Contains Nonbinding Recommendations 
 
 
 
Voluntary Sodium Reduction Goals: 
Target Mean and Upper Bound 
Concentrations for Sodium in 
Commercially Processed, Packaged, and 
Prepared Foods: Guidance for Industry 
 
 
 
You may submit electronic or written comments regarding this guidance at any time. Submit 
electronic comments to https://www/regulations.gov. Submit written comments on the 
guidance to the Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 
Fishers Lane, rm. 1061, Rockville, MD 20852. All comments should be identified with the 
docket number listed in the notice of availability that publishes in the Federal Register. 
 
For questions regarding this guidance, contact the Center for Food Safety and Applied 
Nutrition (CFSAN) at 240-402-1200. 
 
 
 
 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Food Safety and Applied Nutrition 
 
October 2021   
     
  Contains Nonbinding Recommendations 
 
Table of Contents 
 
 
 
I.  Introduction ....................................................................................................................... 3 
 
A:  Purpose and Scope ..................................................................................................................... 4 
B:  Overview .................................................................................................................................... 5 
C:  FDAs Approach to Voluntary Sodium Reduction in the Food Supply ..................................... 6 
D:  Intended Audience ..................................................................................................................... 7 
II.  Background ....................................................................................................................... 7 
A:  Sodium and Health ..................................................................................................................... 7 
B:  U.S. Sodium Intake and Recommendations ............................................................................... 8 
C:  Potential Public Health Impact of Sodium Reduction................................................................ 8 
D:  Other Initiatives with the Goal of Reducing the Sodium Content of Foods .............................. 8 
E:  Food Ingredient Regulation ........................................................................................................ 9 
III.  Discussion......................................................................................................................... 10 
A:  Foods and Food Categories ...................................................................................................... 11 
B:  Baseline Sodium Concentrations ............................................................................................. 11 
C:  Target Mean and Upper Bound Sodium Concentrations ......................................................... 12 
IV.  Appendix .......................................................................................................................... 14 
V.  References ........................................................................................................................ 20 
 
 
   
  2 
 
  Contains Nonbinding Recommendations 
 
Voluntary Sodium Reduction Goals: 
Target Mean and Upper Bound 
Concentrations for Sodium in 
Commercially Processed, Packaged, and 
Prepared Foods: Guidance for Industry 
 
 
This guidance represents the Food and Drug Administration's (FDA's) current thinking on this 
topic.  It does not create or confer any rights for or on any person and does not operate to bind 
FDA or the public.  You can use an alternative approach if the approach satisfies the 
requirements of the applicable statutes and regulations.  To discuss an alternative approach, 
contact the FDA staff responsible for this guidance as listed on the title page.  
 
 
 
I.  Introduction  
 
This guidance is intended to provide measurable voluntary short-term (2.5-year) goals for 
sodium content1 in commercially processed, packaged, and prepared foods2 to reduce excess 
population sodium intake, while recognizing and supporting the important roles sodium plays in 
food technology and food safety. 
 
Sodium is widely present in the American diet (most commonly, but not exclusively, as a result 
of eating or drinking foods to which sodium chloride, commonly referred to as salt, has been 
added).  More than 70 percent of total sodium intake is from sodium added during food 
manufacturing and commercial food preparation (Refs. 1, 2).  Average sodium intake in the U.S. 
is approximately 3,400 milligrams/day (mg/day) (Ref 3).  The Dietary Guidelines for Americans, 
2020-2025 (Dietary Guidelines) (Ref. 3) advises individuals 14 years and older to limit their 
consumption to 2,300 mg/day; this aligns with recommendations from the National Academies 
 
1 In this document, we refer primarily to sodium, a component of sodium chloride, commonly known as salt (21 
CFR 101.22(h)(4)).  Most, but not all, sodium is added to food in the form of salt, and we are interested in all 
sources of sodium added to foods.  The focus of this guidance is on foods to which sodium has been added, not 
those foods, such as milk, that contain only intrinsic sodium. 
2 Commercially processed, packaged, and prepared foods refers to processed, multiple-ingredient foods that have 
been packaged for direct sale to consumers, for use in food establishments including, but not limited to, restaurants, 
or for resale to other members of the food industry, as well as foods that are prepared by food establishments for 
direct consumption.  The guidance addresses certain conventional foods, and not dietary supplements. 
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  Contains Nonbinding Recommendations 
 
of Sciences, Engineering and Medicine (NASEM), which set the Chronic Disease Risk 
Reduction Intake (CDRR) for sodium at 2,300 mg/day3 for those 14 years and older (Ref. 4).     
 
The contents of this document do not have the force and effect of law and are not meant to bind 
the public in any way, unless specifically incorporated into a contract.  This document is 
intended only to provide clarity to the public regarding existing requirements under the law.  
FDA guidance documents, including this guidance, should be viewed only as recommendations, 
unless specific regulatory or statutory requirements are cited.  The use of the word should in 
FDA guidances means that something is suggested or recommended, but not required.  
   
A:  Purpose and Scope 
 
This guidance aims to help Americans reduce average sodium intake to 3,000 mg/day by 
encouraging food manufacturers, restaurants, and food service operations to gradually reduce 
sodium in foods over time.  Although we recognize that a reduction to 3,000 mg/day still would 
be higher than the recommended sodium limit of 2,300 mg/day, the 2.5-year 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 guidance provides 
short-term goals that include both a target mean concentration and an upper bound concentration 
of sodium for various specified categories of food.  The target mean sodium concentration is our 
goal for the food category as a whole rather than for every product in that category.  The upper 
bound concentration is our goal for the highest sodium concentration for any product in that food 
category. 
 
