By S&S Co. Advocates & Solicitors · Published 15 October 2026 · Informational content, not legal advice: see our disclaimer
A packaged food or beverage client asking whether they need a warning label on the front of their product right now deserves an honest answer: not yet, but the runway to get ready for it is shorter than it looks. Front-of-pack nutrition labelling, commonly called FOPL, has been through more than one redesign since the draft regulations first appeared in 2022, and it is currently being pushed along by the Supreme Court itself rather than by FSSAI moving on its own timetable.
This guide sets out where things actually stand, what the latest proposed design looks like, and what a food business should be doing in the meantime so that a final notification does not catch its packaging, labelling vendors and claims substantiation files unprepared.
How We Got Here: The Draft That Would Not Finalise
FSSAI first notified draft Front-of-Pack Nutrition Labelling regulations on 13 September 2022, inviting public comment on a scheme meant to flag packaged foods high in fat, sugar or salt with a visible mark on the front of the pack, separate from the existing back-of-pack nutrition information table. The draft drew an unusually large volume of stakeholder input, reported at well over fourteen thousand comments, and has remained under examination since, with no final regulation notified years after the draft stage closed.
A parliamentary standing committee reviewing the issue expressed open frustration at the pace of this process, urging FSSAI to finalise the regulations on a time-bound basis rather than allow the draft to remain pending indefinitely. That kind of institutional pressure, from a parliamentary committee on one side and public health litigation on the other, is part of why the picture has started moving again after a long period where it looked stalled.
The Supreme Court Has Stepped In
In proceedings in 3S and Our Health Society v. Union of India, the Supreme Court has been pressing FSSAI directly on its plans. By an order dated 10 February 2026, the Court directed FSSAI to seriously consider introducing mandatory front-of-pack warning labels, and called for a response within four weeks on its position. The matter did not end there. At a hearing on 28 September 2026, the Court questioned FSSAI's proposal to give the industry a full three hundred and sixty five days of voluntary implementation after any eventual notification, and reserved its judgment rather than approving the timeline on the spot.
As of now, no final judgment disposing of that challenge to the voluntary implementation period has been reported. This means the regulatory and litigation tracks are both live at the same time: FSSAI has a proposed design and a proposed grace period, and the Supreme Court has signalled real scepticism about how long that grace period should be, without yet ruling definitively on it.
What the Current Proposal Actually Looks Like
The latest version of FSSAI's approach has moved away from an earlier, more complex multi-tier design toward a single warning trigger. Under this single-phase approach, a product that exceeds a prescribed threshold for a specified nutrient, such as added sugar, saturated fat or sodium, would be required to carry a warning mark on the front of the pack. The proposed mark itself is described as a red hexagon set on a white square, a deliberately high-contrast design intended to be noticed at a glance on a crowded shelf or in a quick scroll through an e-commerce listing.
This single-trigger design is a considerable simplification compared to some of the earlier, more granular star-rating or colour-coded systems that had been discussed during the comment period. For a food business, the practical question a single-trigger system raises is binary rather than graded: does this specific product cross the threshold for any one of the specified nutrients, and if so, the pack needs the mark regardless of how it performs on the others.
Why the Exact Thresholds Should Not Be Treated as Fixed Yet
Because the regulation has not been finalised, the specific numeric thresholds for sugar, fat and sodium that would trigger the warning are still subject to change, and different secondary sources describing the draft and subsequent revisions have not consistently reported identical figures. Any business that builds its reformulation or labelling plan around a specific number taken from a news report at this stage risks having to redo that work once the final notification, if and when it comes, fixes the actual thresholds.
The more useful planning exercise right now is directional rather than numeric: identify which products in a portfolio sit closest to whatever thresholds are being discussed in the draft materials, and treat those as the priority candidates for either reformulation or early labelling preparation, while deferring final artwork decisions until the notified thresholds are actually published.
What a Food Business Should Be Doing Right Now
Even without a final notification, there are concrete, low-risk steps worth taking. Review existing nutrition panels for accuracy, since any new front-of-pack trigger will be calculated off the same underlying nutrient values already declared on the back of the pack, and an error there will carry straight through. Map which SKUs in the portfolio would likely be affected under a reasonably conservative reading of the draft thresholds, so that reformulation decisions, where commercially viable, can begin before a hard deadline forces a rushed change.
It is also worth keeping a watching brief on both tracks described above, the FSSAI regulatory process and the Supreme Court proceedings in 3S and Our Health Society, since either one could move the actual compliance date. A business that assumes the full three hundred and sixty five day voluntary period will survive unchanged, given the Court's visible scepticism about it at the September 2026 hearing, is making an assumption that may not hold once judgment is delivered.
How This Sits Alongside Existing Labelling and Claims Rules
Front-of-pack warning labelling would sit on top of, not instead of, the existing obligations under the Food Safety and Standards (Packaging and Labelling) Regulations, including the back-of-pack nutrition information panel and the general prohibition on misleading claims. A business that already has a disciplined process for substantiating nutrition and health claims on its labels is in a reasonably good position to absorb a front-of-pack requirement once it arrives, since the underlying nutrient data and verification discipline required are largely the same. A business without that discipline already in place has considerably more catching up to do than the headline news about a hexagon on the front of a pack might suggest.
There is a second, less obvious overlap worth flagging. A product already carrying a voluntary health or nutrition claim on its front panel, such as a reference to being low in sugar or a good source of protein, will need that claim checked against whatever nutrient values would also trigger a warning mark once the new rule is in force. A claim and a warning sitting side by side on the same pack, drawing attention to one virtue while a mandatory mark flags a different problem, is a labelling design question worth thinking through well before the compliance date arrives, not something to sort out at the last minute once artwork is already being finalised.
Frequently Asked Questions
Is front-of-pack warning labelling mandatory for packaged food in India right now?
No. As of the most recent reported hearing, the regulation remains in draft and under active consideration, with the Supreme Court having reserved judgment on a related question about the implementation timeline. There is no final notified requirement to comply with yet.
What will the warning actually look like if it is finalised in its current proposed form?
The latest proposal describes a single warning mark, a red hexagon on a white square, applied when a product exceeds a prescribed threshold for a specified nutrient such as added sugar, saturated fat or sodium. The exact thresholds have not been finally fixed.
How much time will businesses get to comply once the rule is finally notified?
FSSAI has proposed a voluntary implementation period of three hundred and sixty five days after notification. The Supreme Court questioned this timeline at a September 2026 hearing and reserved judgment, so the final period allowed may change once that judgment is delivered.
Should we start reformulating products now based on the numbers in the draft regulation?
Treat any specific threshold figure reported at this stage as provisional. It is more useful to identify which products sit close to the kind of thresholds under discussion and prepare for either reformulation or labelling change, without finalising artwork or formulations around numbers that have not been notified.
Does this affect the nutrition information panel we already print on the back of our packs?
No, front-of-pack labelling would be an addition on top of the existing back-of-pack nutrition panel required under the Packaging and Labelling Regulations, not a replacement for it. Both would need to remain accurate and consistent with each other.
References & Further Reading
The provisions and rulings below were relied on for this guide. The position can change with amendments and later decisions, so check the current text and the latest case law before acting on any of it.
- Draft Food Safety and Standards (Labelling and Display) Regulations / Front-of-Pack Nutrition Labelling proposal, notified by FSSAI, 13 September 2022
- 3S and Our Health Society v. Union of India, Supreme Court of India, order dated 10 February 2026
- 3S and Our Health Society v. Union of India, Supreme Court of India, hearing of 28 September 2026 (judgment reserved)
- Food Safety and Standards (Packaging and Labelling) Regulations, 2011