Ingredient Colonialism: How Transnational Food Corporations Exploit Indian Regulatory Gaps.

AUTHOR BIO: Rhydham Singh is a political science graduate from Hindu College, University of Delhi

Introduction

The food a corporation sells should be defined by safety and nutrition, not by the geography of its consumers. If a person walks into a supermarket in London and buys a packet of Lay's Classic Chips, then he is buying a snack fried in sunflower oil, which is good for their heart's health. Whereas, the same snack if bought in India is seen to be made by frying in palm oil. Palmolein is a cheaper alternative and has a high saturated fat content. This is bad cholesterol that causes heart attacks.

This practice is not for flavour preferences; rather, it indicates ingredient colonialism. In essence, 'Ingredient Colonialism' denotes a biased corporate approach where multinational corporations take advantage of the less stringent regulations of developing countries to market inferior, less nutritious, or more dangerous product formulations compared to those offered in Western markets. Although the packaging, branding, and marketing stay consistent globally, the ingredients differ by region. Affluent Western consumers are offered premium, health-focused ingredients, whereas consumers in developing markets such as India are given versions filled with less expensive alternatives, higher sugar levels, or lower-quality additives. Essentially prioritising corporate profit margins over the health of citizens in these nations.

An article sold in India may look identical from the outside, but the list of ingredients may differ. In many cases they differ in terms of type of oil used, sugar levels, sodium levels, added flavours, dairy solids or fat sources. Brands often do this to maintain a globally clean and premium image while making maximum profits in large markets like India, China and other poorer countries. These profits are met at the cost of Indian consumers' health. These types of changes have been seen in everyday consumer goods, such as Nestlé Cerelacs, Johnson & Johnson baby powder, Coca-Cola soft drinks, etc.

In this article, I discuss how the government has been making policies to tackle this type of colonialism. It includes the recent Supreme Court mandate in February of 2026, new FSSAI regulatory frameworks as well as various other legislations.

Comparative Analysis: Mapping the Empirical Double Standards

To understand the structural aspects of ingredient colonialism, it is crucial to analyze how these corporate double standards appear in practice. As shown in the comparative analysis below, these cheap substitutes are endangering the lives of the Indian consumers and converting them into second-grade consumers. As of March 2026, this is not only a health concern but also a legal challenge for the Indian lawmakers.

Ingredient comparisons in case of Heinz Ketchup and Coca Cola for international variants were cross-verified via real-time digital inventory listings on Amazon website(India),Coca Cola website (India and USA), and official Heinz website(UK) as of 1st May, 2026.

Why is this problem happening in India?

The products produced for export to Western countries often face strict standards and regulation. Due to this, they are of very high quality, unlike the products for the Indian consumers that prioritise quantity over quality. Global brands often follow the practice of ingredient discrepancy. This practice involves the intentional alteration of a product’s chemical, nutritional, or material makeup by a manufacturer in various geographic locations, while still preserving the same brand image and consumer expectations.

This is being done due to the following reasons:

1. Price Sensitivity – India is a low-average per-capita income country with an income of $2700 for 2024-25, as per the World Bank. Although the World Bank classifies India as a lower-middle-income nation according to gross national income per capita, international brands frequently exploit this purchasing power statistic to rationalize their cost-reduction approaches. Rather than taking on the increased production expenses of high-quality, health-conscious components, corporations use these local economic standards as a justification. This is a major reason, which compels Indian consumers to prioritise lower prices over premium quality. Ultimately forcing the brands to reduce production costs.
2. Cheaper ingredient substitutes – In order to reduce these production costs, brands use cheaper alternatives in India. Such as palm oil instead of high-quality oils. They consistently reduce product quality, replace high-end materials with less expensive options, and modify formulations while claiming to make products 'affordable' for emerging consumer markets. Thus, converting a macroeconomic measure into a justification for corporate hypocrisy.
3. Regulatory differences – Indian regulatory bodies like the Food Safety and Standard Authority of India (FSSAI) are often found to be less strict compared to similar bodies abroad. This regulatory flexibility is inherently integrated into FSSAI's structure. In contrast to Western organizations such as the European Food Safety Authority (EFSA), which require rigorous pre-market approvals, FSSAI places significant emphasis on post-market monitoring. Additionally, as emphasized by the Comptroller and Auditor General (CAG) of India in its Performance Audit Report (Report No. 37 of 2017), the national framework experiences a notable transparency shortfall, which includes significant deficiencies in laboratory infrastructure and enforcement inconsistencies at the state level. These data deficiencies and extended transition phases for newer labeling regulations provide global brands with the operational adaptability to sustain dual-standard products while staying technically compliant. Thus, these global brands have technically received a free pass to maximise profits in India.
4. Some brands often justify this practice as a method to meet local taste preferences. But it is just a facade for cost-cutting.