FDA recognizes the important role of sodium in food for microbial safety, stability, and other 
functions.  FDAs approach to establishing these voluntary, short-term goals is grounded in 
research, review, and expert consultation (Refs. 5-9).  The goals are intended to provide both 
FDA and the food industry with a common system for defining and measuring progress in 
reducing sodium.  The goals are intended to complement existing efforts by food manufacturers, 
restaurants, and food service operations to achieve sodium reduction. 
 
The voluntary sodium content goals in this guidance are intended to: 
 
  Support increased food choice for consumers seeking a diverse diet that is consistent with 
recommendations of the Dietary Guidelines by encouraging food reformulation and new 
product development for Americans; 
  Support the Dietary Guidelines, and NASEM CDRR recommendations of limiting 
sodium intake to 2,300 mg/day4 by encouraging sodium reduction over the short term to 
achieve an average intake of 3,000 mg/day; 
 
3 Above this level, sodium intake should be reduced in order to reduce the risk for hypertension and cardiovascular 
disease; lower levels are recommended for children younger than 14 years of age (Ref. 4). 
4 The Dietary Guidelines recommendation is for individuals aged 14 and older to limit intake of sodium to less than 
2,300 mg/day.  The CDRR level for individuals ages 14 years and older set by the NASEM 2019 Dietary Reference 
Intakes for sodium and potassium report is 2,300 mg of sodium per day (Ref. 4).  The recommendations for children 
younger than 14 years of age are the NASEM age- and sex-appropriate CDRRs.  
  4 
 
  Contains Nonbinding Recommendations 
 
  Provide uniform metrics (mg of sodium per 100 g of food) for voluntary sodium 
reduction for industry stakeholders; 
  Focus on the total amount of sodium in a given food as opposed to individual sodium-
containing ingredients; and   
  Support and extend industrys voluntary efforts to reduce sodium across the range of 
commercially processed, packaged, and prepared foods. 
 
The voluntary sodium content goals in this guidance are not intended to: 
 
  Recommend specific methods and technologies for sodium reduction; 
  Recommend how much of a sodium-containing ingredient, such as sodium chloride or 
sodium nitrite, should be used in a formulation (our recommendations focus instead on 
the total amount of sodium5 in a given food); 
  Focus on foods (e.g., milk) that contain only naturally occurring sodium; or   
  Address the sodium chloride or other sources of sodium that individuals add to their food 
at the table or through cooking.6   
 
B:  Overview 
 
This sodium reduction guidance is based on the following principles: 
 
  Reduction in sodium levels should progress gradually to allow time for product 
reformulation; 
  Population-level sodium intake reduction should progress at a pace such that consumer 
preferences and expectations for saltiness in foods adjust;7 
  Reduction in sodium levels should not lead to reformulation that negatively affects the 
nutritional quality of the foods by modifying other nutrient levels (e.g., by increasing 
added sugars or saturated fat content) and should take into account all Dietary Guidelines 
recommendations and FDA policies; 
  Population-level sodium intake reduction will involve ongoing voluntary efforts led by 
the food industry, in collaboration with FDA, our Federal partners, and other 
stakeholders;8 
  Goals should be expressed in ways that support ongoing efforts to track modifications to 
the sodium content of the food supply over time; 
  Successful sodium reduction is contingent upon broad participation by and distribution of 
impacts across the food industry; and 
 
5 We recognize that total sodium in a food may include some intrinsic sodium and that this contribution to the foods 
total sodium does not represent deliberate introduction of a sodium-containing ingredient.  However, total sodium is 
the most practicable measure of the foods composition and is strongly correlated with the use of sodium-containing 
food ingredients in the foods that are the focus of this guidance. 
6 FDA supports public education efforts on how consumers can reduce sodium in their diet, including salt they add 
to their food. 
7 Consumer preferences and expectations for salty taste can adjust based on dietary changes (Ref. 8). 
8 This includes states, tribes, consumers, international governments, academic institutions, and other organizations 
as appropriate. 
  5 
 
  Contains Nonbinding Recommendations 
 
  Population-level sodium intake reduction can be advanced through both the 
categorization of the food supply based on relevant data and information (e.g., ingredient 
similarity, technical effects in the food, role in food safety, and range of sodium 
concentrations in marketed products) and the use of voluntary objectives.  
 
C:  FDAs Approach to Voluntary Sodium Reduction in the Food Supply 
 
Multiple public health efforts have attempted to reduce sodium intake over the past 40 years 
(Ref. 10).  However, these efforts, which mainly included education initiatives, have generally 
not been successful.  The Institute of Medicine (IOM, now the Health and Medicine Division of 
NASEM) thus concluded that without an overall reduction of the level of sodium in the food 
supply, consumers will not be able to reach intakes recommended by the Dietary Guidelines 
(Ref. 10).  As more than 70 percent of Americans sodium intake comes from foods where 
sodium is added during food manufacturing and commercial food preparation (Refs. 11, 12), 
lowering population intake of sodium to more moderate levels must involve lowering the amount 
of sodium added to commercially processed, packaged, and prepared foods in the U.S. 
marketplace (Refs. 2, 10).   
 
Various food manufacturers, retailers, and food service firms have initiated voluntary efforts to 
reduce sodium, with some success (Refs. 11, 12).  However, consumers who are trying to 
consume less sodium continue to face significant challenges.  The 2010 National Academies 
report Strategies to Reduce Sodium Intake in the United States noted that the food supply itself 
is a key obstacle for consumers: The sodium densities of available foodsboth in the 
marketplace and from restaurant/food service operationsmake it difficult for consumers to 
meet dietary recommendations (Ref. 10).  Given the emphasis on sodium reduction by the 
public health community over the last several decades, the available evidence demonstrating 
little progress in reducing sodium intake on a population level over this time (Ref. 10), and the 
number of foods in the marketplace that are high in sodium, additional strategies are warranted to 
reduce sodium consumption.  To assist consumers who want to lower the total sodium content of 
their diets, this guidance aims to support voluntary, coordinated, and gradual reduction of sodium 
across the food supply.  
 
