Processed Foods: ICMR-NIN Proposes a Two-Axis Test

Why in News?

Scientists at the ICMR-National Institute of Nutrition have proposed a dual-axis framework for food policy: one axis assesses the degree of processing, while the other assesses nutrients of concern such as fat, sugar and sodium.

The proposal builds on the Dietary Guidelines for Indians 2024 and could inform future front-of-pack labels, health-claim controls, marketing restrictions and school-food policy. It is a research-based regulatory recommendation, not a new rule, statutory definition or immediate ban.

• The Hindu reported that researchers see a gap because India lacks a formal regulatory definition that comprehensively captures ultra-processed foods.
• A food may be heavily industrially processed without crossing every nutrient threshold, while a freshly prepared food may be high in fat, sugar or salt without being ultra-processed.
• The proposed framework tries to prevent either axis from hiding the other and to reflect Indian foods and culinary practices.
• ICMR-NIN Director Dr. Bharati Kulkarni linked evidence-based food policy to India’s simultaneous burdens of undernutrition, obesity and diet-related non-communicable diseases.
• Lead scientist SubbaRao M. Gavaravarapu presented the approach as a basis for future labelling, consumer awareness and policy decisions, not as an already-notified FSSAI regulation.

The development matters in the context of:

• The issue matters because food regulation must distinguish necessary processing, which can improve safety and shelf life, from formulations designed around additives, refined ingredients and high palatability.
• It also matters for the design of front-of-pack nutrition labelling: a simple score can conceal a serious nutrient excess or create a health halo after limited reformulation.
• For UPSC answers, separate scientific classification, dietary guidance and enforceable food law. They influence one another but have different legal effects.

UPSC Relevance

Prelims Relevance

• ICMR-NIN is a nutrition research institute under the Indian Council of Medical Research, Department of Health Research, Ministry of Health and Family Welfare.
• FSSAI is the statutory food regulator established under the Food Safety and Standards Act, 2006.
• Ultra-processed food focuses on extensive industrial alteration, refined ingredients and additives not commonly used in domestic cooking; it is not simply another name for high-calorie food.
• HFSS refers to foods high in fat, sugar or salt; a product can be HFSS without being ultra-processed.
• The ICMR-NIN guidance uses processing groups A, B and C for minimal, moderate and extensive processing, then overlays nutrient-risk categories.
• The guidance threshold for 100 g of solid food is 250 kcal, 4.2 g added fat, 3 g added sugar and 625 mg salt; these are reference criteria, not current statutory limits for every food.
• For 100 ml of a liquid, the corresponding guidance values are 70 kcal, 1.5 g added fat, 2 g added sugar and 175 mg salt.
• WHO’s adult recommendation is less than 2,000 mg sodium per day, equivalent to less than 5 g salt; a daily dietary goal is not the same as a per-product threshold.
• The Food Safety and Standards (Safe Food and Balanced Diets for Children in School) Regulations, 2020 restrict specified HFSS foods in school premises and within 50 metres of school gates.
• The wider regulator-and-enforcement context is explained in the Anantam IAS State Food Safety Index note.

Mains Relevance

GS Paper 2

• Examine food labelling and marketing controls as instruments of the right to health, consumer information and preventive public health.
• Analyse why protecting children requires coordinated action across health, education, food regulation, schools and local enforcement.
• Assess the challenge of regulating commercial food environments while India still faces a double burden of malnutrition.

GS Paper 3

• Connect food reformulation and processing standards with food-industry innovation, testing capacity, compliance costs and responsible consumption.
• Discuss how clear classification can reduce information asymmetry without treating every form of preservation, fortification or food processing as harmful.

Essay

• A label informs only when it reveals the risk that marketing tries to hide.
• Public health must address both scarcity and excess because malnutrition can take opposite forms in the same household.
• Good regulation turns complex science into simple choices without turning simplicity into distortion.

Background and Context

What the Proposed Two-Axis Framework Measures

The proposal treats processing and nutrient composition as related but independent dimensions of food quality.

• The processing axis asks how far the edible portion has been altered, whether native fibre and micronutrients are lost, and whether industrial additives or techniques substantially reshape the product.
• ICMR-NIN’s Group A broadly covers unaltered or minimally altered foods prepared with familiar ingredients and without cosmetic or preservative additives.
• Group B covers moderate alteration or preservation, such as drying, freezing, fermenting, baking or canning, while retaining a recognisable food base and avoiding the additive profile associated with extensive processing.
• Group C covers extensively processed formulations whose original food structure is substantially altered, often with additives used for shelf life, texture, colour, flavour or high palatability.
• The nutrient axis asks whether energy, added fat, added sugar and salt remain within guidance thresholds. Foods above the reference levels can enter higher HFSS categories within any processing group.
• This creates a matrix rather than a single ladder. A food can be minimally processed but HFSS, extensively processed but below selected nutrient cut-offs, or high-risk on both axes.

Why UPF and HFSS Are Not Synonyms

The distinction prevents policy from equating the manufacturing process with the final nutrient profile.

