To Regulate Or To Communicate: Path To Nutritional Well Being

November 4th, 2016

Implications of Regulations on HFSS Foods

By - Sunil Adsule

Disclaimer: All the Images used herein are for representation purpose only

Regulation & Good Regulatory Practices (GRP)

• Any Measure or Intervention implemented under Government Authority

• Acts to Control the behavior of Individuals or Groups that come within the ambit of that authority

Courtesy: ‘Regulatory Practices: Interpretation and Compliance’ – Dr. B Sesikeran, PFNDAI Conference, Mumbai-2016

Five Principles of GRP

• Good Governance• Rigorous Impact

Assessment• Scientific Basis and

Proportionality• Open Consultation• Minimal Restrictiveness

What is Regulation

How Food Regulations Fare on these principles

• FSSA Act – Integration of all regulations - 2011

• Proprietary Food – 2013-14

• Harmonization of Additive Standards 2011-1016

Examples P F A

Food & Beverage Industry’s Track Record - Examples

• Nutrition Labeling

• Pesticide Residue Standards – Carbonated Beverages

• Addition of Juice to Sparkling(carbonated) Beverages

Examples

HFSS Foods

o October, 2010, NGO “Udaya Foundation” filed a PIL in the Delhi High Court - seeking ban on Sale of Certain Food Groups

o Rationale given by the Petitioner – From media reports and citing world wide concern

o FSSAI Set up an Expert Group – Participation from Public Health Experts, NGOs and Industry

o FSSAI’s Central Advisory Committee approved the Draft Guidelines for “Making Available Wholesome, Nutritious, Safe & Hygienic Food to School Children in India”-Mar 2014

o March 2015 – Court issued order finalizing CAC’s draft

School Canteen Guidelines – Focus on Products – Ingredients of Concern ??

o Food Groups listed not with respect to ingredients of concern

o Identification : Risk Assessment ?• Though Scientific Criterion listed in Guideline - Food Group

identification/listing is subjective

o Example of 2.3.10 Ready to Serve Fruit Drink

Brain Storming Session on “Foods for Health” on 14th November, 2014 at NIN, Hyderabad

• Healthy Lifestyle includes Diet based on – Balance – Variety & – Moderation

coupled with regular Physical Activity commensurate with one’s age, gender and body constitution

• There are No Good or Bad Foods – but diets

• Build consumer awareness on nutrients to limits and component to encourage

Sources of Food Intake

o Food Cooked @ Home

o Restaurants / Out of Home Consumption

o Processed (Packaged Food)

Brain Storming Session on “Foods for Health” on 14th November, 2014 at NIN, HyderabadConsumption Survey by NIN

Packaged Food

Branded QSRs

Food Consumption Pyramid and ……………

Unbranded Chains, Sweet Makers, Restaurants, Street Food

Food Consumed@HOME

…………… The Ice Berg

o Unhealthy Diets and Physical Inactivity are among the leading causes of the major non-communicable diseases (Ref. WHO -GLOBAL STRATEGY ON DIET, PHYSICAL ACTIVITY AND HEALTH 2004 - Clause 5)

o Physical activity and inactivity patterns – ICMR-INDIAB study

• < 10% Indian engaging in Physical Activity

o EduSports’ Annual School Health and Fitness survey(2014)

• Covering 1,15,559 students across 287 schools in 85 cities

• 40 % of children don’t have healthy Body Mass Index (BMI) levels

Physical Inactivity ??

Report Recommends Schools to raise play hours for children Physical activity/sports as an important

part of the curriculumMandatory Playground / Sports facility

? ?

Responsive Ecosystem - Responsible Manufacturer & Consumer

Responsible Manufacturer

Responsible & Discerning Consumer

Inclusive & Enabling Regulation

NGOs & Interest Groups:Balance in building Awareness

FSSAI 10@10 Initiatives - SNF

oGreen Book • Safe and Nutritious Food @ Home

o Striking a balance between Regulation and Education in reaching out to consumers

Possible Way Forward!

• HFSS Regulation to factor in Risk Assessment

• National Food Consumption Survey • Objective Data

• GDA Labeling as a tool to educate consumers

• Consumer Education Campaign

ILSI, India – Food Consumption Survey – Workshop – Dec 2015

• Highlighted the need for a National Survey– May be supported under PPP

• Comprehensive Objective Data to set Policy Guidelines

• Key Recommendations– Total Diet Survey – National – Covering All the six regions of the Country – Collecting comprehensive data on

• Nutritional status • Prevalence of deficiency diseases as well as NCDs

Guideline Daily Amount (GDA) labeling

• Nutrition information of a Food /Beverage – In context to the daily dietary

requirement

• Informed choices on balancing their diet for consumers– by evaluating the energy and nutrient

contribution of a portion of a food – as percentage of daily allowances for

these nutrients

Energy and other Nutrients

Percentage of Energy, Fat, Saturates, Sugars and Salt per portion of the Food vis-à-vis Daily Requirement

Thank You