What’s The Whole Truth? India’s Clean Label D2C Brands Vs FSSAI

India is in the middle of its biggest food-regulation crackdown in years, and the Supreme Court has now weighed in. 

During a hearing on September 10, the apex court intervened on what a mandatory front-of-pack warning label should look like. It told the Food Safety and Standards Authority of India (FSSAI) that its proposed red hexagon symbol for packaged foods high in sugar, salt or saturated fat was broadly acceptable in principle, but that several important details were still unclear.

The bench said it was “concerned with the health of people, more particularly growing children”. It directed FSSAI to file a response affidavit within 10 days, addressing everything from the scientific basis for its thresholds to the size of the hexagon relative to the pack and whether a red symbol risks being confused with the marker quick commerce apps already use for non-vegetarian food.

The case is set to be heard on September 28 again, which could likely be a consequential call for packaged food companies, D2C brands especially. 

At the heart of the matter is FSSAI, which has been issuing a wave of notices to food companies over labelling and advertising claims it says are misleading, unsubstantiated or, in some cases, simply not true.

The marquee names caught up in this include FMCG giants: Dabur was told in August to strip “100% Natural” and “100% Pure” off its honey, ghee and cooking oil; Marico had to explain the “Heart Pro” claims on its Saffola cooking oil.

But it’s a different, younger set of companies that this crackdown seems to be squeezing hardest: the new-age D2C food brands that spent the last five-odd years building an entire identity, and raising a large amount of the VC capital, on the promise of “clean” eating: no added sugar, 100% natural, zero maida, organic, vegan and many other claims.

By Inc42’s estimates, at least 20 such brands from The Whole Truth and MasterChow to Pluckk, Raw Pressery, Two Brothers Organic Farms, Troovy, Healthy Master and Neuherbs have received FSSAI notices since May 2026 alone, almost all of them for the same underlying reason: a claim printed on the front of the pack that the regulator says doesn’t hold up.

For an industry that has spent years selling itself as the antidote to Big Food, the ensuing regulatory crackdown fundamentally questions this market positioning as a healthy alternative to the legacy packaged food products across millions of retail shelves in India.

For these brands, the notices have come on top of a demand problem that’s eating into growth. Indian D2C nutrition brands have struggled to boost repeat purchases, with ingredient costs and the difficulty of demonstrating an actual nutritional benefit weighing on them well before FSSAI started reading their front labels.

But a lot has changed since the FSSAI crackdown began. Till now, convention dictated that a disputed claim would be settled between a brand, its competitor in arbitration or outside the courts. The Supreme Court’s intervention on September 10 moves it into a proceeding that now has a date attached, and this could direct the course of the entire industry, not just one brand. 

Manisha Kapoor, CEO and secretary general of Advertising Standards Council of India (ASCI) told Inc42 that there is an expansion in the number of products and claims entering the health and wellness space, particularly in nutraceuticals, functional foods and products positioned around metabolic health, gut health and immunity.

“Our Annual Complaints Report 2025-26 found that food and beverages accounted for 376 cases; the previous year it was 332 cases. These figures indicate that F&B advertising has continued to be a significant violative category of the ASCI Code,” she added.

Inc42 has reached out to the several of the flagged brands — The Whole Truth, MasterChow, Pluckk, Two Brothers Organic Farms and Healthy Master among them — for comments. We will update the story as and when they respond.

Where It Actually Started

If there’s a single moment that preceded this entire crackdown, it’s The Whole Truth’s dark chocolate bars.

In fact the claims and counter claims of “No Added Sugar” on The Whole Truth dark chocolate bars began three years before FSSAI’s enforcement wave began.

The Whole Truth is exactly the kind of brand that triggered a wave of “clean-label” packaged food startups in India. The company raised nearly $83 Mn from investors including Peak XV Partners (formerly Sequoia India), Matrix Partners, Sofina and Sauce.vc.

Its pitch has always been ingredient transparency — whey, protein bars, granola and chocolate with nothing hidden on the label.

