FMI shares FDA’s public health goal of reducing sodium content in foods.  Many FMI members have made longstanding public commitments to reducing sodium, and have made significant progress in those efforts, long before FDA published its Phase I or draft Phase II targets.  As an overarching comment, FMI appreciates FDA’s statements in the draft guidance regarding the importance of gradual reductions in sodium, which continues to be a critical theme for sodium reduction in foods.  A gradual approach is necessary to maintain consumer acceptance and provide time for technology to develop and advance, while also taking into account the significant resources and time needed – typically between 1.5 and 3 years for a single product – for product reformulation.  In its notice, FDA states, “[o]ur goal is to further encourage gradual, efficient reduction of overall sodium content using effective and sustainable strategies that maintain other measures of nutritional quality.”  Further, FDA has indicated that the Phase II goals are “intended to balance the need for broad and gradual reductions in sodium and what is publicly known about technical and market constraints on sodium reduction and reformulation.”  The agency also recognizes the role of sodium in foods for microbial safety, stability, and various other functions.  FMI appreciates FDA’s thoughtful consideration of these important aspects, as they remain key factors in our ability to reduce sodium in foods.

 

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