scoring system.
After notifying the draft FSS Labelling Regulations, 2022, on 17.02.2023, the FSSAI constituted an Expert Committee, which would submit its Report, to be considered by the Scientific Committee of the FSSAI, for further recommendation and approval. Only thereafter the FSS (Labelling and Display) Regulations, mandating FoPNL was to come into force.
Hence, till date, the FoPNL system has not come into force, and the FSS Regulations continue to require elementary nutritional declarations largely on the Back of Pack (“BoP”). Recently, the Supreme Court in a PIL9 has emphasised that FoPL enables consumers to make informed and healthier dietary choices by declaring readily understandable nutritional information at the point of purchase. The Supreme Court has specifically noted that processed foods and foods high in sugar, fat and sodium increase the risk of obesity, diabetes, heart disease and hypertension, and that refined sugar, refined flour and trans-fat further heighten the risk of heart disease and obesity.
Ultra-processed foods (“UPFs”), which commonly contain additives such as preservatives, sweeteners and emulsifiers, apart from high levels of sugar, salt and fats, have emerged as a major dietary risk factor for non-communicable diseases. The Govt. of India Economic Survey 2024-25 records that the shift towards UPFs exposes individuals to adverse health outcomes including obesity and cardiovascular diseases10, while the Govt. of India Economic Survey 2025-26 records their association with obesity, chronic heart disease and diabetes11. Moreover, the burden of lifestyle diseases in India is substantial, with 10.1 crore persons estimated to have diabetes12, heart disease accounting for 28.1% of total deaths13, and overweight/obesity increasing from 9% to 22.9% among men and from 13% to 24% among women between 2005-06 and 2019-2114.
However, till date the FOPNL system has not come into force, and the FSSA Regulations continue to keep elementary declarations on the Back of Pack (BoP). The Nutritional Value, including the negative aspects and deleterious effects, of packaged food continues to be hidden within mandatory declarations made on the BoP, in small font size, and several negative aspects remain undeclared; hence unnoticed by consumers. The additives, preservatives etc. used in packaged food has a deleterious effect on health and is considered as the major cause for multiple diseases/conditions.
In the meantime, the FSSAI is chasing non-existent ghosts, initiating proceedings against manufacturers, who are declaring on the FoP and advertisements that their product is “100% pure” etc., without basis to contest the claim of 100% purity etc., on the ground that (a) such claims are not expressly permitted under the FSS Regulations and (b) Regulation 10 (7) of the FSS (Advertising and Claims), Regulations, 2018 prohibits an Advertisement or a claim which “undermines the products of any other manufacturer for the purpose of promoting their products or influencing consumer behaviour”.
To paraphrase, the stand of the FSSAI is that only those claims which are expressly permitted, can be made by a Food Business Operator (“FBO”), i.e., a FBO should assume that anything which is not expressly permitted, is prohibited (contrary to the first principle of law that prohibition ought to be explicit), and a FBO informing consumers that their food products are 100% pure etc., would undermine “…the products of any other manufacturer…”, who may not be selling a similar food product which is 100% pure (as it may contain other permitted ingredients).
While the Govt. of India and the FSSA has been ‘working’ on introduction of Nutritional Value etc. to be declared on the FoPL, the packaged food industry has exponentially grown from USD 2.6 billion15 in 2006 (when the FSSA, 2006 came into force) to USD 137 Billion16, expected to grow to USD 239 billion by 203417.
The key drivers for the growth of packaged food industry are - rising urban incomes, urban lifestyles with long working hours, nuclear families, quick commerce and the ability of delivery platforms to deliver anything across cities and towns instantaneously. Of course, Millennials, Gen Z and Gen Alpha generation, would be the single largest factor in the growth of the packaged food industry, for they believe in ordering online everything, except oxygen (unfortunately unavailable) through delivery platforms, including meals, small meals, packaged snacks, juices, aerated water etc.