So when rival chocolate brand Paul & Mike filed a complaint with ASCI in August 2023 and later with FSSAI arguing that The Whole Truth’s “No Added Sugar” claim on its dark chocolate bars didn’t hold up because the bars were sweetened with date powder, it struck at the company’s core promise.

The Whole Truth’s founder, Shashank Mehta, initially defended the claim, arguing publicly that dates have a glycaemic profile closer to boiled carrots or apples than to refined sugar, and that globally this distinction is “clear and settled.”

But as the FSSAI notice moved through 2024 and 2025,the company eventually agreed to change its labelling replacing “No Added Sugar” with “Sweetened with Dates,” and spelling out the exact composition on pack, for instance “55% Cocoa, 45% Dates.”

Mehta later took to social media himself to explain the change, and, by most accounts, apologised specifically for how long it took the company to actually roll out the new labels, citing procurement lead times and existing inventory as the challenges behind it.

MasterChow, the ready-to-cook brand that has raised roughly $9 Mn across four rounds, was served a notice by the FSSAI on June 19, one of 14 companies flagged that week, over “100% Natural” and “Freshly Made” claims on its ramen noodles.

By August 19, MasterChow was named again, this time among a group of companies that had gone further and voluntarily removed the word “100%” off their packaging entirely, following a broader FSSAI directive that the term 100% has no defined legal meaning under Indian food law and risks implying an absolute purity that can’t really be verified.

The same June 19 batch of notices hit Pluckk, the farm-to-fork and functional-nutrition brand that has raised about $15 Mn including a ₹100 Cr round this year.

The FSSAI notice to Pluckk was over a “No Added Sugar” claim on its mango fruit juice, a product that turned out to be roughly half sugarcane juice by volume.

Pluckk cofounder and CEO Pratik Gupta while responding to our questions stated that while its  product and label was already compliant with the law, the company has responded to the questions by FSSAI and they have advised the brand to add “contains naturally occurring sugar”in front of the pack, along with the no added sugar claim.

“We will comply with this change. In fact, to go a step further in consumer transparency, we are moving our ingredient disclosures directly to the front of the pack,” he added.

Raw Pressery, the cold-pressed juice brand that had raised close to $34.5 Mn over its lifetime before being acquired by Wingreens Farms in 2021, was flagged the same week for claiming its Alphonso mango drink contained only “naturally occurring sugars,” despite added fructose.

According to Inc42’s analysis and media reports, through the months of June and July, a second wave had hit a longer list of health-positioned brands like Neuherbs, for calling itself “True Vitamin”; Troovy and Healthy Master, for using the word “healthy” in their branding; Two Brothers Organic Farms and Storia, for “organic” and “healthy” claims that FSSAI wants tied to actual certification rather than marketing language.

Storia’s case did not stop at FSSAI. The CCPA fined the brand in June over the same class of “100%” claim.

By this time Juza Foods, a Kerala-based baby food brand again hit by the FSSAI crackdown, discontinued its “100% Ragi” and “100% Vegan” claims in mid-August and briefly suspended its own ecommerce site to fix its labelling.

With FSSAI ordering an entire industry crackdown especially those promoting healthy clean alternatives through marketing, labelling, their major distribution channels like quick commerce platforms are also under the scanner.

The Quick Commerce Trap

There’s a reason this crackdown is landing on D2C food brands with particular force, and it has less to do with the brands themselves than with where most of them are actually sold: on quick commerce apps, where a consumer might have relatively less time to decide purchases.

In fact, quick commerce and ecommerce together gave rise to a wave of clean-label food brands and beverages marketed as healthy alternatives.

Rahul Hariprasad, founder of the D2C healthy food brand Sureats, said, “In a physical store, packaging gives the consumer an opportunity to look at the front, back, ingredients and nutrition information. Online, the consumer may see only a product image, a few claims and the price before clicking ‘buy.'”

