ARCHIVED - Initial Stakeholder Feedback on Draft Proposed Sodium Targets for Foods
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Summary of Food Industry Meetings November 24 to December 2, 2009.
Bureau of Nutritional Sciences
Food Directorate, Health Products and Food Branch
Table of Contents
- 1. Executive summary
- 2. Introduction
- 3. Background and Objectives
- 4. The Approach
- 5. Details of Input Received
- 5.1. Sodium reduction
- 5.2. Sodium reduction tools
- 5.3. Setting targets
- 5.4. Challenges
- 5.5. Sector-specific comments
- 6. Conclusions and Next Steps
- 7. Appendix: Session Agenda
1. Executive Summary
This Executive Summary provides a brief overview of initial stakeholder comments and questions related to the draft proposed targets for sodium content in Canadian food, presented to Industry in November and December 2009. Eight meetings were held with industry, each one devoted to a specific food sector. A more detailed report follows this summary. The comments discussed in this report reflect those of participating food industry stakeholders and do not necessarily represent the views of all stakeholders.
1.1. The Process
In November and December 2009, Health Canada invited representatives of the food industry to attend meetings regarding draft proposed targets for sodium content in specific food products. Approximately 157 attended and heard information about the draft proposed sodium targets and provided initial feedback. All were invited to provide written submissions detailing their comments and suggestions.
1.2. Reducing Sodium
Food industry stakeholders agreed on the value to public health of reducing the overall amount of sodium consumed by Canadians. None of the participants questioned the value of this public health goal, nor was any opposition voiced to the overall goal of reducing average Canadian consumption of sodium from approximately 3400 milligrams per day to 2300 milligrams per day by 2016.
It is widely agreed that Canadians are habituated to high levels of sodium in their foods, and that gradual reductions in salt are needed to train the palates of consumers to want and expect less sodium.
Industry participants noted that a significant reduction in sodium will require costly research and reformulation.
Public education is considered extremely important. Participants stressed that consumers need to recognize the health value of reducing their sodium consumption. To date, the demand for lower sodium alternatives has been low. Consumer demand for lower sodium alternatives will provide a powerful incentive for industry to innovate.
Targets are considered a useful tool for sodium reduction. Industry participants generally responded positively to the idea of a goal for overall daily intake toward which Canadians as a whole would strive, as well as product-specific targets for industry to aim for that would lead to that goal.
Industry stakeholders frequently pointed out the importance and value of providing manufacturers and retailers with an incentive to reduce sodium in the form of a marketing benefit.
1.3. Setting targets
Throughout the meetings participants appeared to generally accept the idea that Canada can adapt and build upon the sodium reduction work already begun by the UK Food Standards Agency (UK FSA).
However, the participants raised a number of questions about the way in which Health Canada will adapt the specific UK Food Standards Agency targets to the Canadian context.
The most commonly-raised concern is the use of UK Food Standards Agency product averages as the proposed Canadian maximum level of sodium for specific food categories. (The UK Food Standards Agency set averages for some products categories, allowing for lower and higher sodium products within the category. In contrast, Health Canadas draft proposed sodium targets for these products categories sometimes use the UK FSA average as a maximum sodium amount, below which all products in the category should fall.)
A second concern relates to Health Canadas proposal to set more aggressive sodium reduction targets in those product classes where most Canadian products already meet the UK Food Standards Agency criteria. To some stakeholders this would penalize sectors who have already made progress on sodium reduction.
Industry expressed a considerable amount of interest in the way products will be categorized or grouped within the target plan. Industry expressed interest in engaging with Health Canada to review the way foods are categorized.
Stakeholders identified a number of sodium reduction challenges.
It is clear that the magnitude of reductions described in the draft proposed targets for sodium reduction is very significant to many industry stakeholders.
Sodium (usually in the form of salt) plays an important functional role in the manufacture and preservation of a number of food products. This role poses an especially large challenge for manufacturers trying to reduce sodium, even if consumer palates can be gradually trained to accept a less salty flavour in familiar foods.
According to stakeholders, currently known alternatives to salt/sodium do not offer a good solution to the challenge of sodium reduction. This is due to taste, function, cost and the potential for unforeseen food safety or other health consequences.
An important concern raised by stakeholders is how sodium reductions can proceed on a voluntary basis without creating market imbalances caused when one product reduces sodium while a competing product does not.