In certain respects, the standards prescribed under the FSS regime are more liberal/ lax compared to corresponding Codex standards, while the FSSAI continues to lay considerable emphasis on inconsequential FoP declarations such as the vegetarian/non-vegetarian logo (which essentially reflects a consumer’s personal dietary choice rather than a health-related warning).
For instance, benzoates, including sodium benzoate (INS 211), a commonly used preservative in packaged foods and beverages, are permitted up to 600 mg/kg in water-based flavoured drinks under the FSS Regulations18, whereas Codex prescribes a maximum level of 250 mg/kg for the same food category19. The disparity is also evident in formulations of the same branded products across jurisdictions. Fanta sold in India contains 13.7 g of total/ added sugar per 100 ml20, whereas Fanta sold in the EU contains only 4.1 g of total sugar per 100 ml21, which is less than one-third of the Indian product, marketed under the same brand name.
Against this backdrop in 2024, a PIL22 was filed in the Supreme Court, seeking directions to the Union Govt./ FSSAI to bring into force, mandatory requirement to declare Nutritional Value on the FoP. On 09.04.2025, the Supreme Court after hearing the FSSAI and other stakeholders, disposed of the PIL, directing the Govt. of India/FSSAI to constitute an Expert Committee to finalise the recommendations, and to bring into force the FSS Labelling Regulations, providing for FoPNL, within three months.
However, despite repeated extensions, the proposed FoPNL framework has not been finalised and brought into force.
The Turning Point
Realising the lack of progress, on 10.02.2026, the Supreme Court firmly indicated to the FSSAI that its efforts so far had “not yielded any positive or good result,”23 and directed FSSAI to take steps to adopt FoPNL, and granted four weeks’ time to respond.
Response was filed by the FSSA that India could not match international labelling standards. On 13.08.2026 the Supreme realising that the lack of progress is seriously affecting public health, rejected the argument of FSSA.
Thereafter, by its Order dated 10.09.2026, the Supreme Court found that several aspects concerning the practical implementation of the proposed FoPL framework remained ambiguous and required further clarification. The Court stated that the proposed phased implementation, nutrient thresholds, form of the warning label and the manner of eventual compliance, requires further scrutiny and adjourned the hearing to 28.09.2026.
FSSAI Proposal regarding FoPNL filed before the Supreme Court:
The FSSAI has proposed the following, to be declared on the FoP:
A red, hexagon-shaped warning on the FoP, if a food product is high in two or more of three nutrients of concern i.e., added fat, added sugar and salt.
The hexagon would carry text naming whichever nutrients apply, such as “HIGH FAT” and “HIGH SALT” together, or all three where applicable.
Sweetened drinks that cross the sugar threshold would carry a separate “HIGHLY SWEETENED BEVERAGE” hexagon of their own.
The warning is proposed to be displayed in a font size one point larger than the font used for the nutrition information table on the back of the pack.
Whether a product counts as “high” in a given nutrient would be judged against the thresholds laid down in the Dietary Guidelines for Indians, 2024, issued by ICMR-NIN. These thresholds are currently referenced as the basis for the proposed front of the pack framework; they should not; however, be treated as independent statutory labelling limits unless and until incorporated into the applicable FSSAI Regulations through a notified amendment.
Two categories are proposed to be exempted from the FoP warning requirement: single-ingredient food products generally, and foods that are inherently rich in fat, sugar or salt, such as ghee, edible oil, salt, sugar, jaggery and honey. [Essentially, single ingredient products, consumers can consume at their own risk and bear the consequences, and FSSAI will not facilitate consumer awareness.]
