General Principles explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Regulations 3 and 4 of the Advertising and Claims Regulations, 2018 apply to every food business operator and marketer who advertises or publishes marketing communications for food, including labelling claims. They set fourteen general principles, from truthfulness and substantiation to a disclaimer for brand names that sound like claims.
The text is read as amended up to 13 December 2022 (FSSAI Compendium Version IV dated 14.12.2022). FSSAI compendia are reference consolidations and the Gazette text prevails. Later notifications should be checked on fssai.gov.in. Packs and campaigns can be checked against these principles through FSSAI label compliance.
Claims must be truthful, unambiguous, meaningful and not misleading, and substantiated by validated methods. Brand or fancy names containing words such as "natural" or "pure" that may mislead need a front-of-pack disclaimer in a prescribed minimum font size. The FSSAI logo and licence number may not be used to make a claim. Claims in an advertisement must be consistent with the label.
Regulation 3: who is bound
"Every food business operator and marketer while advertising and publishing or disseminating marketing communication meant for promotion or sale of any article of food including labelling claims shall comply with the following general principles." A proviso says advertisements and claims for food meant for infants shall be in accordance with the Infant Milk Substitutes, Feeding Bottles and Infant Foods (Regulation of Production, Supply and Distribution) Act, 1992. That Act is named here; this article says nothing about its content.
Regulation 4: the principles
| Sub-reg. | Principle |
|---|---|
| (1) | Claims must be truthful, unambiguous, meaningful, not misleading and help consumers comprehend the information |
| (2) | Claims shall not encourage or condone excess consumption of a particular food |
| (3) | Claims shall not state, suggest or imply that a balanced and varied diet cannot provide appropriate quantities of nutrients |
| (4) | Where the claim benefit depends on the method of preparation, that shall be provided on the label |
| (5) | Reduction of disease risk claims shall specify the number of servings of the food per day for the claimed benefit (inserted by amendment) |
| (6) | A claim of nutritional or health attributes shall be scientifically substantiated by validated methods of characterising or quantifying the ingredient or substance that is the basis for the claim |
| (7) | Brand name, trade mark or fancy name containing adjectives such as "natural", "fresh", "pure", "original", "traditional", "authentic", "genuine", "real" likely to mislead as to the nature of the food needs a disclaimer (inserted by amendment) |
| (8) | All disclaimers related to a claim shall be conspicuous and legible |
| (9) | No claim or promotion of sale, supply, use and consumption of food shall be made using the FSSAI logo and licence number |
| (10) | Advertisements shall not undermine the importance of healthy lifestyles |
| (11) | Food or beverages shall not be promoted or portrayed as a meal replacement unless permitted under another regulation |
| (12) | Claims in advertisements shall be consistent with information on the label |
| (13) | No advertisement shall be deceptive to consumers |
| (14) | Every declaration required in advertisements under these Regulations shall be conspicuous and legible |
The brand-name disclaimer in 4(7)
Where the meaning of a trade mark, brand name or fancy name with such adjectives, appearing in labelling, presentation or advertising, is likely to mislead the consumer as to the nature of the food, a disclaimer "shall be mentioned prominently on the front of pack of the label stating that": "*This is only a brand name or trademark, or fancy name and does not represent its true nature; (relevant one may be chosen as applicable)". The proviso sets the font size: not less than 1.5 mm for a principal display panel up to 100 cm2, not less than 2 mm for a panel between 100-200 cm2, and not less than 3 mm for a panel above 200 cm2. The conditions for using the adjectives themselves are in Schedule V; see our article on natural, fresh, pure and authentic.
The FSSAI logo in 4(9)
Regulation 4(9) starts "Notwithstanding the mandatory declaration of Food Safety and Standards Authority of India logo and license number as per Food Safety and Standards (Packaging and Labelling) Regulations, 2011". That 2011 instrument has been replaced; the logo and licence number are now dealt with under the Labelling and Display Regulations, 2020, covered in our article on regulations 5(6) to 5(9). The principle is that the logo and number must appear, but may not be used as a selling point; see also FSSAI logo usage.
Substantiation and consistency
Principle (6) requires a method that validates the claim, not merely an assertion. Principle (12) ties advertising to the label: a claim in a social media post that does not appear, or is contradicted, on the label breaches it. Principle (4) catches claims such as "low fat when baked", where the benefit depends on how the food is prepared; the preparation method has to be on the label.
An invented example: Natura Crunch sells a snack under the brand name "Naturally Fresh". The pack contains flavouring and is not a fresh food. The name is likely to mislead, so under 4(7) the front of pack carries "*This is only a brand name or trademark, or fancy name and does not represent its true nature", at a font size of not less than 2 mm because its principal display panel measures between 100 and 200 cm2. Natura also posts an advertisement that says "low in fat" while the pack does not; principle (12) is breached.
How the principles are used
These principles sit above the specific rules. A nutrition claim must satisfy regulation 5 and Schedule I and also be truthful and substantiated; a health claim must satisfy regulation 7 and also be consistent with the label. See our articles on definitions and nutrition claims. Where a claim breaches the Regulations, regulation 13 points to the Act's penalty for misleading advertisement and misleading claims; see section 53 of the FSS Act and the Act's section 24.
Need help with claim wording?
General principles are easy to state and hard to apply to a real slogan. Our FSSAI label compliance team can test your slogans, brand names and disclaimers against regulations 3 and 4 before launch.
Key takeaways
- Every food business operator and marketer is bound, including for labelling claims.
- Claims must be truthful, unambiguous, meaningful, not misleading and scientifically substantiated.
- A brand or fancy name with a word such as "natural" or "pure" that may mislead needs a front-of-pack disclaimer: not less than 1.5 mm, 2 mm or 3 mm depending on panel size.
- The FSSAI logo and licence number cannot be used to promote.
- Advertisement claims must match the label.
Read next
- Regulations 1 and 2: definitions
- Regulation 5 and Schedule I: nutrition claims
- Schedule V: natural, fresh, pure, authentic
- Section 24, FSS Act: restrictions on food advertising
Disclaimer: Based on the FSSAI regulations named above as consolidated in FSSAI's compendium versions or as published in the Gazette, with the later notifications the article names (consulted on fssai.gov.in on 2-3 October 2026). Later notifications and the Food Safety and Standards Act, 2006 provisions referred to should be checked. This article is general information, not legal advice; check the official text before acting.