Some stakeholders expressed concerns that products imported from countries with less stringent sodium standards would not be modified to meet Canadian targets and thereby gain a competitive advantage over domestic products.
Canadian food exporters and importers would welcome some degree of international harmonization in sodium standards.
Moving forward with draft proposed sodium targets for a subset of foods (Group I) poses a potential challenge for manufacturers whose products in Group I may compete with products planned for Group II, whose targets wont be published until up to several months later.
Some manufacturers of prepared meals expressed concern that they will be placed at a competitive disadvantage if they must reduce sodium and restaurants do not.
Manufacturers who produce products using inputs that they do not produce themselves will not be able to reduce sodium directly but must rely on their suppliers to reformulate as well.
Stakeholders expressed concerns that a change of the current reference standard (Daily Value) for sodium (2400 mg per day) to the Adequate Intake (AI) for sodium (1500 mg per day) on the Nutrition Facts Table could create the false impression of products having increased sodium content, and discourage sodium-conscious consumers from purchasing products.
This report provides an overview of stakeholder comments and questions heard at meetings held by Health Canada to present draft proposed targets for sodium content in foods in November and December 2009. Eight meetings were held with industry, each one devoted to a specific food sector. The comments discussed in this report reflect those of participating stakeholders and do not necessarily represent the views of all stakeholders.
3. Background and Objectives
As part of its commitment to reducing the amount of sodium in Canadian diets, Health Canada plans to publish voluntary targets in 2010 that define the maximum amount of sodium that should be contained in specific types of processed foods. These target levels will help Canadians reduce their intake of sodium from an average of 3400 mg per day to 2300 mg per day by 2016. Health Canadas adopted approach draws heavily upon the experience of the UK Food Standards Agency, which began efforts to reduce dietary sodium in 2003. The Food Standards Agency approach has been adapted to take into account the amount of sodium currently in Canadian foods and the reality of the Canadian marketplace.
To move forward in a timely way with the development of targets, Health Canada selected those food groups from the processed food market that contribute the most sodium to the diet. These food categories are identified as Group I and all remaining categories, which will be dealt with subsequently, are Group II. The food groups comprising Group I include:
- Bakery products
- Combined dishes
- Fats and Oils
- Fish and Seafood
- Processed meats
During meetings in November and December, 2009, Health Canada sought industry feedback and input on the Departments draft proposed sodium targets. Discussion sessions were held with stakeholders, however, it was expected that they would provide their responses to the targets proposed for their sector to Health Canada mainly in subsequent written comments.
4. The Approach
In November and December 2009, Health Canada invited representatives of the food industry to attend meetings regarding the development of draft proposed targets for sodium content in specific food products. These sessions were intended primarily as a means to introduce and discuss the draft proposed targets and their rationale. Participants were encouraged to provide detailed written feedback. A questionnaire was distributed to the food industry following the sessions to assist them in providing the most useful feedback. (The feedback emerging from those questionnaires will be summarized in a separate report.)
Separate sessions were held for each of the major food sectors included in Group I. In the course of each session, participants were presented with a brief background on Health Canadas strategy to reduce dietary sodium, information on the draft proposed sodium targets that Health Canada has developed for each food category, and the underlying rationale used to set those targets. The sessions were held in Ottawa and Toronto. Participants were also offered the opportunity to participate by conference call. Approximately 157 stakeholders participated in the sessions.
The schedule of the sessions is provided in the following table.
|Session||Food Sector||Date (2009)||Location||Participants*|
|2||Fats, Oils and Sauces||November 26||Toronto||12|
|3||Fish and Seafood||November 26||Toronto||9|
|4||Snacks , Cereals||November 27||Toronto||25|
|5||Bakery products||November 27||Toronto||18|
|6||Combined dishes||December 1||Ottawa||16|
|8||Processed meats||December 2||Ottawa||26|
|* Approximate. Some individuals attended more than one session.|
Each session lasted approximately three hours and followed the same structure:
- Overview presentation from Health Canada on sodium reduction initiatives.
- Technical presentation from Health Canada on how the draft proposed sodium targets were determined, and for which foods. This included examples relevant to each sector.
- Comments and questions from stakeholders regarding the overall approach and specific targets.
- Discussion of next steps.
A sample agenda is appended to this report. The presentation decks used during the sessions are available upon request.
5. Details of Input Received
This section of the report details the specific comments and feedback received from industry stakeholders during the meetings with regard to the draft proposed sodium targets.
