Nutrition and Allergen Labelling for D2C Food

Packaged food sold online in India is governed by the same label rules as food sold in a shop, plus an extra obligation: what you type on the product page has to match what is printed on the pack. That second requirement is where most D2C food brands slip.

This is a practical summary and not legal advice. FSSAI labelling requirements have been amended repeatedly since 2020 and further changes are pending. Confirm every point below against the current gazette notification on the FSSAI website before you print artwork.

What the Nutrition Panel Has to Carry

The Food Safety and Standards (Labelling and Display) Regulations, 2020 set the nutrition declaration. In broad terms the panel covers energy in kilocalories, protein, carbohydrate with total sugars and added sugars shown separately, total fat with saturated fat and trans fat, cholesterol, and sodium. Any nutrient you make a claim about has to be declared too.

The panel is declared per 100 g or per 100 ml and per serving, with the serving size and the number of servings per pack stated. There is also a per-serve percentage contribution to recommended dietary allowances. Separate rules apply to specific product classes such as infant nutrition, health supplements and nutraceuticals, so check your category rather than copying a competitor’s panel.

Other mandatory elements sit around the panel: the ingredient list in descending order of weight, the FSSAI logo and licence number, batch or lot identification, date of manufacture and best before or use by date, net quantity, and the vegetarian or non-vegetarian symbol, green for vegetarian and brown for non-vegetarian under the 2020 regulations. Net quantity, MRP and consumer care details also fall under the Legal Metrology packaged commodities rules, a separate regime.

Per Serve Versus Per 100 g

Both columns are required, and they do different jobs. Per 100 g is the comparison column. It is what a shopper uses to compare your granola against another granola and what nutrition apps and journalists scrape. Per serve is the consumption column, and it is only useful if the serving is honest.

The temptation is obvious. Shrink the serving and the sugar number shrinks with it. It does not work for long, because the per 100 g figure sitting next to it makes the manipulation visible. Set the serving to a portion people genuinely eat, and if the per 100 g numbers are uncomfortable, fix the formulation rather than the denominator.

FSSAI approved a proposal in July 2024 to require the per-serve percentage contribution to recommended dietary allowances for total sugar, total saturated fat and sodium to be shown in bold and at increased font size. The notification process has been running since. Check current status before finalising artwork, because this changes the visual hierarchy of your panel.

Allergens and the Contains Statement

Eight allergen categories are specified for declaration: cereals containing gluten, crustaceans, milk and milk products, eggs and egg products, fish and fish products, peanuts and tree nuts, soybeans, and added sulphites at concentrations of 10 mg per kg or more in the finished product.

Two things are expected. Allergens present as ingredients must be identifiable within the ingredient list itself, typically emphasised in bold, italics or a different colour rather than buried among the other ingredients. In addition, a separate contains statement is placed near the ingredient list naming the allergens present.

Cross-contact is different. A may contain advisory belongs on the pack only where a genuine assessed risk exists from a shared line. It supplements allergen controls at the plant, never replaces them. Ask your co-packer for their allergen management plan, changeover cleaning validation and the list of allergens handled elsewhere in the facility before you decide what your pack says.

Front of Pack and Where the Rules Are Heading

India still has no notified front-of-pack nutrition labelling rule. FSSAI released draft regulations on 13 September 2022 proposing an Indian Nutrition Rating using a half star to five star scale, and received more than fourteen thousand comments. As of 2026 the framework has not been finalised.

Pressure has increased. In February 2026 the Supreme Court urged FSSAI to consider mandating front-of-pack labels, indicating that warning labels for high sugar, sodium or saturated fat could form part of the design alongside a positive logo for healthier products. A Parliamentary Standing Committee has separately asked FSSAI to notify the regulations within a defined timeline.

The practical instruction for a brand is simple. Assume some front-of-pack indicator arrives, and design artwork that can absorb it without a full redesign. Leave clear space near the brand block on the principal display panel. If your product would score badly on a star rating or trigger a high-in warning, that is worth knowing now, while reformulation is still cheap.

Claims You Cannot Make

The Food Safety and Standards (Advertising and Claims) Regulations, 2018 govern what you may say. Descriptors such as natural, fresh, pure, original, traditional, premium, authentic, genuine and real are permitted only under the specific conditions set out in the regulations. Sweeping formulations such as 100 percent natural or 100 percent pure need substantiation that most products cannot provide. Home-made and home-cooked are not available to a manufactured product. Claims implying endorsement by medical, nutrition or health professionals are not permitted, nor are claims that cast doubt on the safety of similar foods.

Nutrition claims such as low fat, high protein, source of fibre or no added sugar are conditional on meeting defined thresholds. No added sugar in particular requires that no sugars have been added and that no ingredient carrying added sugar is used, and where natural sugars remain, that has to be stated. Every claim must be supported by evidence you can produce on request.

The Listing Page Has to Match the Pack

FSSAI requires e-commerce food business operators to carry mandatory label information on the listing and to display the seller licence number, and it has issued notices to platforms over listing content. Beyond compliance, mismatch is a customer trust problem.

Keep one master artwork specification and treat it as the single source. Feed the nutrition table, ingredient list, allergen statement and net quantity on every channel from that file. Version the artwork and re-audit all listings whenever the version changes. Never let a marketing team write a claim on a listing that does not appear on the pack, because the listing is the claim as far as the regulator and the customer are concerned.