Legal aspects

Origin of sodium

Main sources of our daily sodium intake

The table below illustrates the approximate main origin of sodium in our daily sodium intake10, showing that changes in the food industry will be key to cut down the intake.

Source naturally contained, e.g. in vegetables table top, addition in cooking food industry
Current contribution to our daily sodium intake 5% 15% 80%
EU target no reduction 50% reduction 60% reduction
FDA target   short term: approx. 15% reduction
long term: approx. 35% reduction 		short term: approx. 15% reduction
long term: approx. 35% reduction

Overview of international regulations

Labels currently in use

The Global Food Research Program regularly publishes condensed overviews on front-of-package labelling including maps where on the world which labels are implemented. The following list might not be complete but gives a general overview on labels that are currently in use.

Food labelling Nutri Score

Europe

In the EU, there are multiple countries with government-endorsed, voluntary interpretive labels:

Nutri-Score was developed in France and can be found on products since 2017. The score of a food product is calculated with a scientific formula where positive and negative aspects of a product are evaluated. The more sugar, salt, saturated fat and energy a product contains, the more "red" (=bad) the score is. It is by now recommended in Portugal, Spain, Austria, Belgium, France, Germany, Luxembourg and Switzerland.

The Keyhole symbol is a positive label that was developed by the Swedish Food agency and is used in Denmark, Iceland, Lithuania, Norway and Sweden. Only food products that comply with the Nordic Nutrition Recommendations can carry the label, which ultimately means that the food "contains less sugar and salt, more fibre and wholegrain and less or healthier types of fat than food products of the same type that can’t be labelled with the Keyhole." 

Other than this, there are also country-specific labels for Denmark, UK, Croatia, Slovenia, Finland, Czech Republic and Poland. However, overall the most interesting regulation to watch out for will be the consequences of the green deal / farm to fork strategy. Here, the proposal is to revise EU rules on the information provided on the food labels, which are supposed to enable the consumer to make healthier choices. The commission adoption which was expected for Q4 2022 is still pending (status February 2023).

Northern America

Canada

Regulation came into force in July 2022, and the industry has time until January 2026 to comply. Warning required if product exceeds set content thresholds for sodium, sugar, saturated fat.

USA

In 2022, the FDA has issued a proposed rule updating the criteria for the "healthy" nutrient content claim on food labels. For sodium, it is suggested to lower the criteria from 480 mg per reference amounts customarily consumed (RACC) to <230 mg per RACC for individual foods so that they can still be labeled "healthy".
Additionally, the FDA proposed to amend 80 standards of identity (SOI). These standardised recipes include salt as a required or optional ingredient, but currently the use of salt substitutes is not allowed.

Latin America

Argentina

Since November 2021 (implementation by August 2022), warning label(s) are needed if a product exceeds set content thresholds for sodium, saturated fat, calories, sugar, total fats.

Brazil

Since October 2022, warning label(s) are needed if a product exceeds set content thresholds for saturated fat, sodium, sugar.

Colombia

Since December 2022, warning label(s) are needed if a product exceeds set content thresholds for sodium, added sugars, saturated fat.

Chile

Since June 2016, warning label(s) are needed if a product exceeds set content thresholds for calories, sugar, sodium, saturated fat.

Mexico

Since October 2020, warning label(s) are needed if a product exceeds set content thresholds for: calories, saturated fat, sodium, sugar, trans fats.

Peru

Since June 2019, warning label(s) are needed if a product exceeds set content thresholds for sodium, sugar, saturated and trans fat. Additionally, products with >1 warning label and/or warnings for trans fats must include the text "avoid excessive consumption."

Uruguay

Since March 2021, warning label(s) are needed if a product exceeds set content thresholds for sodium, sugar, saturated and total fat.

Venezuela

Regulation entered into force in December 2021, and the industry has time until December 2024 for implementation: warning label(s) are needed if a product exceeds set content thresholds for sugar, saturated fat, trans fat and sodium

Asia and Pacific

Thailand

Since 2007, there is a label to enable "healthy choices".

Singapore

Since December 2022, there is the "nutri-grade mark for beverages".

Sri Lanka

Since 2020, there is a traffic light system for solid food and sugar, fat and salt content.

Further countries

Similarly to Europe, there are multiple countries that implemented government-endorsed voluntary interpretive labels: China, Thailand, Philippines, Brunei, Malaysia, Indonesia, Australia and New Zealand.

Middle East

Israel

Since January 2020, red warning(s) are needed if a product exceeds set content thresholds for saturated fat, sodium, sugar and vice versa a green label, if the food is "healthy".

Iran

Since 2016 there is a nutritional traffic light system to indicate low, medium and high levels of salt, sugar, fat and trans fatty acids.

Young woman in grocery store

Food and food additive regulations

How can sub4salt® help if food manufacturers are challenged with these regulations?

sub4salt® consists only of permitted ingredients according to the European food and food additive regulations. The US Food and Drug Administration (FDA) has affirmed as GRAS (generally recognised as safe) sodium chloride (21 CFR §182.1) and potassium chloride (21 CFR §184.1631). Sodium gluconate is also affirmed as GRAS and is permitted for the use in food as sequestrant (21 CFR §182.6757) or nutrient supplement. It is safe under the conditions of its intended use. However, it may be allowed only in certain applications and not in all countries, therefore, please get in contact for further legal advice.

Claims

Claims about the effect of sub4salt® components on the maintenance of a good health are regulated by Regulation (EC) No 1924/2006. Two scientific opinions11/12 that were published by the EFSA support the indication that high sodium intakes increase  blood  pressure; consumption of  foods  low  or  very  low  in  sodium  helps  to  maintain  normal blood pressure, that potassium helps to maintain normal blood pressure and that potassium contributes to normal muscular and neurological function. However, for the indication of claims on the final product label, we recommend our customers to carefully evaluate the eligibility of their recipe to a claim and to verify the wording.

Sources

[9] Collins B, Kypridemos C, Pearson-Stuttard J, Huang Y, Bandosz P, Wilde P, Kersh R, Capewell S, Mozaffarian D, Whitsel LP, et al; Food-PRICE Investigators. FDA sodium reduction targets and the food industry: are there incentives to reformulate? Microsimulation cost-effectiveness analy-sis. Milbank Q. 2019;97:858–880. doi: 10.1111/1468-0009.1240

[10] Harnack LJ, Cogswell ME, Shikany JM, Gardner CD, Gillespie C, Loria CM, Zhou X, Yuan K, Steffen LM. Sources of sodium in US adults from 3 geographic regions. Circulation. 2017;135:1775–1783. doi: 10.1161/ CIRCULATIONAHA.116.024446

[11] https://efsa.onlinelibrary.wiley.com/doi/pdf/10.2903/j.efsa.2010.1469

[12] https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/j.efsa.2011.2237

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