Below, we provide guidance to industry in the form of specific targets for a broad sector of the 
market for sodium content in categories of commercially processed, packaged, and prepared 
foods.  These categories are compatible with existing industry and regulatory categories and with 
government databases (Ref. 5).  This guidance is intended to inform general industry thinking 
about sodium content in their foods.  This guidance is not intended to limit industrys use of any 
appropriate methods or technologies to achieve sodium reduction.  
 
FDA, in cooperation with other agencies, intends to monitor the prevalence of sodium in the 
food supply over time using the measures described in this guidance and supporting documents. 
To avoid the potential for unintended consequences, we plan to monitor the levels of other 
nutrients (e.g., added sugars and saturated fat); such monitoring will be done by, for example, 
consulting product nutrition information and ingredient lists to ensure that no broad trends 
emerge that negatively affect the nutritional quality of foods.  We will continue to discuss with 
industry the appropriate use of ingredients added to food as part of sodium reduction efforts 
  6 
 
  Contains Nonbinding Recommendations 
 
during product development or reformulation.  Our goal is to encourage gradual, efficient  
reduction of overall sodium content using effective and sustainable strategies that maintain other 
measures of nutritional quality.  Because many higher-selling products currently marketed are at 
or below the category means presented in this guidance, it should be possible to avoid disruptive 
changes to individual products that might result in noticeably altered taste, greatly reduced shelf 
life, or other undesirable product outcomes.9 
 
D:  Intended Audience 
 
This guidance is intended for members of the food industry (e.g., food manufacturers and other 
establishments that commercially prepare foods), and also may be of interest to public health 
groups and consumers.  Broad industry adoption of these voluntary recommendations can create 
a meaningful reduction in population sodium intake over time and support adjustment of 
consumer taste preferences.  However, we recognize that most of the food consumption in the 
U.S. comes from a relatively small number of products and menu items in the marketplace that 
are produced by a limited number of food manufacturers.  It is possible that reformulation by 
these food manufacturers could lead to increased demand for lower-sodium versions of 
ingredients used to produce packaged and prepared foods.  As a result, such actions could help 
all members of the food industry be more readily able to provide lower-sodium products.  Given 
the resources involved in successful reformulation to achieve voluntary sodium reduction and to 
have the most public health impact, we specifically encourage attention by: 
 
  Food manufacturers whose products make up a significant proportion of national sales in 
one or more categories, and 
  Restaurant and similar retail food chains that are national or regional in scope.    
 
II.  Background 
 
A:  Sodium and Health 
 
Research shows that excess sodium consumption is a contributory factor in the development of 
hypertension (Refs. 4, 13-15), which is a leading cause of heart disease and stroke, the first and 
fifth leading causes of death in the United States, respectively (Ref. 16).  Decreasing population 
sodium intake is therefore expected to reduce the rate of hypertension.  Research also shows that 
the increase in blood pressure seen with aging, common to most Western countries, is not 
observed in populations that consume low sodium diets (Ref. 17) and that the U.S. population 
consumes far more sodium than recommended (Refs. 3 and 18).  Moreover, dietary reduction of 
sodium can lower blood pressure, as has been demonstrated in the Dietary Approaches to Stop 
Hypertension (DASH)-Sodium trial (Ref. 19) and other experimental studies (Refs. 4 and 20).   
 
 
 
 
 
9 We provide information about products relative to category means on our sodium reduction webpage at 
www.fda.gov/sodiumreduction. 
  7 
 
  Contains Nonbinding Recommendations 
 
B:  U.S. Sodium Intake and Recommendations 
 
Currently, the average sodium intake for Americans 2 years and older is approximately 3,400 
milligrams per day (mg/day) (Refs. 3, 18).  The recommendations of scientific groups that are 
charged with examining the totality of the evidence, including scientific bodies, qualified experts 
and governments around the world, support limiting sodium intake to about 2,300 mg/day (Refs. 
3, 4, 21-24).  Ninety-six countries have implemented a national strategy for sodium reduction 
(Ref. 25).  A systematic review evaluating the effects of sodium reduction in high-income 
countries found no evidence of adverse effects from initiatives to reduce sodium intake (Ref. 26).   
 
This guidance supports the goal of reducing sodium intake as recommended by scientific 
consensus groups, by focusing on short-term reduction to 3,000 mg/day as a gradual approach to 
sodium reduction in the food supply.  The guidance reflects the broad consensus among experts 
regarding the direct relationship between sodium and blood pressure, as well as the relationship 
between blood pressure and cardiovascular disease events (Ref. 4).  With average sodium intake 
in the U.S. over 3,400 mg/day, there is considerable work to do to reduce intake to the 
recommended limit of 2,300 mg/day in order to reduce the risk of hypertension and 
cardiovascular disease.  Thus, the overall goal of this guidance is to support reduction of average 
sodium intake to 3,000 mg/day as we continue the dialogue on sodium reduction.    
 
C:  Potential Public Health Impact of Sodium Reduction 
 
Multiple studies have estimated the public health and economic benefits associated with broad 
reduction in sodium intakes in the U.S. (Refs. 27-30).  Those studies have shown that reductions 
in average intake (modeled at a variety of intake levels below current intake, down to an average 
level of roughly 2,200 mg/day) have been estimated to result in tens of thousands fewer cases of 
heart disease and stroke each year, as well as billions of dollars in health care savings over time.  
One study (Ref. 27) used three epidemiological datasets to estimate the separate public health 
benefits of reducing the populations average sodium intake to 2,200 mg/day over 10 years.  The 
researchers estimated that this pattern of reduction would prevent between 280,000 and 500,000 
premature deaths over 10 years and that sustained sodium reduction would prevent additional 
premature deaths. 
 