This purchasing behaviour has made it all the more pertinent for the brands and marketplaces to be explicit and careful in their front-label marketing claims.

According to a survey conducted by LocalCircles in August, 89% of its poll respondents want any front-of-pack warning label to also show up prominently on ecommerce and quick commerce listings, before a product is even added to a cart.

Sachin Taparia, founder of LocalCircles, told Inc42 that he doesn’t think the logistics of adding that warning to a listing page will be much of a hurdle for quick commerce apps which already display a small red marker to indicate non-vegetarian products.

Now the material change as a result of the FSSAI crackdown and the Supreme Court hearing will be a red hexagon symbol for high-sugar or high-salt items, but that shouldn’t be a meaningfully bigger lift.

Parul Sharma, cofounder and CEO of the D2C food brand Gladful, said that quick commerce has made the product page an extension of the pack. “That makes consistency critical including the product title, images, claims, nutritional information and ingredient list should all tell the same story,” she added.

So while the quick commerce platforms may have to make listing adjustments when new rules come into effect, Taparia said there could be a likely change in consumption behaviour and hence spending on these platforms.

“A consumer who is buying a packet of chips ten times a month may replace two of those purchases with roasted makhanas or peanuts because of the awareness which was exactly the idea behind the rule — to move society towards healthier consumption through awareness,” he said.

Notably, the ongoing crackdown isn’t limited to the brands selling through quick commerce either — the platforms themselves aren’t exempt.

In July, Swiggy Instamart was hit with nine separate FSSAI notices over products sold through the platform, alleging that some had reached customers rotten, spoiled or past their expiry date.

One of the brands named was Swiggy’s own private label, NOICE, whose eggs, the regulator said, were being sold under a name not covered by Instamart’s existing FSSAI licence.

Instamart is not the only platform under scrutiny. In August, Zepto had a Bengaluru dark store sealed over food safety violations, an enforcement action aimed at the platform’s own facility rather than at any brand listed on it.

But right now the brands caught in FSSAI’s crosshairs, which almost owe their existence to the quick commerce platforms, have been forced into a course correction.

“That means D2C brands will need to think about the entire digital shelf — product images, titles, descriptions, nutritional information, claims and warnings — with the same seriousness as physical packaging,” the Sureats CEO said.

“When consumers can compare products instantly, brands will increasingly need to win on what the product actually contains rather than simply how well it is marketed,” he added.

Karthik Srinivasan, a communications strategy consultant known for his social media commentary on brand messaging, argued that consumer awareness over the last few years has substantially grown and impulse-driven quick commerce shopping should not lead the brands to mis-sell or mislead consumers under the guise of healthy alternatives.

“Quick commerce is about faster delivery, but that doesn’t mean customers make impulsive purchases of new products without doing any research. Otherwise, we wouldn’t have people seeking specific details on sugar content, fat content, protein. Customers have always been discerning, and they also look at larger trends in health whether it is high-fibre or high-protein. That is hardly justification for brands to skimp on truth and mis-sell their products,” he said.

ASCI’s Kapoor noted that as  food advertising increasingly moves across digital formats, brands need to ensure that their claims remain substantiated and that important qualifications are not lost. 

“Even if consumers scroll past information quickly, it is the brand’s responsibility to make sure that adequate information required to be provided to the consumer under food laws is present clearly,” she added.

A Reckoning For Clean Label

The larger question that looms over these clean-label new-age brands is that some of these marketing claims have also unearthed formulations which consumers likely were not aware of — natural sugars addition, no verifiable means to claim 100% purity or vegan/organic sourcing among others.

So far the response to this crackdown has been an instantaneous change in the labelling and marketing of products. For instance, The Whole Truth swapped “No Added Sugar” for “Sweetened with Dates.” MasterChow dropped “100%” from its ramen packaging.

But for an entire industry carved out of a genuine need of “healthy, clean-label” products in India, would this be enough especially when the brands claimed themselves as manufacturing products for the above consumer cohort?