• UPF classification focuses on industrial formulation, food-matrix alteration, refined fractions, additives and distance from ordinary culinary preparation.
• HFSS classification focuses on specified nutrients of concern. A home-made sweet or deep-fried snack may be HFSS even if it has no industrial additive.
• A pasteurised food, frozen vegetable or fermented food has undergone processing for safety, preservation or access; processing by itself does not establish poor nutritional quality.
• A product can be reformulated to reduce one nutrient and still remain extensively processed, fibre-depleted or dependent on cosmetic additives. The processing axis limits this reformulation health halo.
• The reverse warning also matters: calling a product minimally processed should not excuse excessive salt, sugar or fat. The nutrient axis keeps traditional and freshly prepared HFSS foods visible.
• A sound rule should classify risk without moralising food or blaming consumers. Price, availability, advertising, time poverty and school environments shape what people eat.

Verified ICMR-NIN Thresholds

The numerical values come from the 2024 dietary guidelines and must be presented as guidance criteria rather than notified legal limits.

• For solid food per 100 g, ICMR-NIN Table 15.1 lists 250 kcal, 4.2 g added fat, 3 g added sugar and 625 mg salt as the reference criteria.
• For liquids per 100 ml, it lists 70 kcal, 1.5 g added fat, 2 g added sugar and 175 mg salt.
• The guidelines explain that the solid-food sugar threshold approximates 5% of energy from added sugar, with total sugar not exceeding 10% of energy.
• The solid-food added-fat threshold approximates 15% of energy from added fat, with total fat not exceeding 30% of energy.
• For beverages, the guidance uses about 10% of energy from added sugar, with total sugar not exceeding 30% of energy, and about 15% of energy from added fat.
• These product-level reference values should not be confused with WHO population intake goals: free sugars below 10% of daily energy, saturated fat no more than 10%, trans fat no more than 1%, and sodium below 2,000 mg daily for adults.
• Differences in denominator matter. A per-100 g threshold helps compare products, while a daily-intake recommendation considers the whole diet and quantity consumed.

Public-Health Rationale and Burden

The proposal responds to a food environment in which nutrient excess and intensive processing can reinforce obesity and diet-related disease.

• WHO identifies unhealthy diet as a major risk factor for cardiovascular disease, diabetes, stroke and some cancers, while stressing adequacy, balance, moderation and diversity.
• WHO estimates that excess sodium was associated with 1.7 million deaths globally in 2023; it recommends product reformulation, front-of-pack labels, healthier public procurement and behaviour-change communication.
• The official ICMR-INDIAB estimate placed diabetes at about 101 million people and prediabetes at about 136 million in India. These figures show metabolic-disease scale, but they do not prove that any single processed food caused an individual’s disease.
• WHO’s country profile estimated age-standardised adult obesity in India at 7.3% in 2022 using the BMI threshold of at least 30 kg/m². Different studies may use different age groups and Asian-Indian cut-offs, so figures shouldn’t be mixed casually.
• India also retains undernutrition and micronutrient deficiencies. The dual burden is explained in Anantam IAS’s malnutrition guide.
• The two-axis model can support prevention, but it should be one part of a wider response that includes affordable healthy foods, physical activity, primary care, screening and action on commercial determinants.

What Current Indian Law Already Does

India already regulates food safety, nutrition declarations, school food and claims, but the proposed matrix has not automatically become part of those rules.

• The Food Safety and Standards Act, 2006 empowers FSSAI to set science-based standards and regulate manufacture, storage, distribution, sale and import.
• The Labelling and Display Regulations, 2020 require nutrition information on packaged foods, including relevant declarations for energy, sugars, fat and sodium.
• The Advertising and Claims Regulations, 2018 require claims to be truthful, meaningful and not misleading; adding a positive nutrient cannot justify an unsupported disease-prevention claim.
• The school-food regulations of 2020 restrict sale and marketing of specified HFSS products to children on school premises and within 50 metres of the school gate.
• FSSAI’s 2022 proposal for an Indian Nutrition Rating and a formal front-of-pack HFSS system is still identified as a draft on the regulator’s notification archive. A draft invites comments; it does not create the same duty as a final gazette notification.
• The new ICMR-NIN proposal may inform future amendments, definitions or guidance, but research recommendations do not amend regulations by themselves.
• For broader preventive-health framing, see this Anantam IAS current-affairs note.

Possible Regulatory Uses

If validated and adopted through due process, the matrix could give different policy tools a common food-classification base.

• A front-of-pack system could display a clear nutrient warning while separately signalling extensive processing, rather than compressing both into one favourable average score.
• Marketing rules could use the matrix to restrict promotion of products that are HFSS, extensively processed or both, especially when advertisements target children.
• School procurement standards could favour minimally processed, nutrient-appropriate foods and apply consistent exclusion criteria to canteens, vending and nearby sales.
• Health-claim review could prevent a manufacturer from adding fibre, protein or vitamins and presenting an otherwise high-risk product as fully healthy.
• Fiscal policy could distinguish product classes for taxes or incentives, but any levy needs evidence on substitution, affordability and distributional effects.
• Reformulation targets could be food-category specific. The technically feasible sodium reduction in bread may differ from that in pickles, sauces or regional preparations.
• Public procurement and nutrition education can translate the framework into food environments, while enforcement must remain led by government and protected from conflicts of interest.

