CCPA Fines Britannia Rs 1 lakh for selling a bread declared to contain 62% wheat flour as “100% Whole Wheat Bread”, holding that “100%” signals totality of composition to an ordinary buyer.
New Delhi: The Central Consumer Protection Authority (CCPA) has imposed a penalty of Rs 1 lakh on Britannia Industries Ltd. for advertising its bread as “100% Whole Wheat Bread” when its own packaging declares wheat flour (atta) at only 62%, and has directed the company to discontinue the advertisements on all print, electronic and social media [In Re: Britannia Industries Ltd.].
The order of October 22, 2026 was passed by Chief Commissioner Nidhi Khare and Commissioner Anupam Mishra in exercise of the powers under Sections 10, 18, 20 and 21 of the Consumer Protection Act, 2019. Britannia was directed to file a compliance report within 15 days.
How the proceedings began
The Authority took suo motu cognizance of claims made for the product on Britannia’s website, its YouTube channel, Facebook and Instagram pages and its packaging. Six claims were first taken up, among them “100% Whole Wheat Bread”, “Made with Goodness of Wheat” and “Britannia 100% Whole Wheat Bread pairs perfectly well with a healthy diet”. A notice dated January 13, 2025 was issued, and Britannia replied on January 28, 2025 that its labelling and advertising complied with the food safety regulations. The matter went to the Director General (Investigation) on February 7, 2025.
During the investigation, the Food Safety and Standards Authority of India (FSSAI) told the investigators that the claim was misleading and ambiguous, and recorded that it had issued an advisory on May 28, 2025 asking food businesses to stop using the term “100%” on labels and promotional material. The order also notes an improvement notice served on the company on July 30, 2026. The investigation report of September 7, 2026 was shared with Britannia, which sent no comments, and the Authority heard the company on October 12, 2026. Three of the six claims were dropped, and the three that use the prefix “100%” were examined.
The legal position
Under Section 2(28) of the Consumer Protection Act, 2019, an advertisement that falsely describes a product, or is likely to mislead consumers about its nature, substance, quantity or quality, is a misleading advertisement. Section 2(47) treats a false representation about the composition or standard of goods as an unfair trade practice. Section 21 lets the CCPA direct discontinuation or modification of such an advertisement and impose a penalty of up to Rs 10 lakh, with higher penalties for repeat contraventions.
The order also relies on Regulation 2.6 of the Food Safety and Standards (Labelling and Display) Regulations, which requires whole wheat flour to form at least 75% of the prescribed composition before a bread may carry the name “Whole Wheat Bread”. On June 18, 2026, the CCPA had penalised Storia Foods and Beverages Pvt. Ltd. and Mrs. Bectors Food Specialities Ltd. Rs 1 lakh each over claims using the term “100%”.
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What Britannia argued
Britannia contended that “100%” referred to the wheat component of the bread, which was entirely whole wheat flour with no maida, and that the product satisfied the compositional requirement on a flour basis. Its counsel submitted that the product contains 62% whole wheat with the rest made up of other ingredients, that a qualifier linked by an asterisk read “Made From 100% Whole Wheat Flour On Flour Basis”, and that the FSSAI advisory is advisory in nature and does not mandate compliance. The order records that the company has begun changing the name at certain places to “Zero Maida Whole Wheat Bread”.
What the CCPA held
The Authority rejected the reading that the 75% threshold could be used to justify the prefix “100%”, and held that the absence of a rule demanding 100% wheat flour does not make absolute claims permissible.
“In common parlance as well as under regulatory scrutiny, the expression “100%” conveys totality of composition and not selective exclusivity of a single category of ingredient.”
It found it “extremely difficult” for an ordinary consumer to reconcile the prominent “100%” on the front of the pack with the “62%” in the ingredients on the reverse, and held that the small-font qualifier could not cure the impression created by the main claim. The Authority also referred to the 2022 misleading advertisement guidelines, under which a disclaimer must be in the same font as the claim and clearly visible.
On the health claim, the Authority held that the line “pairs perfectly well with a healthy diet”, read with the pack statement that the fibre in three slices equals that in one roti, implied a substitute for a traditionally prepared roti. It said that accepting Britannia’s reasoning would allow a product with 5% atta and no maida to be sold as “100% Atta Bread”.
“The Opposite Party has, therefore, not merely overstated the proportion of whole wheat in the impugned product but has also employed a product nomenclature that is, on the stated facts, inconsistent with the prescribed compositional requirement.”
The directions
Britannia must discontinue the misleading advertisements with immediate effect from all print and electronic media, including social media, pay a penalty of Rs 1,00,000, and submit a compliance report to the CCPA within 15 days of the order.
Why the order matters
The ruling extends the Authority’s recent line on the expression “100%”: a product that meets a prescribed compositional threshold on one measure cannot use an absolute claim that the whole product does not support. Compliance with food labelling rules, the order says, does not by itself answer a challenge under consumer protection law.
It also shows how the Authority reads packaging as a whole, since a prominent front-of-pack claim is judged against what an ordinary buyer would understand, and a smaller qualifier elsewhere may not rescue it. This is the Authority’s finding on the material before it, and the company may seek its remedies under the Act.
Case Title: In Re: Britannia Industries Ltd. [F.No. CCPA-2/1/2025-CCPA]
Bench: Nidhi Khare, Chief Commissioner, and Anupam Mishra, Commissioner, Central Consumer Protection Authority
Date of Order: October 22, 2026
Appearances: Advocates Sandeep Kumar, Mohd Mohsin Beg, Tahir Nizam and S Siddharth Jain for Britannia Industries Ltd.