D:  Other Initiatives with the Goal of Reducing the Sodium Content of Foods 
 
This guidance is informed by domestic and international initiatives to reduce sodium in the food 
supply.  In the United States, the New York City Department of Health and Mental Hygiene 
initiated the National Salt Reduction Initiative (NSRI),10 a partnership of 70 local and state 
health departments and health organizations, to set voluntary targets to reduce sodium in 
restaurant and processed foods.  The goal of NSRI was to decrease average sodium intake by 20 
percent over five years (2009 through 2014) by developing stepwise reductions from 2009 base 
levels.  More than 25 companies, including packaged food corporations and restaurants, 
responded to NSRI by committing to reductions in the sodium content of some of their products 
(Ref. 31).  According to the most recent report, some participating food companies achieved the 
 
10 This initative was updated to the National Salt and Sugar Reduction Initiative (NSSRI) in 2019. 
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  Contains Nonbinding Recommendations 
 
2012 NSRI targets for various categories (Ref. 11).  By 2014, NSRI reported that 26 percent of 
packaged food categories met 2012 targets and 3 percent met 2014 targets (Ref. 12). 
 
Internationally, of the 96 countries with sodium reduction strategies, more than 50 countries have 
developed initiatives to support the reduction of sodium in the food supply (Refs. 25, 32).  These 
initiatives have included both voluntary and mandatory efforts.  In an approach developed by the 
United Kingdoms (UK) Food Standards Agency, many companies voluntarily pledged to reduce 
sodium in their foods.  The UK initiative resulted in a decline in average sodium intake from 
3,800 to 3,240 mg/day between 2003 and 2011, and researchers concluded that decreases in 
blood pressure in the UK during this time were largely attributable to the reduction in sodium 
intake (Ref. 33).  In 2020, the UK government issued revised voluntary targets to be achieved by 
2024 (Ref. 34).  Health Canada, the department within the Canadian government responsible for 
helping Canadians maintain and improve their health, also developed a voluntary approach to 
sodium reduction.  Health Canada collated information from the food industry and other 
stakeholders to inform their guiding benchmark sodium reduction levels for processed foods, 
which were issued in 2012 to be achieved by 2016.11  In 2017, Health Canada evaluated the food 
industrys efforts to meet sodium reduction targets in processed foods.  Results showed that 52 
percent of food categories met the Canadian Phase I, II, or III targets, indicating that voluntary 
efforts can reduce sodium in packaged foods (Ref. 35).  In 2020, Health Canada also issued 
updated voluntary targets to be achieved by 2025 (Ref. 36). 
   
E:  Food Ingredient Regulation 
 
The Federal Food, Drug, and Cosmetic Act (FD&C Act) requires that a food additive be 
approved for use in food and used in accordance with its approved conditions of use (see 
generally 21 U.S.C. 348).  Certain food substances are exempt from these requirements because 
they are exempt from the definition of a food additive.  These food substances include substances 
that are generally recognized as safe (GRAS) for their intended use (see 21 CFR 170.30) and 
substances that have been prior sanctioned (21 U.S.C. 321(s)).  FDAs food additive and GRAS 
regulations may establish certain limitations for the use of these food substances.  Moreover, 
these regulations are predicated on usage of the substances under conditions of good 
manufacturing practices (21 CFR 170.30(h) and 21 CFR 172.5).  In addition to the safety 
requirements of the FD&C Act, the intended use of a food ingredient in meat, poultry, or egg 
products must be verified as efficacious and suitable by the United States Department of 
Agricultures (USDAs) Food Safety and Inspection Service (FSIS).12  FDA regards salt (sodium 
chloride) as a common food ingredient that is GRAS for its intended use (see 21 CFR 182.1(a)), 
and salt (sodium chloride) is an optional or required ingredient in many food standard regulations 
promulgated by FDA or by USDA.13 
 
11 Additional information on Health Canadas sodium reduction initiative can be found in FDAs Voluntary Sodium 
Reduction Goals:  Supplementary Memorandum to the Draft Guidance (Ref. 5). 
12 Related Documents for FSIS Directive 7120.1 - Safe and Suitable Ingredients used in the Production of Meat, 
Poultry, and Egg Products, http://www.fsis.usda.gov/wps/portal/fsis/topics/regulations/directives/7000-series/safe-
suitable-ingredients-related-document 
13 For discussions of FDAs regulation of sodium, see generally 72 FR 59973 (Oct. 23, 2007) and 47 FR 26590 
(June 18, 1982). 
 
  9 
 
  Contains Nonbinding Recommendations 
 
 
III.  Discussion  
 
A gradual and voluntary approach to reducing sodium in the food supply is intended to create 
flexibility for industry members interested in supporting the public health goals of this guidance.  
By encouraging action with respect to the products that are the market leaders (i.e., products sold 
in the greatest numbers) in each category, we hope to stimulate innovative product reformulation 
that maintains market share while also having the most significant public health impact and 
minimizes the impact on low-market share products in the food category.  
 
FDA has developed quantitative target mean concentrations and upper bound concentrations for 
sodium levels in various identified food categories.  The target mean concentrations (target 
means) are goals for sodium levels for the category, calculated as the sales-weighted mean 
sodium level (in milligrams per 100 grams of food).  In setting these target means, FDA has 
taken into account concentrations necessary to achieve important food safety functions (e.g., 
antimicrobial) and functionality roles.  The short-term targets are intended to be feasible using 
existing technology and are within the range of currently available top-selling commercial 
products.  The upper bound sodium concentrations (upper bounds) are goals for the highest level 
of sodium for products in each food category (in milligrams sodium per 100 grams of food).   
 
