Reconstituted fruit, fruit percentage and "no added sugar" on drinks and fruit-milk labels

A drink that is named for one fruit, pictured as that fruit, and built on another fruit's concentrate is a labelling problem for the business that sells it. The same problem reaches a dairy or a beverage plant that names a fruit lassi or a fruit-milk drink. This page is how the name, the percentage and a "no added sugar" line have to follow the tank. It is not legal advice.

The reader-facing account of the same reports is How to read a packaged juice label. The words this site will and will not put on a fruit preparation are in Labelling fruit preparations. The fruit percentage you are buying is a field on How to read a fruit preparation spec.

What the reports say was alleged

CNBC-TV18, 19 October 2026, NDTV Profit, India Today, 19 October 2026 and PTI the same day describe adjudication over one pomegranate juice. The company is not named here.

The composition they report is 4 percent pomegranate juice concentrate and 12 percent apple juice concentrate. They say the name and the imagery could mislead a buyer about that composition. They say the label did not adequately identify the juice as reconstituted from concentrate. They say "Equivalent to 100% Fruit Juice (Reconstituted)" was not in line with the applicable advisory. They say "No Added Sugar" was prominent on the front, and a declaration about naturally occurring fruit sugar was less prominent on the back. PTI says the regulator described the declarations as in alleged contravention, that the product was inspected and sampled, that the explanation was unsatisfactory, and that adjudication was sanctioned. India Today says allegations and the start of proceedings remain subject to the legal process, and should not be treated as a final finding of liability.

This page has not seen the label or the order. It does not convert 4 percent concentrate into a reconstituted juice percentage. The reports do not print the factor that would let anyone do that.

The name, the picture and the percentage

The Labelling and Display Regulations, 2020, compendium version VIII, 9 September 2025, are a compilation. The gazette prevails.

Regulation 4(3) says pre-packaged food shall not be described or presented in a manner that is false, misleading or deceptive, or likely to create an erroneous impression regarding its character.

Regulation 5(1) says every package carries the name of the food, indicating its true nature, on the front. Where a standard gives the name, that name is used. Otherwise a common name, or a description of the true nature, is used. A coined or brand name is additional, and it still has to comply with the advertising regulations.

Regulation 5(2) says ingredients are declared in descending order of weight or volume at the time of manufacture. Added water is declared, except where it is part of an ingredient such as a brine or a syrup that is itself declared. A compound ingredient at less than 5 percent of the food need not have its own ingredients listed, except additives that still perform a technological function.

Regulation 5(2)(g) is the percentage rule. For a food sold as a mixture or combination, the ingoing percentage of an ingredient, by weight or volume at manufacture, is disclosed where that ingredient is emphasised as present through words or pictures or graphics, or where it is not in the name but is essential to characterise the food and consumers expect it, if omitting the quantity would mislead or deceive. The regulation then lists cases where the disclosure is not required. They include ingredients used as flavourings, spices, herbs or their extracts; a reference in the name that would not mislead because the amount does not characterise the food or distinguish it from similar foods; a drained-weight declaration, with a stated exception where an emphasised ingredient is in a mixed product; a requirement that another provision already covers; a pictorial serving suggestion made for consumer information; and added micronutrients that are already in the nutrition declaration.

A pack that shows one fruit, and names that fruit, is emphasising it. The apple concentrate in the reports would have to be in the ingredient list in its real order. If apple is what the liquid mostly is, the name and the picture have to be able to survive that list. A second fruit used as a carrier is declared as that fruit. This page will not call it a flavour if it is a juice concentrate doing the work of the drink.

"Flavoured" is the right word when the fruit is a flavour, not a characterising ingredient. Labelling fruit preparations already says this site will not supply a "real fruit" sentence. The same refusal covers a drink whose picture is a fruit the tank does not support.

Which standard the name is claiming matters. In the fruit and vegetable products chapter, version 3, 7 May 2025, a fruit juice under 2.3.6, a nectar under 2.3.9 and a fruit drink under 2.3.10 are different foods. Pomegranate juice in the 2.3.6 table has a minimum of 12.0 °Brix. "Other fruit nectar" and mixed fruit nectar are at a minimum fruit-juice content of 20 percent. A fruit drink other than lime or lemon is at a minimum fruit-juice content of 10.0 percent. Those are category minima. They are not a calculation from the 4 percent and 12 percent concentrate figures in the reports.

