Summary of the November 2010 Consultation on Use of Sales Weighted Averages and/or Maximums
In November 2010, Health Canada conducted a small stakeholder consultation to follow up on feedback received in response to the February 2010 consultation on proposed maximums. The November 2010 consultation was conducted on the issue of sales weighted average and on maximum approaches to help inform Health Canada's decision-making on the approach to be taken in setting voluntary sodium reduction levels for processed foods. The intent of the consultation was to obtain perspectives and expert input on the impact of each approach on population health, reaching the interim and long term sodium intake goals, food industry and food economics, and on the impact on small and large companies.
Sodium reduction levels were developed for food categories to assist in achieving the average sodium intake goal of 2300 mg sodium per day by 2016 in a manner consistent with population health objectives. Three potential approaches were presented:
Option 1 - Maximum levels for each food category: This means setting sodium limits for individual food categories.
Option 2 - Sales Weighted Averages (SWA) levels for each food category: The SWA is calculated using the sodium levels of the products within each category weighted by their volume market share in kilograms (kg). To meet a SWA level, manufacturers would adjust the sodium levels in all their products within the category, so that the SWA for the company's products is equal to, or less than, the SWA level set for the category.
Option 3 - Combined Sales Weighted Average (SWA) and Maximum levels approach: This option is a combination of the two approaches listed above. Maximum levels could potentially be set at a higher level than the maximums proposed in 2010 and SWA levels would have to be set at a lower level than the 2010 proposed maximums.
A total of 24 responses were received from individual food manufacturers, food industry trade associations (including the restaurant and food service sector), academic experts and health-focused organizations (including one response from a provincial ministry of health). This summary presents the results from the consultation.
Summary of Feedback Received
Impacts of each approach on reaching the interim and long term sodium intake reduction goals and on aspects pertaining to high and low sodium consumers, informed-choice and taste adaptation to lower sodium foods
The responses were polarized by sector, with the academic and health organizations generally favouring the use of maximum levels only, while the food industry favouring SWA levels.
The academic and health organizations preferred the use of maximum levels to reach the interim goal of reducing the average population intake to 2300 mg sodium per day by 2016. It was stated that maximum levels would remove high sodium products from the marketplace, thus allowing taste adaptation to lower sodium foods. This approach was also felt to be easier to understand and simpler to implement. Some stakeholders indicated that setting maximum levels as well as SWA levels would result in all foods in the category shifting down in their sodium content. It was also stated that the interim goal is only a reference point for gauging progress towards reaching the ultimate goal slated by the Sodium Working Group (SWG)Footnote 1.
With regard to the impact on high and low sodium consumers, stakeholders from the academic and the health-focused sectors indicated that maximum levels would have the greatest effect on high sodium consumers, but none of the options are likely to have a significant impact on low sodium consumers, who probably already consume few processed foods. On the other hand, it was indicated that option 2 would allow marketing of higher sodium foods, therefore enabling some population groups to maintain higher sodium intakes. It was proposed that both SWA and maximum levels could be utilized should modeling show that the use of SWA levels would be more effective on reaching the population health objectives. In addition, it was indicated that maximum levels are preferred, but it is more important that if both Options 1 and 2 have the potential to reduce sodium intakes, the one that manufacturers perceive more feasible should receive strong consideration.
Industry stakeholders generally indicated a preference for SWA levels because this option provides the ability to offer a broader choice of low and high sodium content products to consumers. It was also indicated that SWA levels would allow manufacturers to focus their sodium reduction efforts on the most frequently consumed foods. On a population basis, decreased sodium intake is a function of both sodium content and the volume of a particular food sold, thus small changes in the sodium content in foods with high sales volume, can have a significant impact on overall intakes. It was also indicated that SWA levels would allow reformulation that would be acceptable to consumers and it would provide more flexibility for industry to focus on foods with high sales volume, thus allowing for taste adaptation.
One industry response acknowledged that maximum levels would have the greatest effect on the upper tail of the sodium intake distribution curve, but stated that this would encourage the production of products at or just below the maximum level.
Should different options be used depending on the food category and on which basis (i.e. use an approach similar to the United Kingdom model with SWA, maximums or both depending on the food product category)
Opinions were divergent with some stakeholders from the health and the academic sectors indicating that there is no justification for using different approaches for different food categories. On the other side, a blend of stakeholders indicated that different options can be used since the feasibility of lowering sodium differs from category to category and each sector is best able to provide a rationale and criteria for the best approach to use for its particular food category. Some stakeholders indicated that maximum levels should be applied for categories with a narrow distribution of sodium levels, while for those that have a wide range of sodium, SWA levels would be more appropriate.
Stakeholders' Recommendations for Monitoring and Evaluating Progress
In general, stakeholders from the health sector indicated that maximum levels (Option 1) would be easier to administer and monitor, and would allow a more straightforward and transparent monitoring process which would add to the credibility of the sodium reduction process. It was noted that the downside of monitoring outcomes of Option 1 is that it would provide little information on how the sodium range in foods is changing over time. It was proposed that a truly informed evaluation would need both sales volume data and sodium content data. Stakeholders pointed out that products' market share data is proprietary information and because of the cost associated with obtaining market share data it would be difficult to monitor the outcomes from SWA levels (Option 2) from an external standpoint. Stakeholders also noted that Option 2 is not conducive to transparent and accountable monitoring and evaluation.
