On 12 October 2023, FSSAI (Food Safety and Standards Authority of India) recommended that food sector operators include a QR code on the label, to allow blind and visually impaired people to be able to listen to product information. (1)
1) India, food labeling requirements
The ‘Food Safety and Standards (Labeling and Display) Regulations’, adopted by FSSAI in 2020, offer an exhaustive list of mandatory information to be included on the label of pre-packaged food products, which includes:
– product name,
– nutritional declaration,
– list of ingredients, in descending order of weight,
– vegetarian/non-vegetarian logo,
– declaration on food additives,
– name, address and FSSAI license number of the ‘brand owner’ or importer in India, preceded by his role (i.e. ‘manufactured by’, ‘marketed by’),
– net quantity, consumer price, ‘customer care’ references,
– ‘date marking’, which includes ‘date of manufacture or packaging’ and ‘expiry/use by’, i.e. ‘best before’,
– special storage conditions, where required,
– Country of production, if different from India,
– instructions for use, if necessary,
– warnings about allergens (ie ‘Contains…’),
– specific requirements for product categories. (2)
2) India – European Union, comparison of labels
Labeling requirements in force in India – in line with the ‘Codex Alimentarius Standard for Food Labelling’, like the relevant regulations in force in the FAO, WHO member states – are in hindsight more stringent than those established in the European Union, with regards to:
– mandatory information on the label not provided for by the Food Information Regulation (EU) No 1169/11, eg ‘veg/not veg’ logo, license number and role of the operator, ‘customer care’ references, production date, country of manufacturing,
– accessibility to mandatory information thanks to their collection in a ‘main display panel’ with a size of no less than 40% of the largest surface, on cylindrical or parallelepiped-shaped packages (25% in other cases, i.e. envelopes),
– visibility guaranteed by a minimum character height proportional to the capacity of the ‘packaging’, from 1 to 6 mm.
3) India, FSSAI recommends including the QR-code on the label
FSSAI takes an important step forward on both fronts of food information and the inclusion of people with visual disabilities, thanks to the recommendation addressed to all ‘food business operators’ on 12 October 2023:
– whereas the Indian Rights of Persons with Disabilities Act (2016) highlights the need to ensure accessibility and health promotion for all, including those with visual impairments,
– ‘ensuring inclusive access to information is a fundamental right of citizens and it is imperative that food products are labeled in a way that ensures accessibility to all consumers, including those with visual impairments‘,
– food business operators (FBOs) are encouraged to insert QR codes on labels that allow accessibility (through automatic reading) of all the information required as mandatory on the label.
‘Inclusion of a QR code for the accessibility of information’ in any case ‘does not replace or cancel the obligation to provide the mandatory information on the product label, as required by current regulations‘. (1)
4) The first comments
‘Embed QR codes on food products, as recommended by FSSAI to make food accessible to visually impaired people, is a significant step to promote food safety and inclusiveness.
The labels they play a vital role in providing valuable information, helping consumers, including those with visual impairments, to make safe and informed choices about the foods they consume. For visually impaired people, these QR codes represent a gateway to essential details such as ingredients, allergens and nutritional contents, allowing them to confidently manage their dietary needs (…).
These measures they not only ensure that safe foods are accessible to all, but also foster a healthier, more informed and inclusive society‘ (Roshan Kore, consultant dietician at the NHSRCC hospital in Mumbai). (3)
Dario Dongo
Footnotes
(1) Dr. Amit Sharma, Science and Standards Division Director. Inclusion of QR Codes on Food Products for Accessibility by Visually Impaired Individuals. FSSAI (Food Safety and Standards Authority of India). 12.10.23 https://tinyurl.com/3hs3wsnp
(2) Food Safety and Standards (Labeling and Display) Regulations (2020). FSSAI, India. See ‘Chapter 2 – Labeling of Prepackaged Foods’. Article 5, labeling requirements https://tinyurl.com/3xn9w3fm
(3) Sneha Kumari. FSSAI recommends inclusion of QR code on food products for visually impaired; expert encourages move. News9. 30.10.23 https://tinyurl.com/3t5b9thb
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