This situation is prevalent in India, as several high-profile cases are still ongoing in the apex court. Although these brands gave various justifications, there have been various regulatory actions and public outcry for 'one brand, one quality'.

The legal argument

The below-mentioned cases indicate how ingredient discrepancies have been so common in India and can be seen in major brands which are trusted by Indian consumers.

1. Nestlé Cerelac

Public Eye and the International Baby Food Action Network (IBFAN) conducted an investigation into Nestlé's leading baby food brands. This investigation shows that, for Nestlé, not all babies are equal when it comes to added sugar. In Switzerland, Germany, France and the UK, the infant cereals as well as the formulas had no added sugar. These countries are the main European markets of Nestle and have strict regulations.

Whereas the same products when sold in lower-income countries like India, Bangladesh, South Africa, Pakistan, etc. contained high levels of added sugar. For example, 3 gm added sugar is found per serving in Nestlé Cerelac in India. NDTV reported that a recent study conducted by researchers forming the Non-Communicable Diseases Risk Factor Collaboration (NCD-RisC) has warned that obesity is on the rise, especially in low and middle-income countries. This further fuels an increase in non-communicable diseases like diabetes.

Following intense public pressure, Nestlé committed to review their portfolio and continue to innovate and formulate their products to further reduce the level of added sugars, without compromising on nutrition, quality, safety and taste. They are making progress towards reducing it further, as well as providing more options without added sugar.

1. Johnson & Johnson's baby powder

This ongoing controversy has seen diverse treatment across the globe. There have been 40,000 lawsuits against Johnson & Johnson for producing baby powder contaminated with asbestos. Asbestos is regarded as a carcinogen, which causes ovarian cancer and mesothelioma. The company has lost many multi-million-dollar lawsuits and made a commercial decision to stop the production and sale of this baby powder. This decision was made in 2020 for the US and Canada, and a global ban was announced in 2023. As reported in The Journal of the Missouri State Medical Association.

Although this ban was announced globally, talc-based versions continued to be on sale in India, longer than in the US or Canada. This exposed Indian children to extreme health risks. As of 2026, Johnson & Johnson replaced the original toxic powder with a natural corn-starch based powder in India. This made it equivalent to the global standards of the company. As reported in the International Ban Asbestos Secretariat.

1. Lay's chips

M9 News reported that Lay's chips are promoted to be fried in heart-healthy sunflower oil in the USA. However, in India the same snack uses palm oil. The latter is found to be high in saturated fats that increase LDL cholesterol and cause heart attacks. PepsiCo India started testing blends of sunflower oil and palmolein as a replacement. The company claimed that this would make Lay's relatively healthier without changing the taste.

1. MDH and Everest spices

In 2024, the BBC reported that Singapore and Hong Kong stopped the sale of spices produced by Indian companies like MDH and Everest. This halt was due to elevated levels of ethylene oxide found in the spices, a cancer-causing pesticide. They also reported that an analysis done by the news agency of the US regulatory data found that since 2021 an average of 14.5% of US shipments of MDH spices were rejected due to the presence of bacteria.

While these companies stated that their products were completely fine, they faced international bans. These products were being sold domestically in India. This raised the question of whether export-quality items faced more scrutiny than those sold in domestic markets.

