Can your claims survive an audit?
What FSSAI actually allows
“High in protein.” “No added sugar.” “Boosts immunity.” Every claim used is a promise, and under the Food Safety and Standards (Advertising and Claims) Regulations, 2018, a promise you have to be able to prove.
A food label is the smallest, most heavily regulated piece of real estate a brand will ever own. For a growing food business operator (FBO) or a first-time founder, the temptation is to reach for words that sell: high in protein, no added sugar, made with real fruit, good for immunity. The regulator asks one question in return: can you prove it? Getting the mandatory label declarations right is only half the job; the other half is knowing what you are and are not allowed to claim beyond them.
The line between declaring and claiming
Every pack answers to two separate sets of rules at once. One tells you what has to appear on it, full stop, whether or not you make a single claim. The other tells you what you are permitted to say beyond that baseline, and that permission always comes with conditions attached. This piece is about the second set: the Food Safety and Standards (Advertising and Claims) Regulations, 2018, amended 2022 and effective March 2023, not the declarations regulation.
The governing standard
A claim must be truthful, unambiguous, meaningful, not misleading, and scientifically substantiated.
The claim types founders actually reach for
Nutrient content claims
“High in protein,” “low fat,” “sugar-free” describe the quantity of nutrient your product contains. Each is a defined value in Schedule I of Advertising and Claims Regulations, not a phrase you get to interpret. Like for example a “sugar-free” claim generally requires no more than 0.5 g of sugar per 100 g or 100 ml. “Source of” and “high in” carry minimum quantities tied to the Recommended Dietary Allowance. Before you print the word, you need the numbers, and those come from analysis.
Nutrient comparative claims
Claims such as “Reduced Fat,” “Lite,” or “25% Less Sodium” can only be made by comparing the product with a specific reference product. The label must clearly state which product is being compared and the exact difference, such as a percentage or amount. Similarly, equivalence claims like “Contains as much fibre as an apple” or “Contains the same amount of vitamin C as a glass of orange juice” must be based on valid comparisons. A claim like “Lite” on its own is not acceptable unless it clearly explains what the product is lighter than.
Non-addition claims
“No Added Sugar” and “No Added Salt” are claims that must be used carefully and are among the riskiest claims a brand can make. They mean that no sugar or salt has been added during manufacturing, no ingredient containing added sugar or salt has been used, and no substitute has been added to perform the same function. However, “No Added Sugar” does not mean the product is low in sugar, as it may still contain naturally occurring sugars. In such cases, the label must clearly state that the product contains naturally occurring sugars, so the claim is not misleading to consumers.
Non-addition of additives claims
A food product can claim as No Added Preservatives, No Added Colours, or No Added Flavours only if the additive has not been added during manufacturing, is not present through any ingredient (unless it occurs naturally), is an additive that is otherwise permitted for that type of food, and has not been replaced by another additive that performs the same function. In simple terms, the claim should be genuine and must not mislead consumers.
Health claims
The regulation separates function claims, such as “calcium supports bone health,” from disease risk reduction claims that imply a food reduces disease risk. Function claims still need evidence; disease risk reduction claims and any novel claim require prior FSSAI approval. Claims that a food can prevent, treat, cure, or diagnose diseases or replace medical treatment are not allowed. The moment a packaging says that, a food becomes an unlicensed drug. The phrase “boosts immunity” should always be presented as a health function claim, backed by scientific evidence, and never as a medical promise; the claim should indicate that it supports normal immune function.
The adjectives with strings attached
Natural, fresh, pure, original, traditional, authentic, real, premium every claim is conditional in the regulation. “Natural” cannot describe anything that has undergone more than minimal processing. “100% pure” and “100% natural” can only be used if the manufacturer can provide clear, unequivocal evidence that the claim is completely true for the product. Proving a product is “100% safe” is practically impossible.
Every claim category above turns on the same idea: a form of words only counts once it can be checked against a number. A stated percentage on a comparative claim, a ceiling on a sugar-free claim, a detection limit on a gluten-free claim — none of it can be estimated, assumed, or carried over from a comparable product. It has to come from your own formulation, tested.
Why free-from claims cut both ways
Declaring an allergen you have is a matter of reading your own recipe honestly. Claiming an allergen you don’t have is a different order of responsibility, and it has to be measured, not assumed. A free-from claim without a test report behind it is not a claim; it is a liability waiting to surface.
Founders tend to underestimate one thing: the burden of proof sits with the brand, not with FSSAI. A Licensing or Designated Officer can call for the evidence behind any claim at any time, and FSSAI’s Advertising Monitoring Committee actively tracks e-commerce listings and social media for exactly this kind of gap.
A practical sequence: formulation to claim
- Formulate, then characterise. Send the actual product for analysis before designing the pack, not after.
- Decide claims against your real numbers. Map tested values to FSSAI’s thresholds, and let the data decide what you are allowed to say.
- Check claims against each other. A non-addition or comparative claim must not contradict the nutrition panel it sits next to.
- Validate before you commit to print. Run a structured review of every claim against the 2018 regulation before the pack goes for final packaging.
- Re-test on schedule. Honour the six-monthly obligation, and treat any reformulation or new supplier as a trigger to re-check whether your claims still hold.
“Isn’t this overkill for a small brand?”
It is a fair question, and most founders ask it. Testing costs money, takes time, and a good lab does not always feel close by. Nutritional testing is an investment, not an expense: the cost per unit ends up negligible once it is spread across a full production run. The six-monthly testing requirement applies regardless of size; the penalty applies equally to businesses of all sizes.
The reframe that matters
Test what you claim, and test what the licence requires. That is not overkill; it is the cheapest insurance a food brand will ever buy.
How Envirocare Labs can help
Envirocare Labs works alongside food businesses and startups: testing your own formulation rather than assuming a comparable product’s numbers will hold, mapping the results to what FSSAI’s thresholds actually allow you to say, and reviewing a label or claim before it goes to print rather than after a notice arrives. Whether it is a nutrient content claim, a non-addition claim, or a free-from declaration that needs proof behind it, the aim is the same: a claim you can defend the day someone asks for the evidence.
Get your claims tested before you print
Send us your formulation and the claim you are considering. Our team can help you determine the tests it needs to stand behind.
FSSAI food claims compliance: FAQs
Every claim on a food label or advertisement has to be truthful, unambiguous, meaningful, not misleading, and scientifically substantiated, as set out in the Food Safety and Standards (Advertising and Claims) Regulations, 2018. In practice, that means the brand making the claim, not FSSAI, has to hold the evidence behind it.
Yes, but the label has to say so. “No added sugar” only means no sugar or sugar-equivalent ingredient was added during manufacturing; it does not mean the product is low in sugar. If naturally occurring sugars are present, the label must clearly declare that, so the claim does not mislead a consumer scanning the front of the pack.
A nutrient content claim, such as “high in protein” or “low fat,” describes the quantity of a nutrient against a defined threshold. A health claim goes further and links a nutrient or food to a health outcome, such as “calcium supports bone health.” Health claims need their own scientific backing and, for disease risk reduction or novel claims, prior FSSAI approval.
Yes. A claim is only as strong as the number behind it, and that number has to come from testing your own formulation rather than a comparable product’s data or an assumed value. This applies to nutrient content, comparative, non-addition, and free-from claims alike.
No. Claims that a food can prevent, treat, cure, or diagnose disease, or replace medical treatment, are not permitted under FSSAI’s claims regulation. A food making that claim is treated as an unlicensed drug, not a food product.
