Which FSSAI labelling mistakes get food brands into trouble?

1. A claim that sounds true but doesn't hold up

Claims such as “no added sugar”, “natural” or “100%” draw the most scrutiny. Under the Advertising and Claims Regulations, 2018, claims must be “truthful, unambiguous, meaningful, not misleading” (regulation 4(1)), and advertising claims must be consistent with the label (regulation 4(12)).

For sugars specifically, a non-addition claim is permitted only if no sugars of any type are added, no ingredient containing sugars is used, no sugar substitutes are used, and the food's own sugar content has not been raised by other means (regulation 6(1)(a)). Where sugars are naturally present, a claim may be made only with the statement “CONTAINS NATURALLY OCCURRING SUGARS” (regulation 6(1)(b)). The “free” threshold is not more than 0.5 g sugars per 100 g or 100 ml (Schedule I).

In one widely reported case, a brand's “no added sugar” claim was challenged by a competitor because the product was sweetened with a concentrated fruit ingredient. The brand first defended the claim, then changed its wording. The lesson: test a claim against the regulation's conditions ingredient by ingredient, not against what feels fair.

The stakes: misleading advertising can be penalised under Section 53 of the Food Safety and Standards Act, 2006, which provides for a penalty of up to ₹10 lakh.

2. A missing or wrong FSSAI licence number

The brand owner's FSSAI logo and licence number must be on the label in a colour that contrasts with the background. If the manufacturer, marketer, packer or bottler is a different party, their licence number is required too (regulation 5(7)). A wrong digit is as bad as a missing number.

3. The veg/non-veg logo

FSSAI says this declaration cannot be exempted, even on packs up to 100 cm², and that the product name and logo go on the front of the pack only. The minimum logo size depends on the area of the principal display panel (regulation 5(4)(c)):

4. Nutrition table errors

Typical errors: the wrong term (it must be “% RDA”, not “% Daily Value”), missing declarations, and values that don't match the lab report. Some foods are exempt, including raw, minimally processed agricultural products and single-ingredient foods with no additives. A table can be right when created and wrong at print because someone edited a number later. The RDA used for added sugars is 50 g.

You can build a table from your lab report with the free nutrition table generator.

5. Allergen declarations

Allergens must be declared as clause 5(14) requires. Raw, unprocessed commodities such as pulses, cereals, spices and fruit are exempt. Sulphite must be declared only at 10 mg/kg or more, measured as sulphur dioxide. For cross-contamination, “May contain” is an illustrative wording and any format with a similar meaning may be used.

6. Date format and character size

For products with a shelf life over three months you can show the month and year in an un-coded numerical sequence, or use DD/MM/YY. DD/MM/YYYY, DD/MMM/YY and DD/MMM/YYYY are also accepted, with month abbreviations of at least three letters.

Minimum character height depends on the principal display panel (PDP) area (regulation 6(3)). The table below is the version substituted into the regulation and operational from 1 July 2022:

The PDP is at least 40% of height × width of the largest panel for rectangular packs, at least 40% of height × average circumference for cylindrical or oval packs, and at least 20% of total surface area for other shapes (regulation 6(2)). Packs with a surface area of 100 cm² or less are exempt from several items, such as the ingredients list and nutrition information (regulation 8(1)), but not from the veg/non-veg declaration. When artwork is resized, re-check heights against the new PDP area.

7. The old file goes to print

This one isn't in any regulation, yet it sits behind many of the others. In one reported case, a growing consumer brand changed its registered company name while packaging and licences kept the old one. Authorities in some states then reportedly treated the new name as a different entity and asked for fresh label approvals before sales could continue.

It happens in smaller ways all the time: a changed address, a new licence number, a new plant, a revised nutrition value. If one file isn't updated, the printed pack is wrong. The fix is a process: one approved version, a record of who approved it, and a check against the rules before every print run.

Misbranded food can be penalised under Section 52 of the Food Safety and Standards Act, 2006, which provides for a penalty of up to ₹3 lakh.

Before-print checklist

• Claims checked against the regulation, not only against marketing intent
• Licence number and FSSAI logo correct, visible and in a contrasting colour
• Veg/non-veg logo present on the front of pack and at least the minimum size
• Nutrition table matches the latest lab report and says % RDA
• Allergens declared as required
• Date format and minimum character heights checked for the pack's panel area
• Company name, address and licence details match your current licences
• The approved file is the file that goes to the printer

Run your artwork through the packaging compliance checker to flag potential issues before it goes to print. If you manage many packs and versions, see how Seventeen29 handles artwork approvals.

Related guide

Why designers dread the back of a food pack: how these rules look from the designer's side of the file.

Frequently asked questions