The Food Safety and Standards Authority of India (FSSAI)'s attempt to introduce health star ratings (HSR) on front-of-the-pack labels (FOPLs) to discourage the use of junk food could be a flawed idea in the Indian context, warns a recent study.

The yet to be peer-reviewed study, prepared by a group of researchers led by Lindsey Smith Taillie of the University of North Carolina, concludes that an HSR representation might be the least effective option among various FOPLs that have been prescribed by various food standard regulators across the world. The results suggest that the direct "warning labels" are the most effective FOPL to help Indian consumers identify and avoid unhealthy foods.

The researchers conducted an in-person randomised experiment in 2,869 adults between ages 18 and 60 years old in six states of India in March 2022. "Participants were randomized to one of five FOPLs: a control label (barcode), warning label (octagon with "High in [nutrient]"), Health Star Warning (HSR), Guideline Daily Amount (GDA), or traffic light label. Participants then viewed a series of foods high in sugar, saturated fat, or sodium with the assigned FOPL, and rated product perceptions and label reactions. Fewer than half of participants in the control group (39.1%) correctly identified all products high in nutrient(s) of concern. All FOPLs led to an increase in this outcome, with the biggest differences observed for the warning label (60.8%) followed by the traffic light label (54.8%), GDA (55%), and HSR (45%). Relative to the control, only the warning label led to a reduction in intentions to purchase the products. The results suggest that warning labels are the most effective FoPL to help Indian consumers identify and avoid unhealthy foods," the study notes.

The World Health Organisation (WHO) has recommended the use of FOPLS to reduce consumption of packaged foods high in added sugar, sodium, saturated fat, and trans fats as studies globally suggest excessive consumption of ready-to-eat or ready-to-heat foods and drinks that are high in added sugars, sodium, saturated fats, and refined carbohydrates etc increase risk of obesity and related non communicable diseases (NCDs).

The researchers found that the HSR system was the lowest-performing FOPL relative to others with regards to helping consumers identify "high-in" products, and had no impact on behavioral intentions. "One likely reason for the HSR's low performance is that it was designed with different public goals in mind. While warnings are designed with the goal to discourage the most unhealthy purchases, while others, like the HSR are designed to nudge towards "healthier purchases", the study says.

"We oppose the recommendation for use of HSR Model in India due to the reasons that health star ratings are taken with a positive connotation and do not meet the intention of FOPL regarding warning for negative nutrients, which may be overwhelmed by positive nutrients in the algorithm design for HSR. Other the other hand, negative warning labels that efficiently help identify unhealthy products have proved to be most effective for discouraging junk food and ultra-processed food choices. They are simple enough to understand and can be used without sustained investments in educational campaigns. It would also act as an efficient tool to guide those consumers who are medically advised to reduce the intake of fat, sugar, or salt in their diet, thereby encouraging them towards a healthy eating habit," George Cheriyan, Director of CUTS International, and a member of stakeholder group of FSSAI on FOPL from January 2021, says.

Incidentally, FSSAI move was based on a study carried out by researchers of IIM, Ahmedabad which looked at "consumer preferences for different nutrition FOPLs in India" in a sample size of 20,564 persons across India. The IIM-A study concludes that HSR and 'Warning Labels' are in the highest pecking order from the perspective of ease of identification, understanding, reliability and influence. "Among the two, HSR appears most acceptable, outdoing the nutrient specific formats on ease of understanding," it said.

However, the survey indicated that the chief concern of the opponents of HSR – that it does not clearly tell the exact percentage of unhealthy nutrient or ingredient - is valid. According to IIM-A, it was MTL (multi traffic light) model that was most preferred when it came to reflecting necessary health information and presence of an unwanted nutrient.

As FSSAI shows no inclination to change its stand, the consumer organisations in India – around 100 organisations from 15 states - have jointly opposed the move to introduce HSR. "All the consumer organisations strongly feel that such HSR system can easily be manipulated by the food manufacturing and processing industry and the objective of consumer health can never be achieved," Cheriyan says.

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