In Table 1 in the Appendix of this guidance, we summarize the results of our analysis of the 
sodium content of the food supply and identify short-term target mean (average) sodium 
concentrations for a wide variety of food categories, as well as the upper bound sodium 
concentration for products in these food categories.14  These sodium concentration goals were 
informed by the distribution of sodium from packaged products and menu items in the food 
supply in 2010, as well as by publicly available data and information about the formulation of 
sodium-reduced foods. Nutrition data came from Nutrition Facts labels for packaged foods and 
from restaurant nutrition information.15   
 
Food industry manufacturers, particularly the firms described earlier (e.g., food manufacturers 
whose products make up a significant proportion of national sales in one or more categories and 
restaurants and similar retail food chains that are national or regional in scope), may consider 
using the voluntary goals in Table 1 to inform decisions about the use of sodium in products or 
menu items.   
 
Table 1 contains four key elements: 
 
  Foods and food categories; 
  Baseline sodium concentrations; 
  Target mean sodium concentrations; and 
 
14 See also FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5) 
for a detailed discussion of target and non-target categories of foods.  Non-target categories of foods either did not 
contain meaningful amounts of sodium or did not contribute meaningfully to sodium intake in the general 
population because they were consumed rarely and thus provided little contribution relative to other food groups.  
15 Additional information on data sources is available in FDAs Voluntary Sodium Reduction Goals Supplementary 
Memorandum to the Draft Guidance (Ref. 5). 
  10 
 
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  Upper bound sodium concentrations. 
 
We describe each of these elements in more detail below.   
 
A:  Foods and Food Categories 
 
In developing sodium reduction goals, FDA reviewed various food categorization systems,16 
identified significant contributors to the intake of sodium in the United States, and organized 
foods into various identified food categories.  We identified and categorized the foods in these 
categories on the basis of: 
 
  Contribution to sodium intake; 
  The total amount of sodium in the food (foods with added sodium, i.e., not just naturally 
occurring); 
  Similar functional roles for sodium-containing ingredients; 
  Similar sodium concentrations;  
  Similar technical potential for reduction in sodium content; 
  Compatibility with existing industry and regulatory categories; and  
  Comments received to the draft guidance docket. 
 
Many food categories have recommended targets (listed in Table 1; e.g., various bakery 
products, meats, cheeses, and types of sauces, etc.).  However, we did not suggest targets for 
certain categories that do not contribute meaningfully to overall sodium intake17 (e.g., salted 
dried fish and organ meat) either because they were consumed rarely (by all ages and ethnicities) 
or because they provided little contribution to sodium intake relative to the other food groups.18   
 
B:  Baseline Sodium Concentrations 
 
Table 1 presents baseline sodium concentrations for each of the identified food categories.  Each 
baseline should be interpreted as our assessment of the approximate state of the market 
regarding sodium concentrations in each food category in 2010,19 based on public 
representations of sodium content by the food industry through food labels and menus, rather 
than as representing a precise measurement of sodium concentrations in the food supply.  We 
derived these baseline values from a large, market-weighted array of products in each category.  
 
16 The food categorization systems mentioned refer to various government food category systems, private-sector 
food category systems, and sodium reduction initiative category systems that are further described in the FDAs 
Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5). 
17 See FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5) for a 
table with foods for which targets were not developed, and Tables 1 and 2 of this guidance.  
18 For more detail about the process we used to identify and categorize these foods, see FDAs Voluntary Sodium 
Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5), as well as our expanded definitions 
for categories in this guidance. 
19 For our rationale in selecting 2010 as our baseline year and for more detail about the data sources used, see FDAs 
Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5).  For this 
guidance, baseline values for categories include the full year of 2010 data (Ref. 37). 
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We include them in the tables to provide context for the target mean concentrations and upper 
bound concentrations.   
 
We developed the baselines for sodium concentrations using label data for packaged foods sold 
directly to the consumer and menu nutrition data for foods sold in large restaurant chains.  We 
used these data because they are available for each individual product and they are the 
manufacturers or restaurant chains representation of the sodium content of their products.  We 
also developed these baselines using sales volume data for the products involved, so that more 
widely consumed products in a category would have more influence on the final sodium 
concentration for the category.  In other words, we used sales volume data to give extra weight to 
higher-selling foods in a category and to eliminate very low-volume foods from our 
calculations.20 
 
We developed baselines for packaged foods by reviewing label data on sodium content for the 
individual food products within a category.  We focused on foods making up the top 80 percent 
of sales by volume in each category.  Using both label and sales data for packaged foods, we 
calculated a sales-weighted average sodium concentration for the category; products with higher 
sales volume counted for more in the final average.  
 
We developed baselines for commercially prepared foods by reviewing public menu data for the 
largest national and regional restaurant chains, capturing only those menu items with added 
sodium.  Because sales data on individual products within each restaurant chain were not 
available, we calculated a sales-weighted average sodium concentration for each category using 
the total sales of each chain as a proxy value; products from a chain with greater total sales of all 
products counted for more in the final average.  Because sodium concentrations are not always 
similar in packaged and restaurant versions of a food, we developed two separate baselines for  
packaged and restaurant (prepared) foods.21   
 
C:  Target Mean and Upper Bound Sodium Concentrations 
 
For our draft guidance, we developed a model of sodium intake based on our food categories and 
the 2009-2010 What We Eat in America (WWEIA) survey22 consumption data (Ref. 5).  We  
estimated that a reduction in mean population intake to near 3,000 mg/day could be attainable if 
the food industry achieved the short-term goals presented in the draft guidance.   
 