The proposed blanket exemption for single-ingredient foods; however, raises a more fundamental concern. A food product does not become nutritionally neutral, merely because it contains only one ingredient. Ghee (clarified butter) is an obvious example. While moderate consumption of ghee may not, by itself, be harmful to the healthy population, it remains a concentrated source of fat and saturated fatty acids, and the nutritional consequence of its consumption would necessarily vary, with quality consumed and the overall health of the consumer. The WHO identifies ghee as a source of saturated fatty acids and recommends that saturated fat should not contribute more than 10% of total energy intake, to reduce the risk of diet-related non-communicable diseases, particularly cardiovascular disease.24
Indeed, scientific literature records that ghee has, over the last several decades, been implicated in the prevalence of coronary artery disease amongst Asian Indians because of its saturated fatty acid and cholesterol. The point, therefore, is not that ghee is inherently “unhealthy”, but that health risk cannot be determined merely by counting ingredients. Exempting such products altogether risks creating an artificial regulatory blind spot, particularly where the product is inherently high in saturated fat, sugar or salt and may be unsuitable for consumers required to restrict such intake.
FSSAI proposal to implement the FoPNL in two phases:
Rather than providing for, and mandating compliance with the grace period of 90 days or so in respect of all food products, the FSSAI has proposed rolling out the implementation in two stages:
Phase I: In respect of products which are high in two or more out of the three heads i.e., added fat, added sugar and salt, along with sweetened beverages that cross the sugar threshold. A product high in one head say sugar, would carry no warning at Phase-I.
Phase II, the requirement to cover products high even in even a single nutrient, would be made mandatory to enable the market/ consumers to have sufficient time to adjust to Phase I.
No specific dates have been proposed for either Phase; timelines are expected to follow once the framework is formally notified, hence may not even be implemented in the foreseeable future, unless the Supreme Court fixes the deadline.
In its hearing on 10.09.2026, the Supreme Court noted a disparity between the Draft FSS (Labelling and Display) Amendment Regulations, 2022 and Dietary Guidelines for Indians, 2024. While the former refers to HFSS (high in fat, sugar and salt) foods as “processed food product which has high levels of saturated fat or total sugar or sodium” the latter dilutes the same by referring to them as “those foods that are prepared with excessive cooking oils/fats or more added sugar and salt”. Hence, unless a food is high on total sugar and sodium, under the Dietary Guidelines for Indias, 2024, no FOPNL is necessary. To give an example an aerated drink will not be high on total sugar and sugar, hence, it would escape the requirement.
In this backdrop, the Supreme Court observed that the differing use of the conjunctive “and” and the disjunctive “or” reflects some confusion which needs to be resolved as a matter of priority, following which the basis of the phased strategy must be approached in accordance with the consensus arrived at on the definition of HFSS foods.
The Supreme Court also expressed concern regarding the absence of a fixed timeline separating Phase I and Phase II, observing that Phase II may otherwise take a backseat or be indefinitely postponed. It held that consumer acceptability or adequate time for industry reformulation could not be sufficient reason for such uncertainty, and required a reasonable, scientifically justified and clearly defined timeline or transitionary period between the two phases.
The Supreme Court has further indicated, prima facie, that phasing may instead be undertaken by progressively moving from relatively higher nutrient thresholds to scientifically appropriate lower thresholds within defined periods, rather than merely distinguishing between products which exceed two nutrients and those which exceed one. The FSSAI has been asked to consider this alternative while finalising its approach. In this backdrop, a statement was made on behalf of the FSSAI that they are willing to bring into force, both Phases.
When will FoPNL see the light at the end of the tunnel?
It is unfathomable, as FSSAI affidavit indicates that the proposal would need to be formally notified as an amendment to the relevant Regulations, following the prescribed procedure. Such process would involve the government approval and a timeframe given for public/stakeholders comments before the amendment can finally be notified. Hence, it is unfathomable when the proposed FoP warnings would be made a binding labelling requirement. Thankfully, the Supreme Court has, retained the matter for further consideration and it may issue further directions for completion of the regulatory process, the position may have clarity, on the next hearing.
On the question of mandatory compliance, the Supreme Court called upon the FSSAI to respond specifically to the suggestion that the final FoPL regime should be mandatory from the outset and, if not, to indicate the reasonable period after which compliance would become mandatory. The Court has further asked whether any voluntary period for compliance is envisaged after notification of the final regulations and, if so, for how long. Unless the Supreme Court ensures that the FOPL declaration is made mandatory, an suggestive/optional FOPL declaration, will be a mirage of consumer interest.
