Nutrition Claims 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.
Regulation 5 of the Advertising and Claims Regulations, 2018 says what a nutrition claim is, what is not a nutrition claim, and when a nutrient content or comparative claim may be made. Schedule I then sets, nutrient by nutrient, the conditions that a food must meet before a claim word such as "low", "source" or "high" can be used.
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. A pack that carries nutrition claims can be checked through nutritional labelling analysis support.
Nutrition claims are nutrient content claims and nutrient comparative claims. A content claim for a nutrient in Schedule I must meet the conditions in Schedule I; Schedule II lists synonyms that may be used. A comparative claim needs foods that are versions of the same food or similar foods, and a minimum relative difference, for example at least thirty per cent in energy value or macronutrients.
Regulation 5: the rules
5(1) Nutrition claims may be (a) a nutrient content claim or (b) a nutrient comparative claim.
5(2) The following are not nutrition claims: (a) mention of substances in the list of ingredients; (b) mention of nutrients as a mandatory part of nutrition labelling; (c) a quantitative or qualitative declaration of certain nutrients or ingredients on the label if required by the Act, rules and regulations. This keeps the mandatory nutrition panel (see our article on regulation 5(3) of the Labelling and Display Regulations) separate from voluntary claims.
5(3) (substituted by amendment) When a nutrient content or any synonymous claim is made for the nutrients in Schedule I, it shall be made in accordance with the conditions in that Schedule, provided flexibility in the wording of a nutrition claim is as per Schedule II, or the use of any other word, if they accord with Schedule I and the meaning of the claim is not altered.
5(4) Where a nutrient comparative claim is made, the foods shall be different versions of the same food or similar foods being compared, easily identifiable, and the relative difference of the claimed parameter must be:
| Clause | Parameter | Relative difference, as printed |
|---|---|---|
| (a) | energy value or macronutrients content | at least thirty per cent. |
| (b) | micronutrients other than sodium | at least ten per cent. of the recommended dietary allowances per 100 g or 100 ml |
| (c) | sodium, or the equivalent value for salt | at least twenty-five per cent. |
A proviso says that for salt when sold as such, a ten per cent. difference is acceptable.
5(5) In addition, where a comparative claim is made, the identity of the foods being compared and the amount of difference, as a percentage, fraction or absolute amount, shall be given in close proximity to the claim.
5(6) (inserted) Equivalence claims such as "contains the same amount of as a " or "as much as a " may be used provided the amount of the nutrient in the reference food is enough to qualify that food as a "source" of that nutrient, and the labelled food, on per 100 g or 100 ml, is an equivalent source, or the nutrient is at the same level as the naturally occurring reference food nutrient and that is indicated on the label and in the nutritional information. The printed examples are "as much fibre as an apple" and a vitamin C comparison with a glass of orange juice.
Schedule I: how it is organised
Schedule I is headed "Nutrient Content Claim" and refers to regulations 5(3) and 7(1)(b). It is a table of four columns: serial number, nutrient or component, claim, and conditions. It has nineteen serial numbers. The claim words are of four kinds: "Low" (and "Very low" for sodium), "Source", "High" (also "Rich"), and a zero-level claim word printed in the Schedule for energy, fat, cholesterol, saturated fat, trans fat, sugars, sodium, lactose and gluten. Conditions are stated per 100 g for solids, per 100 ml for liquids, per 100 kcal or per serving, and some are percentages of the Recommended Dietary Allowance.
Rows quoted as printed:
| Sl. | Nutrient | Claim | Condition |
|---|---|---|---|
| 1 | Energy or Calorie | Low | Not more than 40 kcal per 100 g for solids, or 20 kcal per 100 ml for liquids |
| 2 | Fat | Low | Not more than 3 g of fat per 100 g for solids, or 1.5 g of fat per 100 ml for liquids |
| 10 | Sugars | Low | Not more than 5 g of sugars per 100 g for solids, or 2.5 g of sugars per 100 ml for liquids |
| 11 | Protein | Source | 10 per cent. of Recommended Dietary Allowance per 100 g for solids; 5 per cent. per 100 ml for liquids, or 5 per cent. per 100 kcal, or 10 per cent. per serving |
| 13 | Sodium | Low | Not more than 0.12 g of sodium per 100 g for solids or 100 ml for liquids |
| 13 | Sodium | Very low | Not more than 0.04 g of sodium per 100 g for solids or 100 ml for liquids |
| 14 | Dietary fibre | Source | At least 3 g of fibre per 100 g for solids; or 1.5 g per 100 ml for liquids; or 1.5 g per 100 kcal |
| 16 | Glycemic index (GI) | Low GI | GI value below 55 |
Other serials cover cholesterol, saturated fat, unsaturated fat, trans fat, monounsaturated and polyunsaturated fatty acids, omega 3 fatty acids, vitamins and minerals, probiotics, DHA, lactose and gluten. For example, serial 12 (vitamin or mineral) "Source" requires at least 15 per cent. of the Recommended Dietary Allowance per 100 g for solids, and "High" at least 30 per cent. per 100 g for solids, among other bases. The zero-level conditions are also printed: for sugars, "not more than 0.5 g of sugars per 100 g for solids or 100 ml for liquids"; for fat, "not more than 0.5 g of fat per 100 g for solids or 100 ml for liquids". The claim word for those rows is the word printed in the Schedule against them; this article does not repeat it.
Footnotes to the Schedule explain Glycemic index (the relation of the incremental area under the blood-glucose response curve of a test meal with 50 g of digestible carbohydrates to that of a reference food, with four acceptable reference foods), say that 1 kcal = 4.2 kJ, and give the formula for the percentage of energy from a nutrient. Note 1 says nutrient content claims for products in the health supplement categories are governed by their own regulations.
Schedule II: synonyms
Schedule II lists synonyms for each claim family in six columns (the zero-level family, Low, Reduced, High, Increased, Source). Examples as printed: for Low, "Little, few (for calories), contains a small amount of, low source of, Lite, Light"; for Reduced, "Lower, Lesser, fewer (for calories)"; for High, "Rich"; for Increased, "More, Higher, Enhanced"; for Source, "Provides, Contains". The synonym must still meet the Schedule I condition for the family.
An invented example: Daily Grain Co. makes a muesli and wants to print "source of fibre". Schedule I serial 14 asks for at least 3 g of fibre per 100 g for solids, so its laboratory report must show that level before the words are used; "high in fibre" rests on a separate, higher printed condition in the same serial. If Daily Grain claims "30% less sugar than our earlier muesli", regulation 5(4)(a) and 5(5) require the foods to be identifiable and the difference stated near the claim.
How this fits with the rest
Regulations 3 and 4 set the general principles (principles). Non-addition claims are in regulation 6. The mandatory nutrition panel is covered in the nutrition information panel. See also health and nutritional claims on food labels.
Need help with nutrition claims?
Claims on a pack rest on analysis. Our nutritional labelling analysis service can help match your lab results to the Schedule I conditions and the wording you plan to use.
Key takeaways
- Two kinds of nutrition claim: nutrient content and nutrient comparative.
- Schedule I sets the conditions for each claim word, per 100 g, per 100 ml, per 100 kcal or per serving.
- Comparative claims need the same or similar foods and a stated difference: at least thirty per cent for energy and macronutrients, at least twenty-five per cent for sodium.
- Schedule II lists permitted synonyms; the Schedule I condition still applies.
Read next
- Regulations 3 and 4: general principles for claims
- Regulation 6: non-addition claims
- Nutritional information panel on food labels
- Health and nutritional claims on food labels
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.