Many of you will recall that the 2016 updates to food nutrition labeling included a lower percent daily value for sodium (2300 mg/day). Along with that, the update proposed that there should be a gradual reduction in sodium levels. Last week FDA published a final guidance on voluntary sodium reduction in processed foods, including restaurant foods. As noted in the 2016 draft guidance, ”FDA is not conducting rulemaking with regard to sodium, and these goals are voluntary.”
The initial sodium reduction goal is modest with an aim to reduce U.S. sodium intake from an average of 3,400 mg per day to 3,000 mg per day in 2.5 years. The previously-proposed 10-year goal to reduce the mean sodium intake level to 2,200 mg/day has not been finalized. The guidance focuses on average sodium levels in various food categories and does not set upper limits on individual products or product lines.
The proposal to encourage sodium reduction in processed foods has been controversial. While evidence shows that high dietary sodium increases blood pressure, sodium also has functions beyond kicking up flavor in processed food. Added sodium also affects the texture, stability, and safety of many foods. FDA’s guidance sets targets for both upper bounds and mean sodium levels for various food categories. The targets were developed by assessing the sodium levels of various food categories and by reviewing sales data on those foods. These analyses allowed FDA to set target mean sodium levels that are weighted by the sales data. This means that a greater average reduction in American dietary sodium can be achieved by small changes in high sales categories.
The new guidance provides insights into FDA’s strategy:
“We developed the goals with a particular emphasis on maintaining concentrations needed for food safety, given the function of salt as a food preservative. These short-term goals are within the range of concentrations found in currently marketed foods and are feasible using existing technical strategies.”
“The extent of targeted reduction in each food category is influenced by the functions of sodium-containing ingredients in the category, as well as the distribution of sodium concentrations we found in products within that category. These values are FDA’s goals for each food category as a whole, not necessarily for individual manufacturers who choose to pursue these goals voluntarily. These mean target concentrations represent the benchmarks that we will use to assess the impact of any voluntary efforts by members of the food industry on the overall composition of the food supply.”
The goals are detailed as:
- Support increased food choice for consumers seeking a diverse diet that is consistent with recommendations of the Dietary Guidelines by encouraging food reformulation and new product development for Americans;
- Support the Dietary Guidelines, and NASEM (National Academies of Sciences, Engineering and Medicine) CDRR (Chronic Disease Risk Reduction Intake) recommendations of limiting sodium intake to 2,300 mg/day by encouraging sodium reduction over the short term to achieve an average intake of 3,000 mg/day;
- Provide uniform metrics (mg of sodium per 100 g of food) for voluntary sodium reduction for industry stakeholders;
- Focus on the total amount of sodium in a given food as opposed to individual sodium-containing ingredients; and
- Support and extend industry’s voluntary efforts to reduce sodium across the range of commercially processed, packaged, and prepared foods.
I did a very crude analysis of the proposed target changes to the sales-weighted mean sodium levels and found that FDA is looking for reductions in sodium levels ranging from less than 2% for shelled nuts and seeds to 35% for gravy served in restaurants. FDA has targeted toddler meals for a 23.7% reduction in sodium.
It appears to be common for the restaurant versions of foods such as cheesecake, tomato-based sauces, gravy, potato side dishes, and even whole muscle meats to be slated for greater sodium reductions than their grocery-store counterparts. Notable exceptions to this trend were the grocery versions of butter, margarine, bacon, and bacon bits. I speculate that the requirement to declare sodium levels in the nutrition facts box may be what drives the consumer version of some foods to be lower in sodium than the restaurant versions in order to avoid ‘sodium sticker shock’ on consumer product labels. This would also seem to make sense for the butter, margarine, and bacon products, which have relatively small serving sizes and therefore declared sodium levels that would appear lower in the facts boxes. Chips and popcorn are targeted for 12 to 15 percent reductions but nothing was said about the salted rims of margaritas.
The guidance notes that the reduction in sodium in products should not be accompanied by other ingredient changes that would offset the health benefit of the lowered sodium level. For instance, fat and/or sugar content should not be increased when the sodium is lowered in a given food. Some may recall the low-fat food trends of the 1980’s and 1990’s that resulted in higher sugar levels in processed foods that has been credited for increased levels of obesity and diabetes in the U.S. FDA will be monitoring sodium levels as well as changes in other nutrients that may be affected by product reformulations. It may be safe to assume that those findings will inform the development of longer-term guidance on sodium reduction.