During the last hearing, the Supreme Court has directed the FSSAI to file its response by affidavit within ten days from 10.09.2026, and the Court would hear further suggestions/arguments on 28.09.2026.
FSSAI’s confluence of confusion, can be resolved by adopting Codex FOPNL:
Following the 43rd Session of the CCFL, Codex constituted an electronic working group to examine the need for global principles on FoPNL. The resulting 2017 CCFL Discussion Paper25 on FoPNL prepared for the 44th Session of CCFL, recognised FoPNL as a means to improve consumer understanding and support healthier food choices, particularly in the context of rising obesity and non-communicable diseases. It identified total fat, saturated fat, sugars, sodium and energy as key nutrients for front-of-pack disclosure.
The final Codex framework, contained in Annex 2 to the Guidelines on Nutrition Labelling26, provides that FoPNL should present simplified nutrition information on the front of pre-packaged food, in addition to the detailed nutrient declaration. It may be voluntary or mandatory under national law, and should be clearly visible, easy to understand, consistent with national dietary guidance, and capable of helping consumers compare products and make informed choices.
Though Codex has provided the framework, an effectibe FoPNL system suitable for India ought to be adopted, given the country’s level of literacy, educational attainment and, more importantly, nutritional comprehension.
As per the PLFS 2023-24,27 the literacy rate of persons aged seven years and above is 80.9%, while the World Bank records youth literacy amongst persons aged 15-24 at approximately 97%,28 these figures are required to be taken into consideration, with some caution. Literacy, measures the ability to read and write with ability to understand a short and simple statement, and does not necessarily establish an ability to comprehend technical nutritional information. The distinction assumes greater significance when educational attainment is considered. UDISE+ 2024-25 records an all-India Gross Enrolment Ratio of only 58.4% at the higher-secondary level29, and educational access and quality of imparting education remain uneven. In 2025-26, almost one lac schools across India are operating with a single teacher, including 7,874 schools in Uttar Pradesh and 2,006 in Bihar30. Thus, the ability to read a simple sentence cannot be equated with the ability to understand the nutritional significance of a food product.
Hence, the form in which FoPNL information is provided is of significant importance, a consumer may, for instance, know that excessive consumption of common salt is harmful without appreciating the significance of a declaration expressed technically in terms of “sodium”. Similarly, chemical or technical descriptions of additives, preservatives and nutrients may convey little meaningful information to consumers lacking nutritional literacy.
A FoPNL regime intended to influence choices at the point of purchase should therefore communicate nutritional risk through simple, conspicuous and readily understandable words, symbols, pictorial warnings, or colour-based indicators, rather than predominantly depending on numerical or technical declarations. This approach is consistent with Codex, which recognises that particularly where consumers have comparatively little knowledge of nutrition, food group symbols or other pictorial or colour presentations may be employed to facilitate understanding31.
Realising the reality, the Supreme Court by its Order dated 10.09.2026, observed that the proposed word-based FoPL may not adequately account for differences in literacy and comprehension, and suggested that words may be supplemented with pictorial representations. The Court also sought clarification on the size, placement, colour and use of separate hexagons for individual nutrients, and cautioned that reduction of sugar, fat and salt may lead to increased use of preservatives, emulsifiers and other additives, which FSSAI must consider while finalising the framework.
Way Forward
Even with Supreme Court intervention, it would take a minimum of 6-12 months for FSSAI to bring into force the FoPNL framework, and make it mandatory. In fact, there are several issues which requires closer attention and resolution. For example, while FSSAI has suggested the Hexagons, the size, spacing etc., need to be resolved by the FSSAI, especially in the context of smaller packs and sachets. Also, the draft Notification would have to be issued, consultation with stakeholders and FSSAI would have to seek Scientific Panel and Expert Committee etc., before the Regulations are notified and brought into force.