5.1. Sodium Reduction
Food industry stakeholders appeared to accept the value to public health of reducing the overall amount of sodium consumed by Canadians. No participant questioned the value of this public health goal, nor was there any opposition voiced to the overall interim goal of reducing average Canadian consumption from approximately 3400 milligrams per day to 2300 milligrams per day by 2016.
Furthermore, notwithstanding the concerns some expressed about the process (discussed later), stakeholders were generally willing to accept that the food industry itself should take the initiative in reducing sodium in the products sold to Canadians. None of the food sectors argued that it should be exempt from the responsibility to pursue lower levels of sodium in their food products. In summary, food industry stakeholders engaged constructively in the discussion process and signaled their willingness to work with Health Canada toward the overall goal of sodium reduction.
It was widely agreed that Canadians are habituated to high levels of sodium in their foods, and that sudden large sodium reductions could create taste changes so drastic as to drive consumers to other products and other food types. Instead, gradual reductions in salt are needed to train the palates of consumers to want and expect less sodium. Thus, it is widely understood that sodium should be reduced slowly over time. However, this approach creates a tension between the need for gradual reductions and the financial imperative within industry to limit the number of reformulations and package redesigns they must undertake for each product during the transition period.
Even setting aside labelling issues, industry noted that a significant reduction in sodium will require research and reformulation and, for example, that it is not simply a matter of reducing the sodium by 5% every year. Significant reductions in sodium within some products could also cause fundamental changes to those products.
There is considerable interest in what the interim targets will be for sodium reduction. Stakeholders made two related points concerning interim targets, which seem to depend on product type and reformulation work done to date. Some stakeholders pointed out that early progress will be slow as research is undertaken and reformulations are tested. Thus, initial progress may seem to lag. Others explained that removing 5% to 10% of the sodium used for flavouring in products could be relatively simple during the early years, but larger reductions will require much more work. Therefore, progress in some products may be delayed, while in others, progress may appear to lag after an initial few years of success. In both cases, industry stakeholders signaled that progress may be uneven and that interim targets should take this fact into account.
There was some concern about the fact that an overall sodium goal may be set by the Sodium Working Group, extending beyond 2016 and falling below 2300 milligrams per day. This concern relates to the fact, noted later, that the reductions required to meet the 2016 recommended goal are already considered quite significant by many in the food industry. To set additional targets now, before the initial work has begun, was identified by some stakeholders as potentially discouraging. Also, it would not allow much flexibility in determining the timetable or mechanisms for reaching new targets, nor would it allow for use of lessons learned from working toward the first set of targets. Nonetheless, few seem to doubt that further reductions after 2016 would be valuable from a health perspective.
5.2. Sodium Reduction Tools
In parallel to the discussion about sodium targets for foods, many industry stakeholders also raised the issue of public education. They stressed that consumer demand for lower sodium alternatives which from their perspective, for some foods has been low to date will be critical to success in sodium reduction and also provide a powerful incentive for industry to innovate. They saw successful sodium reduction as requiring a partnership between consumers and the food industry in which consumers demand lower sodium products from industry and subsequently purchase those products. Without public education, some stakeholders suggested that consumers may compensate for the lower sodium in foods by changing their dietary choices, or adding additional salt at the table.
Sodium targets for foods are considered a useful tool for achieving sodium reduction to reach an overall intake goal toward which Canada as whole would strive. Food category-specific targets would provide industry with clear markers to aim for. Stakeholders were told that the draft proposed food category-specific targets were set based on modeling of what is required to bring the average sodium intake of Canadians to 2300 milligrams per day by 2016.
Industry stakeholders frequently pointed out the importance and value of providing manufacturers and retailers with an incentive to reduce sodium in the form of a marketing benefit. They suggested a number of alternatives which go beyond the current authorization to claim a sodium reduction of at least 25% over a reference product. These suggestions included a lower reduction threshold or a longer period during which a reduction may be highlighted on the product label. They also expressed interest in a logo or label which identifies that the manufacturer has pledged to reduce their products sodium content by the proposed amounts over the course of the transition period and that the products bearing the logo are undergoing gradual changes. This approach might reduce the need for multiple label changes and also address the fact that, because all products will be reducing their sodium content, it will be harder to find a reference food against which to make reduced or lower sodium comparison claims. The provision of a marketing benefit is expected not only to provide some incentive, but also to go some distance in addressing the potential penalization of early sodium reducers, discussed later under Challenges. Meeting participants agreed that forming a group to work with Health Canada to develop options for a labeling initiative would be desirable.
