Summary of the January 2011 Consultation Feedback on Reducing Sodium in Processed Foods
Between 2009 and 2011, Health Canada worked with stakeholders, particularly from industry, to understand technical issues and challenges with reducing sodium in foods in order to set feasible sodium levels for processed foods that will assist in achieving the average sodium intake goal of 2300 mg per day by 2016.
In January 2011, Health Canada requested feedback related to the draft sodium reduction levels for both Group I and Group II processed food categories. These food categories and draft levels were developed based on feedback received during previous consultations and meetings between Health Canada and interested stakeholders. More information on the current approach used by Health Canada to set sodium levels and on the guidance for food industry on reducing sodium in processed foods can be accessed at www.healthcanada.gc.ca/sodium.
Stakeholder Responses to Consultation Questions
In all, during the winter 2011 consultation period, written feedback was received from 41 individual food companies, 10 food industry associations, 2 consultants to the food industries, one health non-governmental organization, one consumer group, one health professional, and one provincial government department. The following is a summary of the feedback received.
Roles of Salt and/or Sodium
The majority of the stakeholders agreed that salt and/or sodium played a functional role in several food categories. In addition to information collected in 2010, the following summarizes responses on function of salt and/or sodium by food category:
Bakery Products - Stakeholders indicated that salt and/or sodium was essential for maintaining product structure, controlling fermentation rates, increasing shelf life, maintaining microbial safety and functioning as a flavour enhancer.
Dairy Products - Stakeholders indicated that salt was required in dairy products for enzymatic, humidity and microbial control, for texture and for food safety. It was also indicated that for butter, salt was important in preservation.
Salad Dressings, Mayonnaise and Sandwich Spreads - In these food categories, sodium was reported to be essential for emulsification, pH stability, microbial safety and flavour.
Fish Products - Stakeholders indicated that salt was used as a stabilizer, a preservative, an antioxidant, texture and colour preservative, and for moisture retention and proper batter preparation. It was indicated that sodium was needed in combined dishes for food safety, functionality in machining, moisture retention, preservation, texture, colour retention and for sensory attributes.
Meat Products - In processed meat products, stakeholders stated that salt and/or sodium is required for food safety, sensory attributes, protein extraction, texture and structure, water retention and preservation. They also indicated that it was essential for curing and flavouring of the meat. For fresh meat products, the functions of salt and/or sodium included enhancing microbial food safety, sensory attributes, protein extraction, texture, and water retention.
Soups - For oriental noodle soup, sodium was reported to be required for noodle quality and texture.
Sauces, Dips, Gravies, and Condiments - Few details were provided about the functional role of salt and/or sodium in these foods, however salt was reported to serve mainly as a preservative in some of these categories.
Vegetables - Stakeholders described a functional role for salt in pickled vegetables where salt is said to favour the growth of beneficial bacteria, mask bitter flavours resulting from fermentation, extract water and act as a preservative.
Pasta Sauce - Stakeholders indicated that sodium is needed for food safety and sensory attributes.
Snack Products - Stakeholders indicated the use of salt as an anti-humectant and flavour enhancer in these products.
Beverages - Sodium was reported to serve a taste/flavour function in this type of food products.
Infant and Toddler Foods (mixed dishes, cookies, biscuits, snacks) - Sodium was indicated to play a technical and a taste/flavour role.
Sodium Reduction Levels
Within bakery products, the majority of the stakeholders indicated that the 2016 maximum levels were achievable for cookies, crackers and mixes but less so for breads and buns because of sodium's functional requirement and the current technology (e.g. lack of alternatives to sodium based leavening agents). There was no clear agreement regarding the remainder of the bakery products, however it was felt that research was needed to develop suitable salt substitutes and solve technical issues related to sodium reduction. Stakeholders indicated that reduction beyond the 2016 levels was not possible with existing technologies and that for most bakery products, with the exception of mixes, the phased reduction levels were not achievable due to limited resources to reformulate products, inadequate timelines for reformulation and due to technical issues.
For cereal products, support was expressed for a single 2016 reduction level based on sales weighted average (SWA) levels; however it was felt that the draft 2016 levels were not likely to be achieved. Furthermore, the phased levels were seen as restrictive and unachievable. It was recommended that a subcategory maximum level and an overall SWA level for 2016 be put in place and interim phased levels be eliminated.
