India’s food-safety test is moving beyond labels to enforcement

By: Team India Tracker

The food regulator faces a dual challenge: making marketing claims verifiable while focusing enforcement on genuine safety and quality violations

The Delhi High Court’s decision to stay a food regulator’s order against consumer goods maker Dabur over “100% Purity”, “100% Natural” and “100% Purity Guaranteed” claims has put India’s increasingly contested food-labelling rules back in focus. 

But the more consequential story lies in the Food Safety and Standards Authority of India’s (FSSAI) enforcement data: substandard products, rather than labelling violations, continue to account for the bulk of food-safety non-compliance, even as the number of defective samples has fallen from its pandemic-era peak. 

The number of samples found defective rose from 29,192 in 2019-20 to 44,626 in 2022-23, the highest in the six-year period, before falling to 33,808 in 2023-24 and 34,388 in 2024-25, according to FSSAI annual reports. 

The data, covering the period since the pre-Covid financial year 2019-20, show that substandard samples accounted for 53.7% of non-compliance in 2019-20. Their share subsequently fluctuated but remained above half in most years, reaching 66.9% in 2023-24 before easing to 65.5% in 2024-25. 

That is the bigger regulatory challenge for India: ensuring that what is inside a packet meets prescribed standards, rather than focusing primarily on what is printed on it. 

The distinction matters as the packaged-food market expands and consumers increasingly pay a premium for products marketed as natural, pure, healthy or otherwise superior. 

The Dabur case highlights the difficult balance facing FSSAI. Regulators need to prevent labels from creating impressions that cannot be substantiated. But enforcement must also maintain a clear hierarchy of priorities: a product that fails prescribed standards presents a more direct consumer risk than a dispute over marketing terminology. 

There is some evidence that the nature of non-compliance is changing. The share of samples with labelling defects fell from 20.1% in 2019-20 to 14.7% in 2024-25, while the share classified as unsafe stood at 11.4% in 2024-25, down from 15.5% in 2019-20. 

The decline in defective samples therefore should not automatically be read as a sign that the regulatory problem has been solved. The number of samples analysed, inspection intensity and testing capacity can all affect the number of violations detected. 

More revealing is what has happened after cases were launched. 

FSSAI data show a sharp rise in the proportion of cases resulting in convictions since FY23. The conviction rate was 35.9% in 2022-23, before jumping to 76.8% in 2023-24 and then easing to 38.8% in 2024-25. The volatility suggests that enforcement outcomes can vary considerably from year to year, but the FY24 surge indicates that cases are increasingly translating into legal consequences. 

Penalties have also become a more important part of enforcement. The amount of penalties imposed rose from Rs 59.4 crore in 2019-20 to Rs 80.9 crore in 2020-21, before fluctuating across subsequent years. The figures point to a regulatory system that is not merely identifying violations but increasingly using financial penalties and prosecutions to enforce compliance. 

For food companies, this matters because enforcement can raise short-term costs, from reformulating products and changing labels to strengthening quality-control systems. Yet predictable enforcement can ultimately benefit established manufacturers by making it harder for competitors to gain market share through questionable claims or lower-quality products. 

Several media reports mentioned that the Dabur case does not settle whether claims such as “100% natural” or “100% pure” should be permitted. The court’s stay only underscores the legal complexity surrounding how such claims should be regulated. 

But the numbers suggest where the larger consumer risk lies. 

With 65.5% of non-compliant samples classified as substandard in 2024-25, the principal food-safety challenge remains product quality. Labelling defects, while commercially important, represented only 14.7% of non-compliant samples. 

For consumers, that distinction is crucial. A label is a promise; compliance is the test of whether the product deserves that promise. 

The food regulator therefore faces a two-track challenge: make marketing claims measurable and defensible while ensuring that enforcement resources remain concentrated on products that fail actual food-safety and quality standards. 

The Dabur dispute has sharpened the debate over what companies can say. The more important test for FSSAI is whether consumers can trust what companies are actually selling. 

In that sense, India’s food-safety problem is not simply about whether a product can call itself “100% pure”. It is whether the regulatory system can make “safe”, “standard” and “compliant” mean something equally concrete.