Examine how adequate India's regulatory framework (FSS Act 2006, IMS Act 1992) is in protecting infant nutrition from commercial influence.

The first 1,000 days set lifelong food preferences, which makes infant food a high-stakes market. India regulates it on two fronts. The FSS Act, 2006 controls what goes into the product, and the IMS Act, 1992 controls how it is sold. The framework is sound in design but gaps in it leave room for commercial influence.

Strengths of the framework

• Composition control: The FSS (Foods for Infant Nutrition) Regulations, 2020 cover products from birth to 24 months. They prefer lactose and glucose polymers as carbohydrates [1].
• Marketing control: The IMS Act restricts promotion, inducements to health workers and misleading labels, with the aim of protecting breastfeeding [2].
• Responsive reform: A 2026 draft amendment proposes to bar sucrose and fructose in foods for infants up to six months [3].

Gaps that let commercial interest in

• Sugar is permitted: Sucrose and fructose may still make up up to 20% of total carbohydrate [1]. Firms can therefore call themselves "compliant" without being healthy, as the 2024 Cerelac row showed.
• Wrong age group: The draft covers only 0–6 months [3]. WHO advises exclusive breastfeeding in that period and introducing complementary foods at 6 months. It calls sweetened milks unsuitable at 6–23 months [5]. The cereals and purées where sugar exposure actually happens are left out.
• Ingredient-based loophole: The rule names only some sugars. Fruit concentrates and other sweeteners can replace them. WHO Europe finds that sweet purées high in free sugars dominate baby-food shelves [4].
• Weak labelling: Infant foods are exempt from showing per-serve RDA contribution on labels [6], so parents find it harder to judge sugar content.
• Reactive enforcement: In the 2024 controversy, foreign NGOs found the problem through testing; FSSAI did not. The two laws also sit under different ministries (Health; WCD), so enforcement is split [2].

Way forward

• Extend the no-added-sugar rule to 24 months.
• Adopt a nutrient-profile model that judges the finished food's free sugar and its promotion together, adapted from WHO's NPPM (6–36 months) [4].
• Set fixed reformulation deadlines, test the same brands across markets, and coordinate FSSAI and IMS enforcement.

The framework's structure is sound, but its standards are lenient and enforcement only reacts to outside pressure. Health-based standards and joint enforcement of the FSS and IMS laws would protect every child's right to nutrition under Article 47 and advance SDG 2.2 (ending malnutrition) and SDG 3 (good health).