Bitter and sweet

1. At a Glance

• Core issue: India's food regulator, the FSSAI, has issued a draft proposal to remove the current allowance that lets manufacturers add sucrose and fructose to foods meant for infants aged 0–6 months [1].
• Editorial position ("Bitter and sweet", The Hindu, 22 Oct 2026): The draft is a good step. But the FSSAI should cover all added sugars, and should judge both the ingredients and the nutritional profile of the finished food. Otherwise firms can simply swap sucrose for another sweetener [1].
• Why it matters for UPSC: The topic ties together food regulation (FSSAI), WHO nutrition standards, the Codex Alimentarius, the IMS Act, 1992, child malnutrition and obesity, and corporate ethics ("nutritional dumping") [1].

2. Why in the News

• October 2026: The FSSAI's draft proposal to drop the sucrose/fructose allowance in infant foods was the subject of a The Hindu editorial (Chennai edition, page 10, 22 Oct 2026) [1].
• Industry vs public health: Companies say their sugary formulations comply with the Codex Alimentarius. Public health experts call the sale of sweetened infant foods "nutritional dumping" [1].
• Background, not checked against the retrieved sources: The debate grew sharper after reports in April 2024 that a multinational's infant cereals sold in India contained added sugar while the same products in some European markets did not.

3. Background & Evolution

• 1981: The WHO International Code of Marketing of Breast-milk Substitutes was adopted (background; not from retrieved sources).
• 1992: India enacted the Infant Milk Substitutes, Feeding Bottles, and Infant Foods Act, 1992 (IMS Act). It restricts the marketing of infant foods for children up to two years old [1].
• 2016: WHO issued guidance on ending the inappropriate promotion of foods for infants and young children. The 2022 profile model grew out of this guidance [2].
• 2020: India's Food Safety and Standards Regulations, 2020 allowed sucrose plus fructose up to 20% of carbohydrates in products for 0–6-month-olds [1].
• 2022: The WHO Regional Office for Europe published the Nutrient and Promotion Profile Model (NPPM) for commercially produced foods for children aged 6–36 months [2][3].
• 2026: The FSSAI released its draft proposal to remove the sugar allowance for 0–6-month products [1].

4. Core Static Facts

Item	Fact
Regulator	Food Safety and Standards Authority of India (FSSAI) [1]
Parent Act / ministry	Food Safety and Standards Act, 2006; Ministry of Health & Family Welfare (background)
Current rule	FSS Regulations 2020: sucrose + fructose ≤ 20% of total carbohydrates in foods for 0–6 months [1]
Draft change	Remove that allowance entirely [1]
WHO feeding norm	Exclusive breastfeeding for the first 6 months, then adequate complementary foods with no added sugar until 24 months [1]
WHO NPPM	Published 2022 by WHO Europe; covers ages 6–36 months; aims to cut salt and free sugars and tighten marketing [2][3]
NPPM concerns	Sweet purées, and products where fruits release sugars during processing [1]
Marketing law	IMS Act, 1992: restricts promotion of infant foods for children up to 2 years [1]
Industry defence	Compliance with Codex Alimentarius standards [1]

5. Multi-Dimensional Analysis

Economic / Commercial

• Sugar is a cheap bulking agent. It also makes food taste better and encourages repeat purchases, so adding it is a commercial strategy [1].
• "Nutritional dumping" means selling products in poorer markets that are nutritionally worse than what the same companies sell elsewhere [1].

Social / Health

• Babies who get used to sweet tastes early may form lifelong preferences, which raises the risk of childhood obesity and NCDs. This is relevant because India carries a double burden of malnutrition (analytical inference).
• Weakening the WHO norm on exclusive breastfeeding hits poorer families hardest, since aggressive marketing of substitutes reaches them most [1].

Legal / Regulatory

• Codex standards set the minimum a country must meet. A national regulator is free to set stricter rules [1].
• Banning only sucrose and fructose leaves a gap: other sweeteners could replace them. A full ban would cover all added sugars and assess the finished food's nutrient profile [1].

Ethical / Governance

• Companies follow the legal minimum but not public health best practice. This is a gap between corporate responsibility and compliance [1].
• The 1992 IMS Act limits marketing, and the 2020 FSS rules govern what goes into the product. Together they protect infant nutrition from both sides [1].

International / Standards

• The WHO NPPM is a benchmark for both composition and marketing. Studies have used it to assess baby foods in several countries [2][3].

6. Recent Developments (last 12–18 months)

• 2026: FSSAI draft proposal to remove the sucrose/fructose allowance for 0–6-month infant foods [1].
• 22 Oct 2026: The Hindu editorial "Bitter and sweet" urged the FSSAI to cover all added sugars [1].
• WHO's complementary feeding guidance continues to recommend no added sugar for infants and young children [1][4].