We recognize that any potential changes in the sodium content of the food supply will take time. 
Table 1 identifies our 2.5-year goals for sodium concentrations in the food supply, both for the 
 
20 See FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5) for a 
detailed discussion of our use of sales volume data to give extra weight to higher-selling foods and eliminate low-
volume selling foods from our calculations. 
21 See FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5) for 
more detail about the development of baseline sodium concentrations. 
22 The National Health and Nutrition Examination Survey is a program of studies designed to assess the health and 
nutritional status of adults and children in the United States.  It is a major program of the National Center for Health 
Statistics, which is part of the Centers for Disease Control and Prevention (CDC).  More information about 
NHANES can be found at http://www.cdc.gov/nchs/nhanes.htm.  
  12 
 
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target mean and for the upper bound sodium concentrations (defined in the discussion above and 
further discussed below).23 
 
The 2.5-year 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 distribution of sodium concentrations in currently available products in each 
category was a significant factor in developing these quantitative sodium concentration goals.  
We developed the goals with a particular emphasis on maintaining concentrations needed for 
food safety, given the function of salt as a food preservative.  These short-term goals are within 
the range of concentrations found in currently marketed foods and are feasible using existing 
technical strategies.   
 
We acknowledge that small businesses may not have the same resources as larger companies for 
reaching these goals.  However, we anticipate that these goals would ultimately be within reach 
for all firms, given time and the spread of innovations in food ingredients and manufacturing 
methods.   
 
We consider it likely that the amount of a sodium-containing ingredient needed to achieve 
various technical effects (including flavor) in foods could decrease over time, due to advances in 
food technology, such as flavor science and food preservation.  Changes in consumer taste 
preferences are also possible, and may be more likely, should reformulation occur.  
Reformulation strategies are expected to take time to implement; as a result, we expect 
sustainable reductions in the amount of sodium in the food supply to happen gradually.  The 
reformulation strategies will likely vary; for example, sodium concentrations in processed and 
packaged foods are not always parallel to the sodium concentrations in comparable foods 
prepared at restaurants and other retail food establishments.  The short-term (2.5-year) goals 
(which include both the target mean concentrations and upper bound concentrations) reflect this 
differentiation. 
 
We do not provide detailed guidance on the technical details of reducing sodium in this 
document, although we reviewed the publicly available scientific literature on potential 
opportunities and technologies for reducing sodium (Refs. 6-8).  Experts from the food industry 
are well-positioned to innovate by exploring combinations of strategies and technologies that are 
most appropriate for each food category and each food product reformulation while maintaining 
food safety.  However, we want to make clear that broader public health goals and maintenance 
of nutritional quality are important considerations in developing sodium reduction or 
reformulation strategies.  For example, sodium reduction that relies on increases in added sugars 
would not be consistent with the public health goals of this guidance.24 
 
 
23 See FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5) for 
further discussion on the target mean and upper bounds. 
 
24 We also recognize that in reformulating products, firms may need to balance additional public health goals, such 
as reducing acrylamide formation in certain foods (see FDAs Guidance for Industry: Acrylamide in Foods, March 
2016, available at https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-
acrylamide-foods). 
  13 
 
  Contains Nonbinding Recommendations 
 
1.  Voluntary Target Mean Sodium Concentrations 
 
Table 1 identifies voluntary target mean sodium concentrations for each food category.  The 
voluntary target mean indicates the desired average sodium concentration in each category, 
weighted by relative sales volume so that more popular products have a greater influence on the 
category average.  Target assignment was based on a default reduction percentage modified by 
available category-specific information.  The extent of targeted reduction in each food category 
is influenced by the functions of sodium-containing ingredients in the category, as well as the 
distribution of sodium concentrations we found in products within that category.25  These values 
are FDAs goals for each food category as a whole, not necessarily for individual manufacturers 
who choose to pursue these goals voluntarily.  These mean target concentrations represent the 
benchmarks that we will use to assess the impact of any voluntary efforts by members of the 
food industry on the overall composition of the food supply.  However, individual members of 
the food industry choosing to pursue sodium reduction may find it helpful to assess the sales-
weighted status of their product portfolio in a particular category with reference to the target 
mean concentration in order to inform decisions about where to focus their voluntary 
reformulation efforts.26   
 
2.  Voluntary Upper Bound Sodium Concentrations 
 
Table 1 also identifies voluntary upper bound sodium concentrations for each food category.  
The upper bound is a standard that could be applied to every individual product in a category, in 
contrast to the target means, which apply to average concentrations in a food category.  Food 
industry members can compare any of their products in a category to the upper bound 
concentration for every product in that category.  The upper bound for each category is 
influenced by the corresponding target mean concentration and the current distribution of sodium 
concentrations for products in that category.27  The upper bound sodium concentrations are goals 
and do not represent maximum allowable levels for sodium. 
 
IV.  Appendix  
 
Table 1. Voluntary Sodium Reduction Goals: Target Mean and Upper Bound Concentrations for 
Sodium in Commercially Processed, Packaged, and Prepared Foods (see attached Excel table)   
   
Table 2. Non-Target Categories 
 
The non-target categories are food categories for which we have not developed goals. Non-target 
categories include those that either did not contain meaningful amounts of added sodium (i.e., 
are foods with no sodium or with intrinsic sodium that is not added) or did not contribute 
 
25 FDA consulted with FSIS staff during the development of the meat and poultry categories and target mean 
concentrations. 
26 See FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5). 
27 See FDAs Voluntary Sodium Reduction Goals Supplementary Memorandum to the Draft Guidance (Ref. 5) for 
more details about the calculation of upper bound concentrations. 
  14 
 