Reconstituted, and the word "100%"

Sub-regulation 2.3.6 says the ingredient list mentions "reconstituted" against the juice that is reconstituted from concentrate. The product is labelled sweetened juice if added nutritive sweeteners exceed 15 g per kg.

The advisory of 3 June 2024 says there is no provision in the Advertising and Claims Regulations for a "100% Fruit Juice" claim. It says "100%" is misleading where water is the major ingredient and the fruit claimed is present in a limited concentration, and where the juice is reconstituted from water and fruit concentrate or pulp. It instructed businesses to remove the claim from labels and advertisements, and to exhaust pre-printed packaging before 1 September 2024. The reports say a 2026 label's "equivalent to 100%" line was treated as non-compliant with the applicable advisory. This page does not read "equivalent to" as a way around that advisory.

The press release of 30 May 2025 asks businesses not to use "100%" on food labels, packaging and promotions at all. It says the term is undefined, and that it can suggest absolute purity or superiority, including by comparison with other products. It cites regulation 4(1) and regulation 10(7). The press release describes an advisory. The PDF opened here is the press release.

"No added sugar" on a fruit drink or a fruit-milk drink

Regulation 6 of the Advertising and Claims compendium dated 14 December 2022 allows a non-addition claim for sugars only when all of the following are true. No sugars of any type have been added, examples including sucrose, glucose, honey, molasses and corn syrup. The food contains no ingredient that contains sugars as an ingredient, examples including jams, jellies, sweetened chocolate and sweetened fruit pieces. The food contains no ingredient that substitutes for added sugars, examples including non-reconstituted concentrated fruit juice and dried fruit paste. The food's own sugars have not been increased above the amount the ingredients contribute, the example being enzymes that release sugars from starch.

Where sugars are naturally present, the label carries "CONTAINS NATURALLY OCCURRING SUGARS". A disclaimer used with a non-addition claim has to be conspicuous and legible. A front-of-pack "no added sugar" line and a smaller back-panel line are the presentation the reports say was misleading. Whether a given drink meets the four conditions is a label review. It is not a sentence on the fruit preparation's brochure.

A fruit preparation can bring fruit sugars, a sweetener, or both, into a flavoured milk or a lassi. The customer's ingredient list has to show what was added, in descending order. If the preparation is a compound ingredient under 5 percent of the finished food, its own ingredients still include any additive that keeps a technological function in the drink. The spec has to name the fruit, the sweetener and any colour so the advisor can write the pack. Labelling fruit preparations will not write the consumer claim.

This page did not take a minimum fruit percentage from a flavoured-milk standard. It is not printing one. The drink you sell uses the standard that applies to that drink. A fruit preparation for flavoured milk is briefed on the dairy page. Lassi bases on that page are pilot work. The sample-ready fruits for the dairy line are the ones named on fruit preparations. None of those pages is a permission to name a drink for a fruit the preparation does not contain.

What to write on the brief

Use the sample request on this page. Say:

• The finished food: a juice, a nectar, a fruit drink, a flavoured milk, or a lassi
• The fruit the customer will name, and any other fruit in the preparation
• The fruit percentage on the preparation spec, as a figure the customer's label can use
• Whether the finished food is meant to say "no added sugar", so the sweetener system can be checked against regulation 6
• Whether the juice in the preparation is from concentrate, so "reconstituted" is not a surprise on the customer's ingredient list

A picture that the spec cannot support is a change of name. It is not a quieter claim.

Sources

• CNBC-TV18, 19 October 2026
• NDTV Profit, 19 October 2026
• India Today, 19 October 2026
• PTI, 19 October 2026, via Swadesi
• FSSAI compendium, Labelling and Display Regulations, 2020, version VIII, 9 September 2025
• FSSAI Chapter 2.3, fruit and vegetable products, version 3, 7 May 2025
• FSSAI advisory, 3 June 2024, reconstituted fruit juices and "100% fruit juice"
• FSSAI press release, 30 May 2025, on the term "100%"
• FSSAI compendium, Advertising and Claims Regulations, 2018, file dated 14 December 2022