Progress was reported by stakeholders in cottage and ricotta cheeses; however, no indication was given regarding additional reductions in these products. For cottage and processed cheeses it was indicated that the 2016 maximum levels were achievable but for other cheese types, stakeholders indicated lowering sodium to 2016 maximum levels may result in loss of quality or in potential food safety and organoleptic issues. With respect to butter, the 2016 maximum level was said to be achievable but it was pointed out that this level was set lower than that for butter blends which may result in competitive issues. The phased reduction levels for butter were seen as unachievable because of consumer taste and preference and because a large amount of butter is stockpiled under "Plan B", a program from the Canadian Dairy Commission to manage and ensure a steady supply of butter.
The 2016 maximum levels were said to be achievable for salad dressings, mayonnaise and sandwich spreads, as well as for the majority of sauces, dips, gravies and condiments, peanut butter and canned vegetables. With respect to the latter category, stakeholders felt the 2016 SWA levels was set too low for vegetable juices because salt enhancers were expensive and left an unpleasant aftertaste. Furthermore, stakeholders thought it was unlikely that products in the canned vegetable categories could meet the phased levels. It was indicated that reformulation takes time and research is needed to determine the minimum levels of sodium required for preservation and for an acceptable taste profile. It was noted, however, that several products in the canned vegetable categories have decreased sodium levels of up to 50%.
Stakeholders indicated that for the majority of fish products, the 2016 maximum levels were achievable. Progress in sodium reduction was also reported in canned and frozen fish products (35% - 60% reduction). Concerns were expressed that the phased levels and the 2016 SWA levels are unlikely to be achieved due to the natural sodium present in the products, the lack of control over the salt in ingredients supplied by others, the amount added by suppliers prior to canning, as well as the short timeframes for reformulation.
With respect to combined/mixed dishes, stakeholders indicated that the 2016 maximum levels were achievable but the phased reduction levels are unlikely to be achieved. The reasons cited were that ingredient manufacturers are not able to reduce sodium within the allowed time frame, as well as the diverse number of products and corresponding shelf lives make it difficult to reformulate and test the products for food safety and consumer acceptance. Manufacturers indicated that gradual reductions of about 25% have already been made within this category and that progress made before 2010 should be considered when setting reduction levels.
As opposed to the proposed maximum levels, the 2016 SWA levels for processed meats as well as fresh meat products were seen as not achievable due to sensory, shelf life and product yield concerns. Stakeholders also indicated that further reductions may lead to food safety concerns. Some stakeholders indicated that approval of post lethality processes, such as irradiation, would help to achieve some of the levels. With respect to the phased reduction levels, it was thought unlikely that the fresh meat products would meet the levels whereas some processed meat products would. The reasons given for not being able to achieve the phased levels include technical requirements, shelf life, food safety issues, and consumer acceptance. Some stakeholders thought that for processed meats specifically, the phased levels may be achievable if small and medium sized industries have access to technology and funding. It was indicated that some fresh meat products have already had their sodium content decreased in response to market forces and consumer demand.
The suggestions and comments received on food categorization and on potential missing food categories were taken into consideration and helped to form the categories as published in Guidance for the Food Industry on Reducing Sodium in Processed Foods In general, comments received were about separating or combining categories, adding products to categories, moving products to another category and identifying products by their cooked or uncooked state. Sports drinks were suggested to be removed from the beverages category because sodium enables athletes to maintain fluid and electrolyte balance.
Stakeholders indicated that research gaps prevent them from reducing sodium in their products. Some of the gaps identified include: limited ingredient options; alternate processes for preservation and flavouring that retain quality and cost; how to cryoprotect seafood without sodium phosphate; shelf-life, sensory attributes, consumer acceptance; impact on food safety; suitable salt substitutes; collaborative database on sodium reduction research; technological and food safety challenges related to reducing sodium in cheese.
Plans on Promotion of Sodium Reduction Efforts
Some stakeholders indicated that they would promote their sodium reduction efforts, while others stated they would not. Those that plan to communicate efforts will do so by several possible mechanisms including through trade literature to food service establishments; advertising and signage; front of packaging statements; company websites; corporate communication on progress; sodium reduction label claims; and through direct communication with customers and soliciting feedback.
Further Suggestions and Comments
Suggestions were made on how to effectively reduce the amount of sodium in Canadians' diets and on how industry can be supported in reaching the proposed sodium reduction levels. Examples included more timely regulatory approval of sodium substitutes; regulatory amendments to allow communication of reductions that are less than 25 percent; mandated sodium reduction levels; consumer education; as well as gradual reduction of sodium when palatability plays a role. Suggestions also included requirement of constant communication and updates; making sodium reduction levels in-line with other major international markets; ensuring research grants/funding are available for manufacturers; establishment of an "e-library" with information on salt reduction regulations, rules and technologies; a list of low sodium ingredient suppliers and addressing regulatory impediments.
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