This submission requests two specific actions from the Commissioner, FDA Maharashtra — not immediate endorsement or mandating:
AaharAnk is being proposed as a public good. No commercial benefit is sought. The complete methodology is proposed to be released under Creative Commons Attribution 4.0 (CC BY 4.0), subject to legal review of the intellectual property model. The name and badge design will be protected by trademark solely to ensure accurate use — licensing is free for all compliant adopters.
The ICMR-INDIAB study1 estimated that in 2021, 101 million people in India had diabetes and 136 million had prediabetes. These are observation-period estimates, not current-year projections. The study also recorded hypertension prevalence at 35.5%, generalised obesity at 28.6%, and abdominal obesity at 39.5%.
Diet-related NCDs impose an escalating burden on Indian households and the public health system. Ultra-processed food consumption in India grew significantly between 2012 and 2019, though precise percentage figures vary by study and measurement method. WHO recognises FOPL as an important policy tool to support consumers in making informed food choices.3
NutriScore is a well-studied front-of-pack system, validated for its European application, currently adopted by France, Germany, Belgium, the Netherlands, Luxembourg, Spain, and Switzerland. Its algorithm derives from the UK FSA Nutrient Profiling Model 2004/05.8 However, it is unsuitable for direct adoption by India for the following reasons:
Fair representation: NutriScore's limitations in an Indian context do not diminish its scientific validity for its original purpose. The case for AaharAnk does not require caricaturing competing systems.
Nutrient-specific warning labels (high sugar, high sodium, high saturated fat) have been associated with reductions in purchase of flagged beverages in Chile following their 2016 implementation.10 Note: reported effect sizes vary by study and measurement method; purchase changes should not be equated with consumption changes without further evidence. However, warning labels only signal negative nutrients and do not communicate positive nutritional attributes. AaharAnk is proposed as a complement to, not a replacement for, warning labels. A hybrid system — five-level summary grade plus nutrient-specific warnings — is an option the validation programme will evaluate.
FSSAI's own expert committee found the proposed 0.5–5 star INR "unfit for finalization." No independent published assessment of the INR's scientific basis is available to this submission. Reports of withdrawal following 14,000+ representations (figure from secondary sources — primary FSSAI record outstanding) indicate significant stakeholder and technical concerns that any successor system must address.
आहारांक (AaharAnk) is a coined Hindi/Sanskrit compound: आहार (aahar = food, nourishment) + अंक (ank = score, grade, number). The compound does not appear in any Hindi dictionary as a single term — it is an original creation. It means "Food Score."
| Grade | Hindi Name | English Label | Meaning (Provisional) |
|---|---|---|---|
| अ | उत्तम (Uttam) | Higher Nutritional Quality | Favourable overall nutritional composition under this methodology |
| आ | अच्छा (Achha) | Good Nutritional Quality | Good overall nutritional composition under this methodology |
| इ | ठीक (Theek) | Moderate Nutritional Quality | Moderate nutritional composition — consume in balance |
| ई | सोच-समझकर | Lower Nutritional Quality — Consume Mindfully | Below moderate composition — mindful consumption advised |
| उ | कम खाएं | Lowest Nutritional Quality — Limit Frequency | Lowest composition profile under this methodology — limit frequency of consumption |
The badge displays all five grades simultaneously. The product's assigned grade appears at full opacity and slightly enlarged. Inactive grades appear at approximately 20% opacity. Minimum print width: 20mm. Minimum digital height: 14px.
The complete algorithm, pseudocode, worked examples, and full point-allocation tables are in the accompanying AaharAnk v2.1 Technical Specification. This section provides a summary for senior review.
AaharAnk is derived from the UK Food Standards Agency Nutrient Profiling Model 2004/05 (Rayner M, Scarborough P, Stockley L. London: Food Standards Agency, 2004).8 This model was originally developed to regulate food marketing to children in the UK and has been in use since 2007. It is the same baseline used by NutriScore. The FSA-NPS algorithm is published academic work in the public domain — not patented or proprietary.
