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Making Clean Label Claims for Indian Food Market

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Clean label is a growing opportunity globally owing to the health concerns over adverse health effects of artificial ingredients and increasing consumer awareness on the use of consumer-friendly ingredients that are natural, organic, allergen free, non-GMO etc. The clean label does not have any regulatory or technical definition, but it is a subjective term referred with the consumer perspective of viewing food products as clean and straightforward. In India, the clean label market is still niche but is growing due to the growing consumer demand for clean, simple, and safe products. Consumers are increasingly showing interest in knowing the origin of food products, how it has made, and various artificial ingredients/additives associated with it. “All-natural,” “Organic,” “Free-from additives/preservatives,” are the various clean label claims becomingpopular in the Indian food market. In view of promoting such clean label claims, food manufacturersneed to ensure that the food label is truthful and not misleading.

Various clean label claims that can be made on the food products as per theFood Safety and Standards (Advertising and Claims) Regulations, 2018 from FSSAI are indicated below.

Products can be claimed “Natural”

Food can be claimed “Natural” if it is a single ingredient food derived from recognized sources such as plant, animal, microorganisms, and to which nothing has been added. Besides, the food should undergo processing such as roasting, blanching, dehydration, physical refining, smoking, chemicals free, freezing, concentration, pasteurization, sterilization, and fermentation. Even composite foods can make a claim “made from all-natural ingredients” if all its ingredients satisfy the criteria of natural. For example, a soup made from dehydrated vegetables can claim ‘made with natural ingredients” if all its ingredients and additives are obtained through the natural process as laid down in Food Safety and Standards(FSS). Food Business Operator (FBO) can also claim “Real” or ‘Genuine” in place of natural in such a way to imply similar benefits.

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Frozen food can be claimed as “Fresh”

A food product can be claimed as “Fresh” if it has only used the necessary process (such as washing, peeling, cutting, etc) to make the product safe for consumption without altering its fundamental characteristics. Also, if the process led to the extension of the shelf life of the product, then it is no more allowed to claim as “Fresh.” Not all frozen food can claim as “Fresh”. For example food containing additives, processed and preserved food cannot be called as “Fresh” despite being frozen. Besides, the fresh term can be used along with the term frozen such as “Freshly Frozen,” “Frozen from Fresh” or “Fresh Frozen” if it is clear from the context that food is immediately frozen while still fresh.

Original and Traditional Claims

If the origin of the product formulation or any process that is traceable and major ingredients are not substituted and remain unchanged over time, the product can claim as “Original.” Also, the product should remain available as a standard product even if its variants are available in the market.

Traditional claims are unique to the Indian market and not defined in any international regulations. The primary reason behind the traditional claim can be the sizeable traditional food market in India. The traditional snacks market valued USD 2.71 billion in 2018.

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No-added Sugar, salt and additives

No-added sugar claim has recently gained popularity in the market, with claims such as, Sugar-free juices, breakfast cereals, and bakery products. The product cannot claim “no-added-sugar” if it contains sugar and sugar is present in its ingredients. Also, if sugar is naturally present in any form in the product, the label has to imply by a statement “CONTAINS NATURALLY OCCURRING SUGARS.” Such a claim statement is defined to eliminate confusion among consumers that the product isfree from sugars. Also, if the sugar content in the product is increased by any process such as enzymatic process, even then, “No-added sugar” claim cannot be made.Similarly, the no-added salt claim can be made for food products if the product or any ingredient present in the product contains no added Sodium Chloride. Composite food can also claim as “no-added additives” if it does not contain any added preservatives/additives.

It is also imperative for a company to know the target consumers for clean label products so that clean label claims can be tailored accordingly. For example, no-added-sugar claims can be targeted for diabetic consumers or mid-age group consumers. The nutritional and health claims, if not appropriately mentioned, can be confusing for the consumers. The Advertising and Claims Regulation, 2018 offers the opportunity for FBO to make clean label claims without requiring any approvals.Also, only foods that fit certain nutrition profile can carry claims. This regulation will benefit consumer and raise confidence in the products and the claims.

Reference: Food Safety and Standards (Advertising and Claims) Regulations, 2018

Authored by Saujanya Suman from Sathguru management consultants

Email - Saujanyas@sathguru.com.


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