7. Prelims Hooks

• Under the FSS Regulations 2020, sucrose + fructose may not exceed 20% of carbohydrates in foods for infants 0–6 months [1].
• The FSSAI's draft proposes to eliminate this allowance [1].
• WHO recommends exclusive breastfeeding for 6 months [1].
• WHO advises avoiding added sugars in complementary foods until 24 months [1].
• The IMS Act dates from 1992 [1].
• The IMS Act restricts infant-food marketing for children up to two years [1].
• The NPPM was published in 2022 by the WHO Regional Office for Europe [2][3].
• The NPPM covers foods for children aged 6–36 months [2].
• The NPPM targets salt and free sugars [2].
• The NPPM traces back to WHO's 2016 guidance on inappropriate promotion of foods for infants and young children [2].
• The NPPM flags sweet purées and fruit sugars released during processing [1].
• Industry defends its formulations by citing the Codex Alimentarius (FAO/WHO food standards body) [1].
• "Nutritional dumping" is the term for selling nutritionally inferior foods in some markets [1].

8. The Draft Misses the Product That Started the Row

• The rule and the scandal cover different age groups
• As the editorial describes it, the FSSAI draft only removes the sugar allowance for foods meant for babies aged 0–6 months [1].
• The 2024 controversy was about Nestlé's Cerelac cereals. These are complementary foods (the first solid foods given alongside breast milk) for babies from six months [5].

• So a product like Cerelac may fall outside the draft even after it becomes law.

• WHO's advice runs much longer than India's rule

• WHO says no added sugar in complementary foods until 24 months [1].
• The draft protects only the first six months, when WHO says a baby should get only breast milk anyway [1].

• In practice, babies start eating packaged cereals and purées at 6–24 months. Most sugar exposure happens in this period, and the draft leaves it uncovered.

• What the industry calls a limit is actually a permission

• Nestlé India's chief said Cerelac had 7.1 g of sugar per 100 g, well below a permitted maximum of 13.6 g per 100 g [6].
• When the legal ceiling is almost twice what the product contains, the company can call itself compliant without doing anything about the health concern.

9. Nestlé's Defence, and Where It Falls Short

• The strongest case for the industry
• Nestlé says its sugar levels are within FSSAI limits [6]. It also points to Codex Alimentarius (the FAO/WHO body that sets global food standards) [1].
• It says it cut added sugar in its infant cereals by up to 30% over five years [6].
• It says its infant foods are formulated globally and calls the charge of treating Indian consumers differently 'unfortunate' [10].

• Some of this is true. The company broke no Indian law. Cutting sugar step by step is real progress, and a sudden ban gives factories no time to change recipes.

• Why the defence still fails

• The same product, Cerelac wheat-based for six-month-olds, was sold with no added sugar in the UK and Germany [5].
• In India, 15 Cerelac products averaged 2.7 g of added sugar per serving [5].
• This shows a sugar-free recipe is possible, and the company already makes one. The sugar in India is a business choice, not a technical need.

• Codex sets the minimum standard. A country is free to set stricter rules [1]. Meeting Codex shows the product is legal, not that it is safe for children's long-term health.

• Fair concession: a phase-in period for reformulation is reasonable. A permanent double standard is not.

10. A Regulator That Moved Only After Outside Pressure

• India's regulator did not find the problem
• The sugar gap was exposed by Public Eye and IBFAN, two campaign groups outside India. They tested products in many countries [5].
• FSSAI started its probe and collected Cerelac samples only after their report came out in April 2024 [7].

• The draft rule arrived in 2026, about two years later [1].

• The industry's praise is a warning sign

• In October 2024, Nestlé launched 14 new Cerelac variants. Its chairman praised FSSAI as 'more proactive, industry-centred' [8].
• A food safety regulator's first duty is to the consumer, here a baby who cannot choose.

• When the regulated company publicly calls the regulator 'industry-centred', the public has reason to ask whose interest the regulator serves. This is the risk of regulatory capture (when a regulator starts serving the industry it is meant to control).

• The campaigners were not satisfied

• Public Eye and IBFAN later called for legal action against Nestlé over its 'double standards' [11].
• The draft rule does not settle what happened to products already sold.

11. Fruit Sugar: The Next Loophole

• Banning sucrose does not end sweetness
• The editorial warns that firms can swap sucrose for another sweetener [1].
• The bigger risk is fruit. WHO's NPPM flags products where fruits release sugars during processing [1].

• Free sugars (sugars added to food, plus sugars in honey, syrups and fruit juice) do the same harm whether they come from a sugar bag or from fruit concentrate.

• The European market shows where this leads

• WHO Europe found that sweet purées and snack foods high in free sugars dominate baby-food shelves [9].

• These products often look healthy because they are fruit-based, which makes the sugar harder for parents to spot.

• Why this matters for India's draft

• A rule that names only sucrose and fructose checks the ingredient list.
• A company can drop both and add fruit concentrate. The label then looks cleaner, but the baby gets as much sugar as before.
• Only a check on the total free sugar in the finished food, as the editorial asks for, closes this gap [1].

