The current provisions for nutrition labeling, related claims about sodium, and disclosure/disqualifying criteria for sodium on the labels of food products were established at a time when less was known about how consumers effectively interpret and use label information and about relevant technologies and potential unintended consequences related to reducing sodium levels in foods. Overall, the existing regulatory provisions would benefit from review and updating as appropriate in order to provide useful information to consumers and to enhance the food industry’s motivation to reformulate foods relative to sodium content. It is anticipated that such activities would be undertaken through notice-and-comment rulemaking in a timely fashion. USDA should move forward with proposed nutrition labeling regulations for single-ingredient, raw meat and poultry to ensure that the sodium content—as would be relevant in the case of meat and poultry enhanced with sodium solutions—is made known to consumers. Similarly, FDA should review its approach to seafood labeling. Further, given a 2005 report from the Institute of Medicine that identifies an AI for sodium—a reference value that had not been established at the time the current regulations for nutrition labeling were finalized—the AI should serve as the basis for the Daily Value for sodium, a component of the Nutrition Facts panel on foods. The AI, from the perspective of public health, provides a truer picture for the consumer of the contribution of the particular food in assembling a healthful diet and is preferable to use of the Tolerable Upper Intake Level (UL). To avoid unintended consequences and disincentives to the food industry given this recommendation, the basis for claims related to “low sodium” and “very low sodium” is worthy of review.

The Nutrition Labeling and Education Act established a framework for providing information about the nutrient content of packaged foods, but its provisions for nutrient-related food label claims were not specifically limited to packaged foods. However, in implementing the act, FDA limited its claims regulations to packaged foods. FDA should now undertake activities to provide for sodium content claims (e.g., low sodium, reduced sodium) and related health claims (e.g., “diets low in sodium are associated with a low prevalence of hypertension”) on menu items offered by restaurant/food-service operations that are sufficiently standardized for implementation to be practically accomplished. There will be a need for preliminary activities