All departures from the FSA NPM 2004/05 are declared in the Model Change Register in the Technical Specification.
Corrected score range: Theoretical minimum −18 (maximum P=18 for eligible millet product, zero N) to theoretical maximum +40 (maximum N, zero P). No operational range stated — requires Indian product dataset analysis.
| Indicator | Trigger | Display | Rationale |
|---|---|---|---|
| Contains Non-Sugar Sweetener | Any NSS present in ingredients (acesulfame K, aspartame, sucralose, stevia, saccharin, etc.) | Separate text disclosure alongside badge | WHO's 2023 conditional recommendation advises against using NSS as a means of achieving weight control or reducing NCD risk.11 The disclosure format is preferred over a grade penalty — penalising NSS in the primary score could perversely discourage manufacturers from reformulating away from added sugar. |
| High Processing | Product qualifies as NOVA Group 4 | Separate "High Processing" flag below badge | NOVA inter-rater reliability issues make it unsuitable as a primary grade modifier without a validated Indian decision tree. Displayed separately for transparency. |
| अ (Higher Quality) | आ (Good Quality) | इ (Moderate) | ई (Lower) | उ (Limit) |
|---|---|---|---|---|
| ≤ 0 | 1 to 3 | 4 to 11 | 12 to 20 | ≥ 21 |
This proposal explicitly does not seek immediate mandate authority or pack-printing permission. A staged approach is proposed to build the evidence base needed for any policy recommendation.
| Stage | Timeline | Activities | Success Criteria |
|---|---|---|---|
| Stage 1 Digital Pilot |
Month 1–3 | AaharAnk calculator deployed in a consumer app or retailer platform. Users can see grades for participating products. No physical badge yet. | ≥1,000 product look-ups/week. No significant consumer complaints about grade accuracy. |
| Stage 2 Shelf Label Pilot |
Month 4–6 | Shelf edge labels in 3–5 consenting retail stores showing AaharAnk grades for stocked products. Labels clearly marked "proposed system — under evaluation." | Retailer participation. Label visibility confirmed by store audit. |
| Stage 3 Comprehension Study |
Month 4–6 | Independent consumer research agency conducts comprehension study. Compare AaharAnk vowels against: Roman letters, star ratings, traffic lights, warning labels. Minimum 400 respondents across literacy/language groups. | Published study report. ≥70% of respondents correctly identify अ as the most favourable grade and उ as least favourable. |
| Stage 4 Regulator Review |
Month 7–9 | FDA Maharashtra reviews pilot data. Independent scientific panel reviews algorithm. Anomaly products identified and grade disputes resolved. | Written scientific review report. Anomaly list resolved. |
| Stage 5 Decision Point |
Month 10+ | Based on pilot evidence, FDA Maharashtra decides whether to recommend AaharAnk to FSSAI as a candidate FOPL framework for national consideration. | Formal written recommendation to FSSAI (positive or negative). Either outcome is valid — the goal is evidence-based decision-making. |
AaharAnk's governance is designed to maintain scientific independence, public accountability, and freedom from commercial capture.
| Body | Role | Composition |
|---|---|---|
| Scientific Advisory Council | Algorithm oversight, threshold calibration, annual review | 1 food scientist (nutrient profiling), 1 ICMR-affiliated nutritionist, 1 public health researcher, 1 consumer representative. Government observer invited — not assumed. |
| Nutrient Profiling Working Group | Technical algorithm decisions and edge cases | Food science specialists. No food industry membership in voting roles. |
| Consumer Testing Working Group | Comprehension studies and feedback integration | Research agency, consumer representative, regional language expert. |
| Methodology Secretariat | Version control, public repository, audit trail | Technical team. Minutes published within 30 days of every meeting. |
| Conflict of Interest Committee | Disclosure review and appeals | Independent members. Industry funding must be declared and may trigger recusal. |
We respectfully request the Commissioner, Food and Drug Administration, Maharashtra to:
The system is proposed. The science is open. The evidence must be built together.