Some academia and health organization stakeholders noted that the problem with monitoring any of the options by external parties is the lack of a public comprehensive brand-specific nutrient database and the cost of valid up-to-date sales data. They stated that an on-line evergreen database is needed for capturing up-to-date food label data submitted by food manufacturers. It was proposed that, if necessary, regulations should be enacted to make this reporting mandatory or that sodium limits for particular common food products should be regulated. One stakeholder indicated that a food monitoring program must also evaluate changes in other levels of nutrients and serving sizes.
Stakeholders from trade associations indicated that regardless of the option chosen, consultation with industry would be essential to deal with issues such as how to access real-time sales and nutrition data, and how to establish a standardized reporting system. One stakeholder from a trade association indicated that the application of a common formula, developed in cooperation with industry, for reporting, scoring, and auditing sales volume and sodium levels on a regular basis, would be necessary. A trade association stakeholder indicated that the first priority needs to be publication of all of the reduction levels, after which government and industry can then develop an appropriate monitoring plan.
Relative impact of each option on large companies vis-à-vis: resource allocation; capacity to meet the sodium reduction levels within the timelines; and impact on reformulation programs to improve nutrition profiles of food products
The use of SWA levels appealed to industry stakeholders as it would allow greater flexibility to industry in deciding which products need to be reformulated. Costly reformulations and sales impact could be minimized and companies would have the flexibility to choose the product lines most amenable to sodium reduction and to prioritize internal resource allocation. It was felt that resource allocation would be extreme should a maximum only approach be set since all products currently above the maximum level would need to be reformulated. This may impact consumer preference and acceptance, and food safety may be compromised. Another industry stakeholder stated that significant resource allocations would be required to meet sodium reduction levels, citing costs for updating label information and to reformulate each product. With the number of reformulations required under Option 1, manufacturers indicated that it would not be possible to meet all maximum levels by 2016. It was stated that option 2 would allow SWA sodium levels to be reached by 2016. A food manufacturer stated that resources needed to be allocated to finding appropriate salt substitutes and conducting required research and development. Also, it was suggested that the approval process, time required for reformulation, shelf-life testing, and texture analysis make it difficult to meet the timelines. A food industry stakeholder pointed out that U.S. suppliers might be unwilling to change recipes for ingredients used in Canadian products or for products destined for sale in Canada.
Relative impact of each option on small and medium sized companies vis-à-vis: resource allocation; capacity to meet the sodium reduction levels within the timelines; and impact on reformulation programs to improve nutrition profiles of food products
There was no consensus within sectors on this issue. A blend of stakeholders stated that the impacts are similar regardless of the company size. One stakeholder from the health organization sector speculated that resources required for small manufacturing operations may be minimal if they are already required to provide Nutrition Facts on their labels and that small companies might like maximum levels since they are easier to understand. On the other hand, a blend of stakeholders indicated that the magnitude of the relative impact of the options would be greater for small and medium sized companies based on whether or not in-house expertise or designated research and development programs exist. It was stated clearly that for small and medium sized companies, the impact on resource allocation, capacity to meet reduction levels and reformulation of products will, in relative terms, be much more significant and test their ability to respond to expectations.
Potential consumer confidence issues that may arise from using a SWA approach, thereby allowing some higher sodium products to likely remain in the marketplace
Responses to this question were polarized, by sector. Stakeholders from the health and academic sector stated that since some high sodium foods will remain on the market with Option 2, this will clearly affect consumer confidence. Some of the statements made include: consumers might be taken aback by high sodium foods if they perceive that government is supposed to be dealing with the issue; the fact that higher sodium products still remain on the shelf should be enough to dismiss SWA levels; and that it would appear as though Health Canada has designed a system that "engineers-in" loopholes for manufacturers. Health Canada might be accused of not doing enough to protect the health of Canadians and the accusation of "giving in to industry" and "hiding the real data" might be made. Industry stakeholders acknowledged that setting SWA levels might result in potential consumer confidence issues as it would allow high sodium products to remain on the market, however it was indicated that an education program is necessary to deal with this issue. They added that timely reporting on sodium reduction efforts would also build consumer confidence. Food manufacturers stated that higher sodium products will also remain on the market with Options 1 and 3, particularly when maximum levels are not achievable or if consumer confidence will be eroded.
In addition to comments on the use of maximum levels and SWA levels, some additional recommendations were made by individual stakeholders including:
- Given the concerns that sodium reduction is related to food safety, reports of adverse effects related to food safety resulting from products with reduced sodium levels should be part of monitoring.
- Further assessment of international processes and results should be conducted to inform the Canadian deliberations. Further consultations with industry are needed once a methodology is chosen.
- Health Canada is urged to solicit further input from individual companies that understand consumer behaviour and the food market place.
There was no clear consensus amongst sectors and stakeholders on which approach should be taken. Taking into consideration the feedback received, Heath Canada decided to use a combined approach (option 3). Health Canada believes this approach will achieve the best impact at a population intake level, encourage the reformulation of higher sodium products within categories and allow companies the flexibility in prioritizing the products to be reformulated. More information on the 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.
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