Hence, FBOs may use the interim period to assess their preparedness and potential exposure, and in this regard, the following aspects may be reviewed:
Mapping product portfolios against the ICMR-NIN 2024 nutrient thresholds to identify potentially affected SKUs and assess overall exposure;
Assessing the impact of the proposed distinction between added sugar/added fat and total sugar/total fat;
Reviewing existing packaging, artwork and available front-of-pack space for accommodating the proposed disclosures;
Assessing potential reformulation requirements, particularly for products likely to fall within both Phases; and
Prepare views, especially unique to their SKUs, so that when draft Notification is issued by the FSSAI, they can participate in stakeholder consultation and bring to the attention of FSSAI, constraints, if any, peculiar to their product range.
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In a PIL - 3S and Our Health Society v. Union of India
PRS Legislative Research, Legislative Brief: The Food Safety and Standards Bill, 2005, 13-2-2006, at: https://prsindia.org/files/bills_acts/bills_parliament/2005/legis1167478357_legislative_brief_food_safety_standards_bill_2005.pdf
FSSAI E-Newsletter, April 2016, at: https://fssai.gov.in/docs/footer/other/newslettr/Newsletter_April_2016.pdf
FSS (Packaging and Labelling) Regulations, 2011, Notification F. No. 2-15015/30/2010, dated 1-8-2011, Gazette of India, Extraordinary, Part III, Section 4.
FSSAI, Press Release, “FSSAI’s New Labelling and Display Regulations: Efforts to Encourage Consumers Make Healthier Food Choices”, dated 25-6-2019, at: https://www.fssai.gov.in/upload/press_release/2019/06/ 5d144d6a64d6dPress_Release_Labelling_Regulations_27_06_2019.pdf
Ibid.
FSS (Labelling and Display) Regulations, 2020, Notification F. No. 1-94/FSSAI/SP (Labelling)/2014 (Pt-2), dated 17-11-2020, Gazette of India, Extraordinary, Part III, Section 4.
Supra at 1
Economic Survey 2024-25, Ch. 11, available at: https://www.indiabudget.gov.in/budget2025-26/economicsurvey/ doc/eschapter/echap11.pdf
Economic Survey 2025–26, Ch. 11, available at: https://www.indiabudget.gov.in/ economicsurvey/doc/ eschapter/ echap11.pdf
Ministry of Health & Family Welfare, Update on Treatment of Diabetes, PIB, 1-8-2023.
Ministry of Health & Family Welfare, Update on Status of Treatment of Lifestyle Ailments, PIB, 3-2-2023.
Supra at 13.
2006-07, the FICCI-Technopak report Land of Opportunities
Exchange-rate fluctuations over the relevant period have not been factored into the comparison.
FSS (Food Products Standards and Food Additives) Regulations, 2011, App. A, Table 14, Food Cat. 14.1.4.
Codex Alimentarius Commission, GSFA, Food Cat. 14.1.4 (Benzoates-250 mg/kg)
Supra 1 above
3S and Our Health Society v. Union of India, M.A. No. 1177 of 2025 in W.P. (C) No. 437 of 2024, Order dated 10-2-2026 (SC).
WHO, Saturated Fatty Acid and Trans-Fatty Acid Intake for Adults and Children: WHO Guideline, 2023
Codex Committee on Food Labelling, Discussion Paper on Consideration of Issues Regarding Front-of-Pack Nutrition Labelling, CX/FL 17/44/7, Sept. 2017.
Codex Alimentarius Commission, Guidelines on Nutrition Labelling, CXG 2-1985, Annex 2, “Guidelines on Front-of-Pack Nutrition Labelling”, adopted 2021.
Ministry of Statistics and Programme Implementation, Government of India, Periodic Labour Force Survey (PLFS), Annual Report 2023-24
World Bank, World Development Indicators, “Literacy Rate, Youth Total (% of People Ages 15-24) - India”
Department of School Education and Literacy, Ministry of Education, Government of India, UDISE+ 2024–25, Table 6.1, p. 108
Rajya Sabha Unstarred Question No. 1165, “Vacancies in Schools”, answered on 29-7-2026, Annexure II (UDISE+ 2025-26)
Supra at 27
