Alcohol Labels: Food Safety’s Newest Compliance Frontier

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By Ritu Sharma

New Delhi, Aug 5:  Most drinkers assume that a bottle labelled “aged 12 years” contains whisky that spent twelve years in a barrel.

Under India’s own alcoholic beverage regulations, that assumption has never actually been guaranteed.

Regulation 13.7 of the Food Safety and Standards (Alcoholic Beverages) Regulations, 2018 requires any age statement to reflect the youngest spirit in a blend, not the oldest.

A bottle built from spirits aged three, eight, and fifteen years may legally be labelled only as three years old.

FSSAI’s notices to alcohol manufacturers this month suggest a number of producers have not been following that arithmetic.

The regulator’s notices, issued this July, cover two distinct violations.

The first relates to the added flavours. Brandy, gin, rum, vodka, and whisky are required to derive their characteristic taste solely from raw materials and the manufacturing process. FSSAI says it found instances of manufacturers introducing flavours directly instead.

The second relates to the age claims, where the regulator flagged brands using the word “aged,” or indirect synonyms implying maturity, without the disclosure that Regulation 13.7 requires.

Companies have been directed to explain why enforcement action should not follow, and a stakeholder consultation involving the Confederation of Indian Alcoholic Beverage Companies was convened to discuss the findings, with the industry body maintaining that its members follow FSSAI’s norms.

The timing is notable less for what it says about liquor specifically than for what it says about the direction food-claims enforcement has been moving in more broadly this year.

Alcohol has long occupied an odd position in India’s food regulatory architecture, governed by the same overarching Act as everything else on a supermarket shelf but treated, in practice, as something closer to a separate universe of excise rules, state licensing, and industry self-description. That separation is narrowing.

The same logic FSSAI has applied to a “no added sugar” claim sitting beside maltodextrin, or a “100 percent atta” biscuit that is closer to seventy percent, is now being applied to a whisky label implying an age the blend does not actually carry throughout.

In each case, the underlying principle is identical — a claim printed or implied on packaging has to be provable against a defined standard, not simply plausible to a consumer glancing at a shelf. 

Alcohol manufacturers spent decades competing partly on the prestige an age statement conveys.

FSSAI’s position is that prestige built on a technically accurate but functionally misleading number is exactly the kind of claim the Alcoholic Beverages Regulations already existed to prevent, and that enforcement, not just the regulation’s text, needed to catch up.

Ashwin Bhadri, Founder and CEO of Equinox Labs, sees the alcohol notices as confirmation that no food or beverage category is likely to remain outside this scrutiny for long.

“Whether it’s a biscuit calling itself digestive, a juice claiming to manage diabetes, or a whisky calling itself aged without disclosing what that actually means under the regulation, the underlying question regulators are asking is the same: can you prove it? Alcohol was arguably the last major category operating on legacy trust rather than documented substantiation. That’s now changing category by category, and there’s no reason to expect it stops here.”

For manufacturers, the practical takeaway is straightforward even if the compliance work is not: an age statement, like a health claim, is no longer a marketing choice a brand gets to make unilaterally.

It is a number regulators expect to be able to verify, and increasingly, one they are checking. (BVI)

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