12. What FSSAI and the Health Ministry Should Do Next

• FSSAI should extend the no-added-sugar rule to 24 months
• This would match WHO's complementary feeding advice [1][4].

• It would cover cereals like Cerelac, which were the actual subject of the 2024 row [5].

• FSSAI should adopt a nutrient profile model, not an ingredient ban

• WHO Europe's NPPM judges the finished product by its total free sugar and salt. It also judges how the product is marketed [2].

• India could adapt this tool for foods for children aged 6–36 months, the same age range the NPPM covers [2].

• FSSAI should give a clear phase-in deadline

• Nestlé's own 30% cut over five years shows companies can reformulate when pushed [6].

• A fixed deadline turns slow voluntary cuts into a legal duty.

• FSSAI should test products itself, not wait for foreign campaign groups

• Public Eye's cross-country testing exposed the gap, not Indian checks [5].

• Regular testing of the same brands across markets would catch double standards early.

• The Health Ministry should link this to marketing control

• The IMS Act, 1992 already restricts promotion of infant foods up to 2 years [1].
• The WHO NPPM treats a sweet product and its promotion as one problem [2]. Indian rules on composition (FSS) and on marketing (IMS) should be enforced together, not separately.

13. Anchors for Answers

• Data: 15 Cerelac products sold in India averaged 2.7 g added sugar per serving, while the same wheat-based product had none in the UK and Germany [5]
• Data: Nestlé India stated Cerelac had 7.1 g sugar per 100 g against a permitted maximum of 13.6 g per 100 g [6]
• Report/Committee: WHO Europe Nutrient and Promotion Profile Model, 2022 (ages 6–36 months) [2]; Public Eye–IBFAN investigation, April 2024 [5]
• Law/Case: Food Safety and Standards Act, 2006; FSS Regulations, 2020 (sucrose + fructose up to 20% of carbohydrates for 0–6 months) [1]; IMS Act, 1992 [1]
• Comparison: UK and Germany: the same Cerelac product sold with no added sugar [5]; WHO Europe found sweet purées and snacks dominate European baby-food shelves [9]
• Scheme: Mothers' Absolute Affection (MAA) programme: promotes exclusive breastfeeding for the first 6 months, the period the FSSAI draft covers

14. Mains Relevance

• GS-II: Health; government policies and interventions; vulnerable sections (children).
• GS-III: Food processing; food safety regulation.
• GS-IV: Corporate ethics; conflict between profit and public good.
• Question stems: 1. "Compliance with Codex standards does not equal public-health responsibility." Discuss with reference to added sugars in infant foods in India. 2. Examine how adequate India's regulatory framework (FSS Act 2006, IMS Act 1992) is in protecting infant nutrition from commercial influence. 3. What is "nutritional dumping"? Suggest regulatory and ethical safeguards against it.

15. Related Topics to Study Next

• FSSAI front-of-pack labelling (FOPL) debate: the same tension between sugar and salt content and industry pushback.
• IMS Act 1992 and its 2003 amendment: the law on marketing infant foods.
• WHO Code of Marketing of Breast-milk Substitutes, 1981: the international basis for the IMS Act.
• Codex Alimentarius Commission: the FAO/WHO standard-setter; know its limits.
• POSHAN Abhiyaan / Mission Poshan 2.0: India's child nutrition flagship.
• NFHS-5 data on obesity and stunting: evidence for the double burden of malnutrition.
• Mothers' Absolute Affection (MAA) programme: promotes breastfeeding.

16. NCERT Concepts to Revise

• Malnutrition (Economy): Article links early sugar to obesity and India's double burden of undernutrition plus overweight; this defines both.
• Dumping (Economy): 'Nutritional dumping' echoes dumping: selling inferior products in some markets that firms wouldn't sell elsewhere.
• National Family Health Survey (Geography): NFHS-5 gives the data on child stunting and obesity that backs the double-burden argument.
• Substitute goods (Economy): Explains why banning only sucrose and fructose fails: firms can swap in another sweetener.
• Stunting (Economy): Key child undernutrition indicator, studied alongside obesity when discussing infant feeding and India's nutrition policy.

17. Common Errors / Trap Areas

• The 0–6 month rule vs the 24-month advice: The FSSAI draft deals with 0–6-month products. WHO's no-added-sugar advice runs to 24 months. The IMS Act's marketing limits also run to 2 years [1].
• NPPM scope: It covers 6–36 months, not 0–6 months. It was issued by WHO Europe, not WHO headquarters [2].
• Which sugars: The current allowance covers sucrose and fructose only. Banning these two is not the same as banning all added sugars [1].
• Codex status: Codex is an FAO/WHO standard-setting body. Its standards are not binding minimums on Indian law.
• IMS Act vs FSS Act: The IMS Act regulates marketing. FSS rules regulate composition [1].