Summary of the February 2010 Consultation Feedback on Reducing Sodium in Processed Foods


Between February and March 2010, Health Canada's Food Directorate sought written feedback from industry stakeholders on the proposed sodium reduction levels that were developed for the first set of food categories (Group I). Group I foods are those which were identified as priority food categories for setting sodium reduction levels. The feedback was used to help revise the Group I levels and to develop sodium reduction levels for the balance of the food categories (Group II).

The levels proposed in 2010 were maximum sodium levels to be attained by all foods in the category by 2016. The following overarching criteria were considered when establishing the proposed maximum levels: maximum levels should be voluntary, significant, gradual, realistic, feasible, measurable and sustainable. It was indicated that maximums are intended to apply to all products in a category, regardless of their price or whether the foods were destined directly to consumers, for further processing, or to the food service and restaurant sectors. Health Canada also recommended that industry pay particular attention to lowering the sodium in foods directed at children as much as possible while ensuring the safety of these foods. 

Additional specific criteria were also used to draft the levels proposed in 2010. These criteria were based on where the Canadian average sodium level for a given food category was in relation to the UK Food Standards Agency (FSA) targets for 2012. More information on the current approach used by Health Canada to set sodium reduction levels and on the guidance for food industry on reducing sodium in processed foods.

Stakeholders' Responses to Consultation Questions

In all, 56 written submissions were submitted in response to Health Canada's consultation questions. The following is a summary of the feedback received.

Roles of Salt and/or Sodium

Bakery Products - Stakeholders indicated that functions of salt in bakery products include: stabilization of yeast fermentation rates; strengthening of the dough and decreasing its "stickiness", thus allowing for high-speed mechanical handling; slowing the growth of spoilage microorganisms; and enhancement of the flavour of the final products. In addition to salt, sodium is also contributed by additives including sodium stearoyl-2-lactylate (SSL), an emulsifier and dough conditioner, and sodium bicarbonate, a leavening agent used in most cakes, muffins, and sweet goods.

Cereals - Stakeholders indicated that the primary functions of sodium in cereals include: product stability, promotion of browning, flavour (sugar/salt balance), control of fermentation, texture, and of starch gelatinization, and expansion and stability of air pockets in extruded products.

Dairy Products - For natural cheeses, stakeholders indicated that salt regulates starter culture growth, ensures proper functioning of the lactic acid bacteria in the formation of cheese, and inhibits undesirable bacteria. They stated that salt is required for rind development, texture formation, characteristic flavour profiles, moisture content, and protein functioning. It was also reported that sodium plays a functional role in the cooling process, acts as an emulsifying agent, controls acidification caused by bacteria (before full cooling), and controls maturation rate. Stakeholders indicated that sodium/salt is essential for food safety (prevention of listeria growth), since it acts as a preservative by decreasing water activity. They added that salt maintains the melting characteristics of specific cheeses, such as mozzarella, where sodium replaces a portion of the calcium in the casein micelles. For processed cheeses, it was reported that sodium is required for emulsification, microbial stability of processed cheese slices, and flavour enhancement.

Fats and Oils (including salad dressings) - In margarines, stakeholders indicated that sodium acts as a preservative and flavour enhancer. In salad dressings, mayonnaise and sandwich spreads, sodium was reported to be essential for emulsification, pH stability, microbial safety and flavour.

Fish Products - For most fish products, sodium is part of the natural product. For salad type shrimp, stakeholders indicated that sodium is essential for maintaining pH and preventing "mushing". For frozen fish products, sodium phosphate is used to stabilize the product and increase shelf life, while sodium erythorbate is used to prevent oxidation. Salt is also used as a flavour enhancer.

Processed Meat Products - In processed meat products, stakeholders indicated that salt is essential for maintaining food safety, tenderness and palatability. It is also important for texture and protein solubility. Reductions in salt increases drying time and affects taste, texture and product yield. Stakeholders indicated that decreased salt content can result in shortened shelf life with the potential that retailers will not purchase products that do not meet their shelf life expectations. They added that salt solubilizes muscle protein which forms a matrix that encapsulates and holds moisture and fat and helps adhere chunks of meat together, which is important for yield and texture. For packaged deli meats, stakeholders indicated that salt is required for texture, to slow microbial growth, and to enhance flavour. It was indicated that sodium nitrite is used as a curing agent and preservative, sodium erythorbate is used as an antioxidant and accelerator for sodium nitrite, and sodium phosphate is used to increase water holding capacity.

Sauces - For sauces, stakeholders indicated that sodium is required for food safety, shelf life, and taste.