5.3. Setting targets
Industry stakeholders generally accepted the idea that Canada can adapt and build upon the sodium reduction work already begun by the UK Food Standards Agency (UK FSA). The overall approach of the UK FSA setting individual targets for specific groups of like products made sense to most stakeholders. Ideally, some stakeholders, especially exporters and importers, would prefer that Canada align to the sodium reduction targets pursued in the United States (New York City approach). This reflects the critical importance of the United States both as a market and a source of inputs to Canadian food manufacturers. It also reflects the fact that a variety of market realities such as required shelf life and food definitions are different between the British and Canadian markets. However, the UK FSA model is generally considered acceptable.
Stakeholders raised a number of questions about the way in which Health Canada will adapt the specific UK FSA targets to the Canadian context.
The most commonly-raised concern is, in some cases, the use of UK FSA product averages as the proposed Canadian maximums. In other words, where the UK FSA system set a target for the weighted average of a product sector (with individual products falling either above or below the average), some targets proposed by Health Canada set the UK FSA average as the Canadian maximum under which all Canadian products of that type should fall. Some stakeholders objected to this approach with the rationale that it would force large reductions in sodium on all products, and does not take into account such things as varieties of flavours and ingredient combinations or that it might not be feasible for some products in the category.
A second concern relates to Health Canadas proposal to set more aggressive sodium reduction targets in those product classes where most Canadian products already meet the UK FSA criteria. To some stakeholders especially those who have been actively reducing sodium in their products for years this approach would penalize sectors who have already made progress on sodium reduction. Industry expressed the need for prior sodium reductions to be taken into consideration when the sodium targets are set for their respective sectors.
Industry expressed a considerable amount of interest in the way products will be categorized or grouped for target setting. This interest is often related to specific product characteristics which require differing levels of salt (For example, meat processors want separate categories for ready to eat products as opposed to raw products). Industry also expressed interest in further engaging with Health Canada in discussions to create logical and cohesive categories of products which can reasonably be given the same target. During the meetings, it was indicated that the categories should be limited to the smallest number possible in order to avoid excessive complexity. A number of very specific concerns about categorization are noted in the later sector-specific sections of this report.
One important question raised by industry concerns the unit size of food upon which the targets are to be based. While the Nutrition Facts Table (NFT) currently provides information based on the serving size, this serving size varies between similar products making it difficult to compare their sodium content. A standard unit of measure (of perhaps 100 grams) is preferred by many stakeholders as it would provide comparability. However, this does pose a challenge for products with wide variations in density soups for example where 100 grams could represent quite different amounts, in terms of volume, of comparable or competing products. This difference could put a denser product at a competitive disadvantage.
Overall, stakeholders provided considerable input on the draft specific targets proposed by Health Canada, much of which is captured in later sections of this report. Much more detail is, however, anticipated in the written submissions expected before March 31, 2010.
During the meetings, the food industry noted a number of challenges they have so far identified in reaching the draft proposed targets for their own products, as well as in reaching the overall sodium intake goal of 2300 milligrams per day by 2016. Participants were strongly encouraged to provide Health Canada with additional information and evidence in their written submissions regarding these challenges and their proposed alternatives or solutions.
5.4.1. Scale of change
The magnitude of reductions described in the draft proposed targets for sodium reduction were identified as very significant to many stakeholders. While some products already meet or nearly meet the draft proposed targets, some entire categories would require a sodium reduction of more than 50% in order to meet them. Stakeholders clearly indicated that these larger reductions will pose a serious challenge to manufacturers and that some of the proposed targets may be very difficult to achieve.
Sodium (usually in the form of salt) plays an important functional role in the manufacture and preservation of a number of food products, and this role poses an important challenge for manufacturers even if consumers can be weaned off their taste for salt. Important examples include the role that salt plays in the workability of bread dough, the formation of a meat batter in wieners, and the preservation of pickles and deli meats. Some manufacturers fear that these products cannot be made or be made safely with significantly lower levels of salt. Thus, targets which set the amount of sodium below the functional requirements may eliminate some popular products from the marketplace or lead to food safety concerns.