Contact:
Siddhesh Ghuge — Initiator, AaharAnk Framework
siddhesh@rapsap.com | +91-9867870802 | Mumbai, Maharashtra
Conflict of Interest Disclosure: The initiator is also Founder and CEO of Rapsap Essential Retail Private Limited, which operates 13 supermarkets in the Mumbai Metropolitan Region. Rapsap may be among the first retailers to pilot AaharAnk on its shelves if the pilot is approved. This interest is disclosed in the interest of transparency. AaharAnk is proposed as a brand-agnostic open standard — no commercial exclusivity is sought or will be accepted.
Enclosures:
1. AaharAnk v2.1 — Technical Specification and Validation Protocol
2. AaharAnk v2.1 — Visual Identity System (pitch deck)
1 Anjana RM, Unnikrishnan R, Deepa M, et al. Metabolic non-communicable disease health report of India: the ICMR-INDIAB national cross-sectional study (ICMR-INDIAB-17). Lancet Diabetes Endocrinol. 2023;11:474–489. DOI: 10.1016/S2213-8587(23)00119-5
2 World Health Organization. Noncommunicable diseases: India country profile. WHO, 2023. https://www.who.int/india/health-topics/noncommunicable-diseases
3 World Health Organization. Guiding principles and framework manual for front-of-pack labelling for promoting healthy diets. WHO, 2019. https://www.who.int/publications/i/item/9789241513999
4 FSSAI/Ministry of Health. Draft notification on front-of-pack nutritional labelling. WTO notification G/SPS/N/IND/288. September 2022. https://fas.usda.gov/data/india-indias-fssai-publishes-draft-notification-front-pack-labeling-packaged-food-products
5 Supreme Court of India. Order in PIL by 3S and Our Health Society. Bench: Justice JB Pardiwala, Justice KV Viswanathan. 10 February 2026. Case: 3S and Our Health Society v. Union of India & Ors. (Writ Petition Civil). February 10, 2026 order. Supreme Court of India. [Official order text from Supreme Court website to be inserted — case number to be confirmed from official records.]
6 LawBeat. "Supreme Court gives FSSAI 'last chance' on front-of-pack warning labels." Published circa July–August 2026. https://lawbeat.in/top-stories/supreme-court-gives-fssai-last-chance-on-front-of-pack-warning-labels-for-high-sugar-salt-fat-foods-1621897 [Accessed August 2026] Note: This is secondary reporting. The primary source is the official Supreme Court order, which should be obtained and cited from sc.gov.in.
7 Deora M. Post on X (formerly Twitter). @milinddeora. July 15, 2026. [Characterises SC direction — not an official court order text.]
8 Rayner M, Scarborough P, Stockley L. Nutrient Profiles: Options for definitions for use in relation to food promotion and children's diets. London: Food Standards Agency, 2004. https://www.ndph.ox.ac.uk/food-ncd/files/about/uk-ofcom-nutrient-profile-model.pdf
9 Santé Publique France. Nutri-Score: conditions for use of the trademark. 2022. [Official NutriScore governance document. Operators prohibited from registering similar marks.] https://www.santepubliquefrance.fr/determinants-de-sante/nutrition-et-activite-physique/nutri-score
10 Taillie LS, Busey E, Mediano Stoltze F, Dillman Carpentier FR. Governmental policies to reduce unhealthy food marketing to children. Nutr Rev. 2019;77:787–816. [Chile warning label evidence. Note: reported percentage figures vary by study; citing publication rather than specific percentage.]
11 World Health Organization. Use of non-sugar sweeteners: WHO guideline. Geneva: WHO; 2023. https://www.who.int/news/item/15-05-2023-who-advises-not-to-use-non-sugar-sweeteners-for-weight-control