Soups - Stakeholders reported that salt plays an essential role in taste, which drives consumer acceptance. Dry cubes and powders need salt for taste but not safety; whereas it was indicated that liquid concentrated products require salt for safety, in addition to taste.

Miscellaneous/combined dishes (appetizers, frozen dinner entrees, frozen pizza, frozen potatoes, snacks) - In the miscellaneous dishes, stakeholders indicated that sodium is often added as a flavour enhancer, although, depending on the product, it could be added for food safety purposes, to decrease water activity, to maintain texture, and to regulate leavening action.

Achievability of Sodium Reduction Levels

Stakeholders' comments on the question "if the proposed draft maximums were achievable" varied depending on the category. Some proposed maximums were deemed achievable, however, stakeholders indicated other proposed maximum levels that were deemed difficult, if not impossible to achieve. Some of the identified barriers to achieving the maximums were the cost of reformulation, covering the cost for research and development (R&D) for identifying suitable alternatives; Canada's vast geography and the resultant distribution system; shortened shelf life and preservation concerns; availability of salt replacers or alternatives; consumer acceptability or aftertaste issues of lower sodium products; food safety issues; short timelines to meet the levels; and acceptability of Canadian lower sodium foods for export to foreign markets.

Needs for Assistance Identified by Stakeholders

In general, stakeholders suggested that:

  • Financial assistance or incentives may help alleviate some of the financial burden of reformulating products. 
  • Technical and R&D assistance would be useful to determine if the technological and microbial safety issues can be addressed in order to meet the maximum levels.
  • Current regulations be revised to allow manufacturers to inform consumers of sodium reductions that are less than 25 percent, and to use front of package promotional claims pertaining to a company's efforts to reduce sodium.
  • Standards of identity be revised to allow for the use of salt substitutes.
  • Regulatory amendments permitting sodium substitutes or alternative ingredients should be fast tracked and a more streamlined regulatory process is needed to speed up the approval process for food additives which would replace sodium.
  • The basis of the % Daily Value for sodium in the Nutrition Facts table should not be changed while efforts are being made to lower sodium, as this might give consumers the impression that sodium has actually increased in the product. 
  • Initial efforts be focused on higher sales volume food products to have the greatest impact.
  • Longer time frames for achieving the maximum levels would be helpful.  
  • Education of industry stakeholders and ongoing information exchange between industry and Health Canada on the sodium reduction be conducted.

Food Categorization

The suggestions and comments received on the food groupings, categorization and identified missing food categories helped to revise the food categories as presented during the January 2011 consultation.

Phased Sodium Reduction Levels

Support for the phased levels varied among the stakeholders. Some stakeholders supported the use of gradual phased levels and that levels should be set in equal increments. Others did not support the setting of phased levels and instead suggested that progress reports be submitted to Health Canada in 2012 and 2014. For cheese, it was suggested that phased levels need to take into consideration that cheeses require various ripening periods. A suggestion was made that progress should be measured as a percentage of a company's portfolio that achieves the 2016 sodium reduction levels. Other stakeholders did not support phased levels because of longer product turn around times and of multiple labelling and package changes. Finally, it was suggested that in lieu of phased levels, periodic fora should be held to allow updates on progress and challenges prior to the 2016 timeframe.

Research Gaps Identified by Industry Stakeholders

Gaps that need to be addressed through research included:

  • Sodium replacements that are functional, safe and acceptable to consumers.
  • Understanding the taste mechanism of salt to help in designing reformulations and/or increase the likelihood of finding acceptable alternatives.
  • The impact of salt reduction on the functionality of products such as handling characteristics of bread dough, safety and protein solubility of meat products and ripening and texture development in cheese.
  • Consumer behaviour in response to lower sodium products.

Further Suggestions and Comments

There was strong support for sales weighted average (SWA) levels to be used instead of levels based on maximums. Some stakeholders argued that this would be a more effective public health strategy since not all products would be clustered below a maximum value. It was suggested that sales-weighted data can be used for assessment purposes. It was added that the use of SWA reduction levels provides the ability to offer a broader choice of low and high sodium content foods to consumers, and that maximums may limit consumer choice and the occasional purchase of higher sodium foods. Stakeholders also indicated that it may be more onerous to reduce sodium in some products, compared to others, making it difficult to move below the proposed maximum levels. These stakeholders added that the progress made to date by industry may be negated if the sodium levels in some foods do not move below the maximum. Finally, there were several suggestions that the final levels for processed as well as restaurant foods should not be released until all consultations on proposed sodium reduction levels are completed.

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