5.4.3. Market Share
An important concern raised by stakeholders is how sodium reductions can proceed on a voluntary basis without creating market imbalances caused when one product reduces sodium while a competing product does not. Manufacturers expressed the concern of being unfairly penalized for leading sodium reduction in a product category, by losing customers to high sodium competitors. This concern is especially relevant if the manufacturer cannot obtain a countervailing benefit such as the right to claim a sodium reduction on their packaging when the product does not meet the 25% reduction threshold. Such labelling would help explain to consumers why they are noticing a change in flavour and the health benefit associated with that change. In highly competitive sectors, the possibility of lost market share is of serious concern to industry.
5.4.4. Imports and Harmonization
Further to the issue of fairness is the question of how imports will be treated in the sodium reduction program. Stakeholders frequently raised questions about the extent to which imports have been taken into account in setting targets and how closely they would be monitored for compliance. The concern is that products imported from countries with less stringent sodium standards would not be modified to meet Canadian targets and thereby gain a competitive advantage over domestic products. A closely related issue concerns the degree to which Canadian food exporters and importers will have to meet different sodium standards in different countries. It would be far simpler from a manufacturing perspective to avoid different product formulations for different countries, especially if the primary difference relates only to sodium content. Industry stakeholders expressed that they would welcome some degree of international harmonization.
Many manufacturers produce products with inputs that they do not manufacture themselves. One example would be a ham lunch kit made by a meat processor which contains crackers and cheese from other suppliers. Another example is a frozen pizza which includes pepperoni purchased from a meat processor. In these cases, the manufacturer of the final product will not be able to reduce sodium directly but must rely on their suppliers to reformulate as well. Ideally, market pressure would convince the input manufacturers to comply but this is nonetheless somewhat outside the control of the manufacturer, especially when the inputs are imported from larger markets.
According to stakeholders, alternatives to salt do not offer a good solution to the challenge of sodium reduction. This is for four key reasons. First, the existing alternatives (such as Potassium Chloride or KCl) do not have the same flavour profile as salt. Second, the existing alternatives do not mimic the functional role of salt. Third, alternatives (such as KCl) are far more expensive than salt. Finally, there was concern that relatively unknown chemicals used as alternatives to salt may, in the long run, prove to be a poor public health choice compared to the salt they replaced.
Nonetheless, industry did note that new substances and additives may play a role in sodium reduction and they encouraged Health Canada to make the approval of these substances a priority.
5.4.7. Groups I and II
Time limitations and reasons of feasibility led Health Canada to separate the food supply into two Groups when developing draft proposed sodium targets. Industry noted that moving forward with draft proposed sodium targets for a subset of foods (Group I) would pose a potential challenge for manufacturers whose products in Group I may compete with products planned for Group II. An example is the inclusion of canned soups in Group I which compete with dried soups planned for inclusion in Group II. This will only become a challenge if the timeline for Group II is substantially different than that set for Group I, thereby creating an imbalance.
5.4.8. Updating Sodiums Daily Value Reference Standard
Participants noted that there is a potential to create consumer confusion if the Nutrition Facts Table (NFT) is modified in the future so that the Daily Value (DV) for sodium reflects the Adequate Intake (AI) value of 1500 milligrams per day rather than the current DV for sodium of 2400 mg per day which is closer to the Tolerable Upper Intake Level (UL) than the AI. This was especially a concern amongst participants if this change were implemented during the transition period planned for meeting the sodium reduction targets. This change may also create the false impression among consumers that the sodium content of foods is actually increasing, because the percentage of AI will be significantly higher compared to the current DV. Manufacturers expressed concern that consumers would thereby be discouraged from purchasing products, especially if consumer education efforts are successful in raising public awareness concerning sodium.
5.4.9. Food service
For many manufacturers of prepared meals, the food service industry is considered as a major competitor and vice versa. As they strive to create products that rival restaurant food, these manufacturers expressed their concerns that they will be placed at a competitive disadvantage if they must reduce sodium while restaurants do not. Although it is understood that achieving sodium reductions in food service is a complex task, they nonetheless sought consideration of setting sodium reduction targets for the food service industry at the same time.
5.5. Sector-Specific Comments
The foregoing sections have outlined the comments that were made generally by participants in all meetings. Representatives of each sector also made specific comments about their challenges, of which a synopsis in bullet form is presented. Food stakeholders were strongly encouraged to provide Health Canada with additional evidence to support their concerns in subsequent written submissions.