  Contains Nonbinding Recommendations 
 
meaningfully to overall sodium intake because they were consumed rarely (by all ages and 
ethnicities) and because they provided little contribution relative to the other food groups.28 29 
 
Table 3. Definition of Terms Used in This Document (for the purposes of this guidance only) 
 
 
28 As measured by an analysis of the food sources of sodium intake using 2007-2008 WWEIA/NHANES data. 
29 As assessed by a sensitivity analysis to determine if food categories shifted, looking at percent consumer, per user 
mean, and per capita mean. 
  15 
 
  Contains Nonbinding Recommendations 
 
Table 2. Non-Target Categories 
General Food Category  Category and Product Examples 
Dairy  All milk except buttermilk and dry milk 
Dairy  Buttermilk 
Dairy  Dry milk 
Dairy  Yogurt 
Dairy  Ice cream/frozen yogurt 
Dairy  Hot Cocoa 
Dairy  Ice cream bars/cones/sundaes 
Dairy  Whipped topping 
Dairy  Cream and cream substitute 
Dairy  Sour cream 
Dairy  Custards/flans 
Dairy  Mousse-type pudding 
Dairy  Mascarpone cheese 
Dairy  Ricotta cheese 
Dairy  Fresh Mozzarella cheese 
Dairy  Cheese fondue (packaged food) 
Dairy  Cream-based fruit dips 
Fats, Oils,  and Dressings  Animal fats 
Fats, Oils,  and Dressings  Natural oils 
Fats, Oils,  and Dressings  Raw commodities 
Fats, Oils,  and Dressings  Butter  unsalted 
Fats, Oils,  and Dressings  Margarine, vegetable oil spreads  unsalted 
Fruits, Vegetables, and Legumes  Fruit - raw/fresh 
Fruits, Vegetables, and Legumes  Fruit  frozen 
Fruits, Vegetables, and Legumes  Fruit filling 
Fruits, Vegetables, and Legumes  Fruit  canned 
Fruits, Vegetables, and Legumes  Fruit - salads/cocktails 
Fruits, Vegetables, and Legumes  Fruit  cooked 
Fruits, Vegetables, and Legumes  Fruit  juice 
Fruits, Vegetables, and Legumes  Fruit  dried 
Fruits, Vegetables, and Legumes  Fruit - misc. (sauces, juice bars, etc.) 
Fruits, Vegetables, and Legumes  Coconut products 
Fruits, Vegetables, and Legumes  Vegetables - raw and/or no added sodium 
Fruits, Vegetables, and Legumes  Boiled/baked/raw potatoes, no toppings 
Fruits, Vegetables, and Legumes  Dried beans and dried peas 
Fruits, Vegetables, and Legumes  Instant potatoes, unseasoned 
Fruits, Vegetables, and Legumes  Dried vegetables 
Fruits, Vegetables, and Legumes  Vegetable pastes/purees 
Fruits, Vegetables, and Legumes  Peppers, Shelf-Stable 
Pickled Vegetables, excluding pickled cucumbers 
Fruits, Vegetables, and Legumes 
(pickles) 
Fruits, Vegetables, and Legumes  Fruit  pastes/cubes 
  16 
 
  Contains Nonbinding Recommendations 
 
Fruits, Vegetables, and Legumes  Tomato  puree 
Fruits, Vegetables, and Legumes  Crispy fried onions 
Fruits, Vegetables, and Legumes  Grape leaves  stuffed/non-stuffed 
Nuts and Seeds  Nuts/seeds, unsalted 
Dessert/sweet seed/nut spreads (almond paste, chocolate 
Nuts and Seeds 
hazelnut spread, caramel paste, etc.) 
Nuts and Seeds  Miso (soy bean paste) 
Soups  Liquid/paste bouillon 
Soups  Refrigerated soup bases/starters/mixes 
Soups  Wet broth/stocks  concentrate/base/starter 
Soups  Frozen soups 
Sauces, Gravies, Dips, Condiments, 
Seasoned salt and seasoning salt 
and Seasonings 
Sauces, Gravies, Dips, Condiments, 
Relish 
and Seasonings 
Sauces, Gravies, Dips, Condiments, 
Hummus dip, dry-mix 
and Seasonings 
Cereals  Ready-to-eat cereals, shredded 
Cereals  Ready-to-eat cereals, granola 
Cereals  Ready-to-eat cereals, muesli 
Bakery Products  Pie crust/shells 
Bakery Products  Soda bread 
Bakery Products  Bread pudding 
Bakery Products  Tortillas and wraps, corn  
Bakery Products  Brownie dough 
Bakery Products  Dry mix brownies and cookies 
Bakery Products  Liquid bakery batters 
Bakery Products  Graham cracker crumbs 
Bakery Products  Wrappers  egg roll/won ton/gyoza/spring roll 
Bakery Products  Ice cream bowl/cone 
Bakery Products  Other desserts (panna cotta, creme brulee) 
Meat and Poultry (and substitutes)  Organ meat, not cured/smoked 
Meat and Poultry (and substitutes)  Organ meat, cured/smoked 
Meat and Poultry (and substitutes)  Veal 
Meat and Poultry (and substitutes)  Lamb and goat 
Meat and Poultry (and substitutes)  Game meat, not cured/smoked 
Meat and Poultry (and substitutes)  Game meat, cured/smoked 
Meat and Poultry (and substitutes)  Prosciutto 
Meat and Poultry (and substitutes)  Ground meat/poultry, raw patties 
Meat and Poultry (and substitutes)  Pate/Meat Spreads 
Meat and Poultry (and substitutes)  Vegetarian Pate/ & Terrines 
Fish and Other Seafood  Fresh/raw fish and seafood 
Fish and Other Seafood  Salted/pickled/dried/smoked fish and other seafood 
Fish and Other Seafood  Escargot 
Fish and Other Seafood  Seafood pastes/pates 
  17 
 
