Last Updated on April 28, 2024 by Dipika Chauhan

Food Labelling

To be continued……. FSSAI: Food Labelling and Display – Chapter-3

Navigating Exceptions: When Ingredient Disclosures Are Not Mandatory

In the intricate landscape of food labelling, exceptions exist to the rule of mandatory ingredient disclosure.

These exceptions, outlined under the Food Safety and Standards Act, offer a nuanced perspective on when certain disclosures can be omitted.

Let’s unravel the scenarios where ingredient disclosures are not required.

1. Flavouring Agents Exemption

(i) Flavouring Agents:

• The regulations extend leniency when ingredients are utilized solely as flavoring agents.
• In such cases, detailed disclosure may not be mandatory, recognizing that these components serve primarily to enhance taste without altering the fundamental composition.

2. Reference in the Name of Food Exception

(ii) Reference in the Name:

• When the name of the food explicitly references a particular ingredient or category of ingredients, detailed disclosures may be exempted.
• The name itself becomes a window into the product’s composition, providing consumers with a clear indication of key components.

3. Drained Net Weight Indication Exemption

(iii) Drained Net Weight Indication:

• If the label includes the drained net weight, fulfilling the requisite standards, the detailed disclosure of each ingredient might not be obligatory.
• This exemption acknowledges that certain products, like canned goods, can convey essential information through alternative means.

4. Specific Provisions Stipulated in Regulations Exception

(iv) Specific Provisions in Regulations:

• Where specific provisions are explicitly stipulated in the regulations for a particular food item, ingredient disclosure exemptions may apply.
• This recognizes that certain foods might have unique requirements that override the general guidelines.

5. Pictorial Representation for Consumer Information Exception

(v) Pictorial Representation:

• A serving suggestion presented through pictorial representation can serve as an alternative means of consumer information.
• In such instances, detailed ingredient disclosures may not be mandated, as the visual guide provides insight into the product’s use and composition.

6. Added Micro-Nutrients Subject to Nutrition Declaration Exception

(vi) Added Micro-Nutrients:

• Micro-nutrients, including vitamins, minerals, and amino acids, which are subject to nutrition declaration requirements under regulation 5 (3), may not necessitate a separate ingredient disclosure.
• The focus shifts to nutrition declaration, acknowledging the primary role of these components in enhancing nutritional value.

To be continued……. FSSAI: Food Labelling and Display – Chapter-5 (Coming soon)

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