Design and Implementation Challenges

A scientifically appealing matrix still needs clear definitions, validation and administratively workable rules.

• Regulators must define which additives or industrial processes move a product into the highest processing group and ensure that independent assessors reach consistent classifications.
• Manufacturers need rules for composite foods, restaurant meals, artisanal products, fortified staples and products sold after preparation from a commercial premix.
• The framework needs an accurate nutrient database, standard laboratory methods and a rule for whether values are measured as sold, as prepared or per serving.
• Per-100 g comparisons improve consistency but can mislead when normal portion sizes differ sharply. Per-serving information also risks manipulation through unrealistically small declared servings.
• A label must be readable across literacy levels and languages. Consumer testing should compare warnings, traffic lights and summary ratings before choosing a national design.
• Small businesses may need phased compliance and technical support, but high-risk products should not gain open-ended exemptions that weaken public-health protection.
• Government should publish the evidence, conflict-of-interest safeguards, consultation record and final rationale before notifying any binding classification.
• Post-implementation evaluation should track product reformulation, purchases, dietary intake and equity, not merely the number of labels printed.

Way Forward

Validate the Matrix

• Test inter-rater reliability, nutrient thresholds and classification outcomes across Indian packaged, restaurant and traditional foods.
• Publish a searchable examples database and a transparent method for resolving borderline products.

Use Formal Rulemaking

• FSSAI should move from evidence to a draft, public consultation, scientific review and final gazette notification before imposing duties.
• The final instrument should specify coverage, exemptions, transition periods, testing and penalties.

Protect Children First

• Align school-food enforcement, digital marketing rules and procurement standards around a consistent, evidence-based definition.
• Strengthen monitoring within the existing 50-metre school zone and across online advertising.

Pair Labels with Food-System Action

• Combine simple labels with reformulation, healthy public procurement, nutrition literacy and affordable access to minimally processed foods.
• Measure whether the policy changes diets and disease risks across income groups, not only whether consumers recall the logo.

Conclusion

ICMR-NIN’s proposed dual-axis framework improves the policy question. It asks not only what nutrients a food contains, but also what industrial processing has done to its structure, ingredients and role in the diet.

Its strongest contribution is preventing false equivalence: UPF and HFSS overlap but aren’t identical. That distinction can sharpen labels, claims, school rules and marketing controls.

The next step is lawful, transparent conversion from evidence to regulation. India needs validated definitions, tested labels, public consultation and enforceable standards, while retaining healthy forms of preservation and processing.

UPSC Practice Questions

Prelims MCQ 1

With reference to the proposed ICMR-NIN dual-axis framework, consider the following statements:

1. It assesses the degree of food processing separately from nutrients such as fat, sugar and sodium.
2. Every food that is high in fat, sugar or salt must also be ultra-processed.
3. The proposal itself has the force of a final FSSAI regulation.

How many of the above statements are correct?

(a) Only one (b) Only two (c) All three (d) None

Answer: (a) Only one

Explanation:

Only Statement 1 is correct. HFSS and UPF are distinct axes, so either can occur without the other. The ICMR-NIN framework is a policy proposal based on dietary guidance; it does not acquire legal force without adoption through the applicable FSSAI rulemaking process.

Prelims MCQ 2

Which one of the following correctly distinguishes a WHO intake recommendation from an ICMR-NIN product threshold?

(a) Both always use the same denominator and legal status (b) WHO’s adult sodium goal concerns total daily intake, while ICMR-NIN reference values can compare a fixed quantity of food (c) WHO recommendations apply only to packaged food manufacturers (d) ICMR-NIN thresholds are criminal prohibitions under the Food Safety and Standards Act

Answer: (b) WHO's adult sodium goal concerns total daily intake, while ICMR-NIN reference values can compare a fixed quantity of food

Explanation:

WHO’s sodium recommendation is a population dietary goal of less than 2,000 mg per adult per day. ICMR-NIN’s table supplies per-100 g or per-100 ml reference criteria. Their denominators and present legal roles differ.

UPSC Mains Questions

1. India’s processed-food debate cannot be resolved by nutrient profiling or processing classification alone. Explain the logic of ICMR-NIN’s proposed dual-axis framework and assess how it could improve front-of-pack labels, school-food policy and health claims without treating all food processing as harmful. (250 words)
2. Scientific recommendations become legitimate public-health regulation only through clear definitions, validation, consultation and enforceable standards. Discuss this proposition with reference to FSSAI’s existing labelling, advertising and school-food architecture and the proposed classification of ultra-processed and HFSS foods. (250 words)

Sources: ICMR-NIN Dietary Guidelines for Indians 2024 and The Hindu.

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