Industry stakeholders indicated that:
- Bread is a large source of sodium due to its widespread use. A unique and distinct solution may therefore be required to reflect breads central role in the diet, the realities of Canadian geography, required shelf life, and the very wide diversity in product offerings. Although no specific suggestions were made for alternative approaches for bread, the implication was that the standard approach which would work for most product categories may have to be more specific, nuanced or more flexible for bread.
- Bread should not be painted as a poor food choice, because it is considered to be an important and healthy food.
- Breads with salt toppings should be given their own category.
- While the sector might reach an overall average of perhaps 430 milligrams per serving of bread, it would be almost impossible to bring all products below a maximum of 430 milligrams.
- Industry recommended that the persistence of US-based information about bread in the Canadian Nutrient File be remedied as a priority.
Industry stakeholders indicated that:
- The proposed draft targets for cheese slices were considered by industry as far too low and also needing to be subdivided to reflect the fact that some slices are refrigerated while some are shelf stable.
- Cheeses such as Brie and Camembert have a shelf life of less than six weeks, The proposed sodium levels would reduce that to just a few weeks at most.
- Aged cheeses which would be sold later in the transition period are being made now. Planned reductions would therefore lag significantly for those products.
- Cottage cheese relies heavily on salt for its identity. Reduced sodium cottage cheese tastes very different from what people are used to with cottage cheese.
5.5.3. Processed meat
Industry stakeholders indicated that:
- Reduced sodium will shorten the shelf life of processed meats, which would make them less attractive to retailers.
- Some traditional products such as dry cured sausages were recommended to be exempt from sodium reduction targets or they will cease to be manufactured.
- Progress on sodium reduction would need to be reported separately for domestic and imported meat products, so as to fairly reflect the efforts of Canadian manufacturers.
- The product categorization in the sodium reduction targets would need to reflect the fact that raw and ready to eat products are very different in terms of sodium content, as sold, for reasons of food safety and because of the effect of cooking on water content and hence sodium concentration.
Industry stakeholders indicated that:
- Dried soups are a major competitor to canned soups and should have simultaneous and comparable targets.
- Broth and bouillon are used as soups but also as ingredients in recipes. This dichotomy should be dealt with in the targets.
- Some soup manufacturers have already made significant reductions in sodium.
- Condensed and ready to serve soups would need to be considered for different targets because they are not used in the same way by the consumer. Condensed soups, for example, are frequently used as meal ingredients while ready to serve soups are rarely used this way.
- Soups of differing densities may be hard to compare if a standard weight measure is used, such as 100 grams, because the corresponding servings will be different in volume.
During the discussions, participants indicated that:
- Refrigerated salad dressings should have different targets than shelf-stable dressings.
- Any broad communication strategy developed for industry to signal participation in the sodium reduction strategy (e.g. a labeling initiative) should not be dependent on a central role for the HealthCheck program, because many producers cannot afford to participate in that program.
- Pretzels would need to be considered as a separate snack category.
- Shrimp often include sodium phosphate for water retention.
- Canned and frozen fish are different from each other in terms of sodium content and would require separate targets.
6. Conclusions and Next Steps
The food industry participants agreed to consider the proposals as soon as possible and prepare comments. Health Canada invited them to maintain a dialogue with the Department during their deliberations so that questions can be answered and concerns discussed before conclusions are reached. Participants were encouraged to meet with Health Canada officials in person or by teleconference.
Written comments were requested by March 31, 2010. Health Canada indicated they would review this input, revise or adjust the proposed targets if necessary, distribute the revised targets back to industry for their final comments by the end of April, and then submit the final proposed targets to the Sodium Working Group for their endorsement. The intention is to have Group I targets published around June of 2010.
7. Appendix: Session Agenda
Standard Agenda Food Industry Meetings on Sodium Reduction Targets with the Food Directorate, Health Canada Several dates in November and December 2009
|1. Introductions Roundtable||10 min|
|2. Welcoming remarks.
3. Review of September Industry Stakeholder Outreach meetings. What we heard.
4. Background Sodium Working Group health goals for sodium intakes of Canadians, and for Canadian approach to reducing sodium in foods.
|5. Criteria and rationale used to set targets.||15 min|
|6. Presentation of Canadian label data and proposed targets.||30 min|
| 7. Feedback and Discussion on:
|8. Next steps:
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