The Legal Risk of Using “100%” Claims in the F&B Industry
Food Safety and Standards Authority of India (“FSSAI”) issued an advisory in 2025 to Food Business Operators (“FBOs”) to discontinue the use of “100%” claims on food labels and in advertisements. Since then, the FSSAI and Central Consumer Protection Authority have stepped up enforcement and are taking action against FBOs that continue to use “100%” claims on their products.
How does it affect FBOs?
FBOs are to discontinue the use of the term “100%” in all advertisements, on social media platforms, and on packaging or product labels.
This advisory has implications across an FBO’s supply chain, including manufacturers, packagers, marketers, and advertisers.
Recent Examples
A bread manufacturing company was fined for using a “100% Atta Bread” claim that did not match product composition. The company was directed to change its labels and pull the claims from packaging, websites, and e-commerce websites.
A juice company was fined for using claims such as “100% Tender Coconut Water” and “100% Natural Juice” and had to take down the claims.
A baby food company using "100% Ragi", "100% Vegan" and "100% Clean Ingredients" claims was asked to withdraw the claims and had to suspend sales through its website, pending rectification.
FSSAI passed a prohibition order against an FMCG for using claims such as “100% Natural”, “100% Pure”, “100% Purity Guaranteed” and “100% Organic”.
An instant noodle company using "100% Natural" on its ramen noodles had to take down the claim.
A cooking oil company using a "100% Pure Coconut Oil" claim in its product name voluntarily removed the claim from packaging and advertisements, discontinued old stock, and is rolling out revised packaging progressively from September 2026.
A biscuit company using a "100%" claim in advertising for a jeera biscuit product voluntarily dropped the claim.
A health and wellness company using a "100%" claim on a honey product complied with the FSSAI advisory and removed the claim.
Can a “100%” claim be made on labels when it can be scientifically proven?
Even if the claim is accurate, FBOs should not use a “100%” claim. FSSAI's advisory is specific that FBOs are to discontinue the use of this claim because the expression is undefined, can be misleading and can create an impression of superiority.
What should FBOs do?
FBOs should not wait for a notice from FSSAI to rectify their labelling claims. The following should be done to lessen regulatory risks:
Audit all existing claims
This includes checking all the product packaging materials, websites, listings on e-commerce sites like Zepto, Instamart, BigBasket, Amazon, Blinkit, etc., social media platforms, and any advertisement.
Replace all “100%” claims
All “100%” claims being marketed by the FBOs should be replaced with better substantiated or verifiable claims.
Instead of | Can Use |
|---|---|
“100% Atta Bread” | “Made with Whole Wheat Flour” |
“100% Natural Juice” | “Made with Real Fruit” or the actual juice/concentrate percentage |
“100% Real Fruit” | “Made with Real Fruit” |
“100% Arabica Coffee” | “Made with Arabica Coffee” or specify the verified Arabica percentage |
3. Review your entire labelling vocabulary
FBOs should review their entire labelling vocabulary, rather than limiting the change to a single “100%” expression. Other absolute claims such as “Authentic”, “Made with No Artificial Ingredients”, “Zero Calories”, and “No Added Sugar” should also be reviewed. They should be truthful, verifiable and not misleading.
Conclusion
Businesses should be careful about the labels they use and how they market them to mitigate regulatory exposure. “100%” claims should not be used in any case. For the products that are already being marketed with this claim, advertisements and labels should be changed. FSSAI can prohibit the sale of a product merely because it carries such a claim.