The global vs. domestic regulatory bodies

1. The Global Check

According to smartfoodsafe.com,

"Each additive is subject to rigorous safety valuations by regulatory agencies to ensure it is safe for consumption at specified levels. The use of food additives is regulated by the Food and Drug Association (FDA) in the US and the European Food Safety Authority (EFSA) in Europe with strict standards for acceptable levels and required labelling."

The EU tends to emphasise the potential hazard of an additive, focusing on the possibility of it causing harm. This often leads to strict regulations or outright bans on certain additives if there is any dispute. However, the US FDA focuses on risk. This means it may allow an additive in the US until there is clear evidence that it poses a significant risk to consumers. As reported by Smart Food Safe.

These agencies have proved to be very strict. For example, the US FDA's Quality Management System Regulation (QMSR) guidelines of 2026 required manufacturers to ensure quality not just at the factory but throughout the products' lifecycle.

1. The Indian Check

In recent years, the FSSAI has introduced various changes and regulations to meet the international standards. expanding eligibility for food safety auditors from a handful of traditional food science disciplines to 39 academic fields. The new draft rules also include stricter experience and certification criteria to enhance the quality of food safety audits. The amended rules have been introduced at a time when India's food processing sector is growing at a fast pace, with food exporters under growing pressure to meet international safety standards. The 49th Central Advisory Committee meeting, 2026, emphasised the need for risk-based inspection and sustained surveillance drives in high-risk commodities such as milk and milk products, edible oil, spices and honey. They called for strict action against non-compliant food business operators (FBOs).

As per the Faculty of Food Safety and Quality, FSSAI in January 2026 has mandated that all claims made by food businesses regarding the safety of their products shall be backed by scientific evidence. It plans to introduce a standard format guided by scientific panels, evidence on nutrition, toxicology, allergies and other factors.

The Hindu reported on 17 February 2026, that the Supreme Court has mandated FSSAI to introduce front-of-package warning labels for packaged foods that are high in sugar, salt and saturated fats.

On 12 March 2026, FSSAI guidelines strengthened licensing and registration. This bolstered traceability and stricter checks on ingredient quality. FSSAI has also abolished companies from using terms like '100%', 'natural', etc. on their packaging, unless there is evident proof that their product justifies those termsThe era of using Indian markets as an experiment lab is finally coming to an end. The Indian consumers will no longer continue to live as lab rats at the cost of their health. The new regulations have pushed Indian regulatory bodies to move from a mere reactive institution to an action-driven institution.

Conclusion

The era of using Indian markets as an experiment lab is finally coming to an end. The Indian consumers will no longer continue to live as lab rats at the cost of their health. The new regulations have pushed Indian regulatory bodies to move from a mere reactive institution to an action-driven institution.

The judiciary has also stepped in to fill in the gaps. The 'right to be informed' is legally recognised under the Consumer Protection Act, 2019. Thus, making a self-declaration certificate is a prerequisite for all global brands. This is to ensure that the image of each global brand is accompanied by a singular standard, worldwide. Any disparity found in the ingredient composition of a local product when compared to its global version would make the brand legally liable. Nevertheless, tackling the issue of ingredient colonialism necessitates confronting a significant macroeconomic fact, the Indian consumer market cannot consistently accommodate the higher pricing structures of Western markets. To avoid high regulatory standards leading to unaffordable food costs, India needs to execute structural policy reforms.

Initially, the FSSAI ought to implement a 'Tiered Compliance Subsidy' or financial incentives for large corporations that reformulate local, cost-efficient products by utilising high-quality domestic alternatives like swapping costly imported stabilisers for inexpensive, nutrient-rich local grains such as millets. Secondly, the government should reduce the burden of compliance costs by making substantial investments in centralised, high-quality public testing laboratories, which will transfer the economic responsibility of stringent quality assurance from the producer's financial statement to state-funded infrastructure.

Furthermore, the message is clear to the global conglomerates. The health of Indian citizens is no longer negotiable. The Indian market is moving from the idea of 'caveat emptor', which means 'let the buyers beware', to the idea of 'caveat venditor', meaning 'let the seller beware'.

Disclaimer: The views expressed in this article are solely personal to the author and do not necessarily represent the views of the publisher, editors, or any affiliated institution.