A mixed fruit jam that does not meet the standard and a label full of claims
Sunrise Foods, a small unit in Ajmer, has developed a mixed fruit jam using 40% fruit pulp (mango, papaya, guava) with a refractometer reading of 62 °Brix. To keep cost down while keeping the product sweet, the owner has added both sugar and saccharin, and wants the front panel to read: 'Mixed Fruit Jam - No Added Sugar - Rich in Vitamin C - 100% Natural'. The pouch is filled with 190 g but printed 'Net Weight 200 g' because the filler occasionally overfills. The unit holds a State FSSAI licence, but the jam is to be made by a third-party processor in another state, whose licence number the owner plans to print on the label instead of his own. No shelf-life study has been done, but the label will claim 'Best Before 12 months from packaging'. The owner argues that 'jam is jam' and the label can be corrected later if a customer complains.
1. Assess the product against the prescribed standards for jam and identify every element that must be corrected. For each, say whether reformulation, relabelling or both is needed.
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Product standard (reformulation needed): the standard for jam requires a minimum of 45% fruit pulp and a total soluble solids of not less than 68% by refractometer. At 40% pulp and 62 °Brix the product fails on both counts, so it cannot lawfully be sold as jam, and 'jam' is a reserved name - the name itself is a false description. The choice is to reformulate to 45% pulp/68% Brix, or reposition the product as a proprietary fruit-based spread (with the appropriate licence category and product approval) and drop the word jam entirely.
Saccharin with a 'No Added Sugar' claim (both): the label statement is false and misleading because sugar is added and the sweetener is artificial; the product also cannot be called '100% Natural' once saccharin is present. Synthetic sweeteners are permitted only in the categories and at the levels listed in the regulations, and a 'no added sugar' declaration cannot be made while sucrose is in the ingredient list.
'Rich in Vitamin C' (relabelling or substantiation): a nutrient content claim must meet the threshold in the FSSAI Advertising and Claims Regulations (a 'rich/high' claim requires a substantially higher level of the nutrient than a 'source of' claim - the exact threshold must be checked against the current regulation) and must be backed by a NABL laboratory report. Without analysis, remove the claim.
Net weight (relabelling): 190 g printed as 200 g is a legal metrology violation; the declared quantity must be the actual average.
Lesson: a label cannot be 'corrected later' - misbranding is an offence from the first sale.
2. The owner wants to print only the third-party processor's licence number. Is that acceptable? List the mandatory label declarations the pack must carry.
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Not acceptable. The brand owner whose name appears on the pack remains the food business operator and is answerable for the product; the label must carry his own FSSAI licence number and logo. Where the food is manufactured by another unit, the label additionally gives the name and address of that manufacturing unit and its licence number, so the consumer and the enforcement officer can trace both parties. Merely importing a co-packer's number transfers no legal responsibility and leaves the brand owner exposed to misbranding action. The third-party unit must itself hold a valid licence for that product category, and the arrangement should be covered by a written agreement and reflected in the brand owner's licence details.
Mandatory declarations:
- Name of food (correct category - not 'jam' unless it meets the standard) and brand name
- List of ingredients in descending order by weight, including additives with class names
- Nutritional information per 100 g (energy, protein, carbohydrate, sugars, fat)
- Declaration of the sweetener and the warning 'contains artificial sweetener - not recommended for children' where applicable
- Net quantity (true average weight)
- Name and address of manufacturer / packer / brand owner, with licence numbers
- FSSAI logo and licence number; green vegetarian logo
- Batch number, date of manufacture, best-before, storage instructions
- Country of origin where imported; customer care details
- All text in the prescribed size and in Hindi/English as required.
3. Can a 'Best Before 12 months' be printed on a 62 °Brix jam in a pouch without a study? Justify your answer and outline the shelf-life study you would run.
Read the worked answer
No. Shelf life at 62 °Brix rests on a water activity of roughly 0.86–0.88, which is not low enough to guarantee ambient stability; such a product is prone to surface mould and osmophilic yeast growth, particularly in a pouch with a poor seal or residual headspace air. Printing 12 months without data is an unsubstantiated claim, and if mould appears the brand carries the cost of a recall.
Study design:
- Take three production batches from different days.
- Pack in the commercial pouch and store at 25 °C, 37 °C and 45 °C (with a control at refrigeration temperature).
- Test at 0, 1, 2, 3, 6, 9 and 12 months for °Brix, pH, water activity, yeast and mould count, total plate count, colour and sensory score, and check pouch integrity and seal strength.
- Use the 37 °C/45 °C data as accelerated evidence to predict ambient behaviour, then confirm with the 25 °C data.
- Set the best-before at the point where any parameter first fails, minus a safety margin.
Faster alternative: reformulate to 68 °Brix, hot-fill at 85 °C, invert and hold, use a permitted preservative where allowed, and repeat the study - the higher solids will support a longer shelf life with far less risk.