  Contains Nonbinding Recommendations 
 
Fish and Other Seafood  Caviar 
Eggs and Egg-based Dishes (and  Eggs and egg substitutes, no additions during 
substitutes)  preparation (packaged) 
Snacks  Popcorn kernels 
Sweet popcorn (kettlecorn, caramel, chocolate covered, 
Snacks 
etc.) 
Snacks  Roasted vegetable snacks  corn nuts/wasabi peas, etc. 
Snacks  Wheat nuts 
Mixed Ingredient Dishes  Sushi 
Toddler/Baby Foods  Toddler/baby meat sticks 
Confectionary (Sweets)  Sugar and sugar substitutes  
Confectionary (Sweets)  Syrups 
Confectionary (Sweets)  Gelatin desserts, jellies, jams 
Confectionary (Sweets)  Chewing gum 
Confectionary (Sweets)  Fudges 
Confectionary (Sweets)  Candy and chocolate with nuts 
Confectionary (Sweets)  Candy and chocolate without nuts 
Confectionary (Sweets)  Non-dairy based bakery desserts 
Confectionary (Sweets)  Non-dairy frozen/prepared desserts 
Confectionary (Sweets)  Frosting 
Confectionary (Sweets)  Chocolate syrup 
Confectionary (Sweets)  Chocolate fondue 
Confectionary (Sweets)  Chocolate-covered potato chips 
Confectionary (Sweets)  Halva 
Confectionary (Sweets)  Brittles 
Other Foods  Infant food products, infant formula 
Other Foods  Meal replacement powders, and supplements 
Other Foods  Pasta  shelf-stable 
Other Foods  Matzo balls, in broth 
Beverages   Non-alcoholic 
Beverages  Alcoholic 
Beverages   Water 
 
   
  18 
 
  Contains Nonbinding Recommendations 
 
 
Table 3. Definition of Terms Used in This Document (for the purposes of this guidance 
only) 
 
Term   Definition in this Guidance  
Sodium concentration of the product after the food product is 
As prepared  prepared according to the products specific preparation and 
cooking directions provided on the product label. 
The amount of sodium in a category representing the 2010 U.S. 
food supply.  The levels are provided as sales-weighted mean 
concentrations (sodium in mg per 100 g).  Baseline levels were 
Baseline level  calculated using product nutrition information from commercially 
available databases and public websites.  Scanner data was used 
for sales weighting packaged foods and restaurant total dollar 
amounts were used for weighting items at major restaurant chains. 
A grouping of food products at the level for which a sodium 
reduction target is suggested.  Unless otherwise noted, each 
category includes all relevant food items containing added sodium.  
Food Category 
The category product inclusions are not confined to a specific 
industry sectors (e.g., packaged foods, prepared foods) or point of 
purchase.   
Food Service  An operation that stores, prepares, packages, serves, and sells food 
establishment  directly to the consumer. 
High level food category grouping for the list of sodium reduction 
Food Group 
targets (e.g., Dairy; Fats, Oils, and Dressings; etc.). 
Refers to both target mean and upper bound concentrations that 
Goals or Sodium 
have been established for 2.5 years after final publication of this 
Reduction Goals 
guidance. 
Hypertension, or high blood pressure, generally means a systolic 
Hypertension  blood pressure of greater than 140 millimeters of mercury (mm 
Hg) or a diastolic blood pressure of greater than 90 mm Hg.  
Packaged or prepared food that is ready for human consumption at 
time of purchase.  Ready-to-eat food does not require further 
Ready-to-eat food 
addition of ingredients, preparation, or cooking by the consumer to 
achieve food safety.  
A measurement of sodium content calculated by weighting 
individual products by volume sales given as the average sodium 
content in milligrams per 100 grams.  A sales-weighted mean 
Sales-weighted mean 
gives more weight to items that sell more, thereby providing a 
preferred monitoring metric for evaluating future sodium 
reduction progress. 
Sodium is specified here as the chemical entity or electrolyte 
sodium and is distinguished from sodium chloride, or salt, 
Sodium  which is 39 percent sodium by weight (21 CFR 101.74).  
Examples of other sodium-containing ingredients found in foods 
include sodium propionate, sodium lactate, and sodium benzoate.  
  19 
 
  Contains Nonbinding Recommendations 
 
Table 3. Definition of Terms Used in This Document (for the purposes of this guidance 
only) 
 
Term   Definition in this Guidance  
Addition of salt, herbs and spices to food for the purpose of flavor 
Seasoned (and seasoning) 
enhancement. 
The goal sodium level for the category, calculated as the sales-
Target (mean)  weighted mean sodium level (in milligrams per 100 grams of 
food). 
The goal upper bound sodium content of an individual food 
Upper bound  product or menu item included in a food category (in milligrams 
per 100 grams of food). 
ii This is based on the definition of food establishment in FDAs Food Code (2013). 
http://www.fda.gov/food/guidanceregulation/retailfoodprotection/foodcode/ucm374275.htm 
 
V.  References 
The following references marked with an asterisk (*) are on display at the Dockets Management 
Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 
20852, and are available for viewing by interested persons between 9 a.m. and 4 p.m., Monday 
through Friday; they also are available electronically at https://www.regulations.gov.  References 
without asterisks are not on public display at https://www.regulations.gov because they have 
copyright restriction or are not publications.  Some may be available at the website address, if 
listed.  References without asterisks are available for viewing only at the Dockets Management 
Staff or, in the case of non-publication references, at any website listed.  FDA has verified the 
website addresses, as of the date this document publishes in the Federal Register, but websites 
are subject to change over time. 
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  20 
 
  Contains Nonbinding Recommendations 
 
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  23