The Sureats CEO said that the industry will have to rethink beyond the packaging claims and shift the focus to transparency in terms of formulations too.

“This could actually create an opportunity for brands that genuinely have better nutritional profiles. Instead of competing only through claims such as ‘healthy’ or ‘natural,’ brands can differentiate through transparent ingredient lists, meaningful nutritional advantages and, where commercially viable, probably reformulation too,” he added.

“Clean label cannot simply be a marketing claim. It has to show up in the ingredients, formulation and nutritional profile. The answer is not finding safer words for the same promise. It is building products that can stand on their ingredients and nutrition, and letting the marketing follow,” the Gladful founder said.

She added that brands need to have stronger internal checks around how claims are developed, reviewed and substantiated paired with a return to basics with consumers “Show the ingredients, show the nutrition, explain the choices, and give consumers a reason to trust you again,” Gladful’s Sharma added.

“Beyond that: does the verbiage on the pack and marketing collaterals mislead or overclaim? These are basic checks that didn’t get enough pushback earlier, but now they do,” Srinivasan added.

ASCI’s Kapoor argues that most D2C brands tend to have lower than required evidence for the claims they make. 

“They tend to present study results in exaggerated ways that mislead consumers about the product delivery. D2C brand marketing teams may not always be well trained and familiar with the nuances of food regulation, but ignorance of the law is not a legitimate excuse. This is a training gap they need to bridge proactively given the nature of claims they make and the seriousness of the category in which they operate,” she told Inc42.

The Accountability Question

Amidst the heated debate on front-of-pack labelling and revisiting formulations, Vishal Sharma, founder and principal consultant at Legal Defence Advisors (LDA), said that if a company doesn’t comply, or the claim is serious enough, it can escalate into licensing action or a penalty proceeding for misbranding or misleading advertising.

“We’ve already seen the regulator go further than a notice this year. In August, it invoked its power to actually stop a company from selling a product, in Dabur’s case, though that particular order has since been stayed by the Delhi High Court for want of a proper hearing,” LDA’s Sharma said.

The escalation is not confined to the FMCG names. Storia, among the brands FSSAI pulled up in June, drew a CCPA penalty the same month — a D2C brand moving from a notice to a fine rather than to a relabelling, which is the outcome most of the brands in this story are still betting they can avoid.

Correcting the label, he added, doesn’t retrospectively clean the slate for the brand.

“When an adjudicating officer decides on a penalty, the law requires them to weigh things like whether the company gained financially from the claim, how widespread the harm was, and whether it was a one-off or a repeated pattern. A quick correction can work in a brand’s favour at that stage, but it doesn’t erase the fact that a violation occurred in the first place,” he added.

Srinivasan places the responsibility across the entire chain that produces a claim, not on any one function.

“It’s also on the founders who passionately market their own products on their personal handles as much as the over-eager marketing and creative teams who are desperately looking for the next attractive word or phrase to convince buyers in a very crowded market,” he said.

His test for founders wanting to get ahead of a notice is less about legal review than personal accountability.

“Would they feed that product daily to their own five-year-old child, or their 77-year-old grandmother? What would an 11-year-old understand when she reads the label — would she be able to comprehend what the product is good for and not good for? Would a grandmother be able to comprehend it?” he said.

Those questions are not specific to food. 

The vocabulary which the FSSAI has targeted is the same one that built India’s D2C beauty and personal care brands. Clean beauty has been THE pitch for a decade’s worth of brands. 

Instead of the FSSAI, these brands are being governed by state-level food and drug administrations such as the one in Maharashtra. Brands will be tested on their compliance with consumer protection law and health regulations when it comes to their product claims,  rather than food safety and hygiene laws.

Whether this is a just an issue about untested and fake claims made by manufacturers or a real change in how retail food manufacturing, it is not just about one retail company, brand or category, this could change the course of the new-age retail industry as a whole and raise the entry barrier for new D2C brands. 

Edited By Nikhil Subramaniam

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