carbohydrates, protein, and fiber) available in writing upon request. Given the challenges of labeling foods consistently across the entire universe of restaurant/foodservice operations, the Patient Protection and Affordable Care Act did not require smaller operations to use such labeling. However, voluntary labeling for smaller restaurant/foodservice operations would also be useful to consumers.
One potential obstacle to making nutrition labeling, and specifically sodium labeling, possible for all restaurant/foodservice establishments is a nutrition labeling exemption for products distributed only to restaurant/foodservice operations. Requiring nutrition information on foodservice products would both help all restaurants in providing sodium information to consumers and help establishments monitor and lower the sodium content of their menu offerings.
Nutrient-related claims are another potential aspect of restaurant/foodservice labeling that is worthy of consideration. The Nutrition Labeling and Education Act stipulates that the rules for nutrient content and health claims are germane to “labeling,” and menus are characteristically considered to be labeling. As described later in this chapter in the context of providing incentives to the food industry, there are options by which provisions for sodium claims could be extended to restaurant/foodservice operations and thus provide some additional information to all consumers at the point of purchase.
Under current regulations, raw meat and poultry products are exempt from nutrition labeling even when packaged for retail sale (see Chapter 7). However, such products do contain sodium enhancement solutions and therefore can be a source of sodium in the diet. This is also the case for seafood, which is subject to the use of sodium enhancement solutions as well and for which nutrition labeling is voluntary on the part of the producer. While the labeling of such non-uniform products is challenging in the same way that labeling fresh produce is challenging, it would be worthwhile to explore approaches to the use of labeling that would make the presence of sodium known to the consumer.
While the Nutrition Labeling and Education Act of 1990 was intended to help consumers compare and select foods that lead to healthful diets, its focus also included the food industry. The aspects of the act that relate to standards for allowing claims on the labels of packaged foods about the nutritional content of the product were viewed as offering incentives to