The U.S. Food and Drug Administration (FDA) has published draft
guidance “that provides practical, voluntary sodium reduction targets for
the food industry.” Titled ‘‘Voluntary Sodium Reduction Goals: Target
Mean and Upper Bound Concentrations for Sodium in Commercially
Processed, Packaged, and Prepared Foods,” the guidance sets short- and
long-term sodium targets for the following food categories: (i) cheese;
(ii) fats, oils and dressings; (iii) fruits, vegetables and legumes; (iv) nuts
and seeds; (v) soups; (vi) sauces, gravies, dips, condiments and seasonings;
(vii) cereals; (viii) bakery products; (ix) meat and poultry; (x) fish
and other seafood; (xi) snacks; (xii) sandwiches; (xiii) mixed ingredient
dishes; (xiv) salads; (xv) other combination foods; and (xvi) baby/toddler

“Our goal is to promote gradual, efficient voluntary reduction of overall
sodium content using effective and sustainable strategies that maintain
other measures of nutritional quality,” states the agency in its guidance.
“The extent and speed of reduction will be different for different products
and categories, since the 10-year targets set were designed to allow for
flexibility in reformulation based on differences in food categories and

Relying on consumption data, FDA estimates that these industry
measures will reduce the mean population intake to approximately
2,300 milligrams of sodium per day, from 3,400 mg/day. The agency
has requested comments pertaining to the food categories and two-year
salt reduction goals by August 31, 2016. It has requested comments
on the 10-year targets, as well as feedback on technical challenges and
innovative solutions to salt reduction, by October 31, 2016. See Federal
Register, June 2, 2016.

Meanwhile, the agency reportedly denied the Center for Science in
the Public Interest’s (CSPI’s) petition for mandatory salt reduction
in packaged and processed foods. “We hope that industry will work
cooperatively with the FDA and health experts to achieve the proposed
reductions, which would benefit the health of all Americans,” said CSPI
President Michael Jacobson in a June 1 press release. “While this is a
voluntary approach as opposed to the mandatory approach we asked
for and that the Institute of Medicine endorsed, it provides clear goals
by which companies can be held accountable. And, it helps level the
playing field for those companies that are already trying to use less salt in
their foods.”

The Grocery Manufacturers Association (GMA) also issued a statement
on the proposed guidelines in support of further dialogue with FDA. As
GMA Chief Science Officer Leon Bruner explains, “Success in cutting
sodium consumption will require a holistic approach that includes
actions by manufacturers, retailers and restaurants and that addresses
consumer behaviors and preferences… Like others inside and outside
of government, we believe additional work is needed to determine the
acceptable range of sodium intake for optimal health. This evaluation
should include research that indicates health risks for people who
consume too much sodium as well as health risks from consuming too
little sodium.” See GMA Press Release, June 1, 2016.


Issue 606


About The Author

For decades, manufacturers, distributors and retailers at every link in the food chain have come to Shook, Hardy & Bacon to partner with a legal team that understands the issues they face in today's evolving food production industry. Shook attorneys work with some of the world's largest food, beverage and agribusiness companies to establish preventative measures, conduct internal audits, develop public relations strategies, and advance tort reform initiatives.

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