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ARCHIVED - Stakeholder Consultation on Setting Sodium Reduction Targets (January 2011)

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Bureau of Nutritional Sciences
Food Directorate, Health Products and Food Branch
Health Canada

In response to the Sodium Working Group (SWG)'s recommendations issued in its final report, Sodium Reduction Strategy for Canada, Health Canada has been working to establish sodium reduction targets for foods sold in Canada. With more than 75% of sodium in the diets of Canadians coming from commercially prepared foods, much of the effort to lower sodium must focus on the food supply. Health Canada recognizes that the process of setting targets for sodium content in foods is complex since the role and function of salt, and other sodium-containing additives and ingredients, vary depending on the nature of the food.  As such, we are seeking feedback from industry to ensure that the proposed targets are substantive and realistic, thereby achieving the public health goal of reducing dietary sodium intakes while taking into account potential technical or transitional issues.

Feedback Questionnaire on Proposed Sodium Reduction Targets

Background

Between October 2007 and July 2010, Health Canada convened a Multi-Stakeholder Working Group on Dietary Sodium Reduction (the Sodium Working Group or SWG).  The SWG was tasked with developing a population health strategy for the reduction of the sodium content in the diets of Canadians to be in line with the recommendations of the DRI report of the Next link will take you to another Web site Institute of Medicine of the U.S. National Academies (IOM).

The SWG's work culminated with its Sodium Reduction Strategy for Canada (July 29, 2010), a multi-staged strategy based on a three-pronged approach including: voluntary reduction of sodium levels in prepackaged processed food products and foods sold in foodservices establishments, education, and research. These elements would be complemented by ongoing monitoring and evaluation, and adjustment of the approach as required.

It is currently estimated that the average Canadian's sodium intake is 3,400 mg per day. The Strategy has an interim sodium intake goal of a population average of 2,300 mg of sodium per day to be achieved by 2016. The ultimate goal recommended by the SWG is to lower sodium intakes to a population mean whereby as many individuals as possible (greater than 95% of the population) have a daily intake of sodium below 2,300 mg, which is the Tolerable Upper Intake Level.

Structured voluntary approach in reducing sodium in the food supply

The voluntary approach recommended by the SWG is a structured one that involves

  • Published sodium reduction targets for foods.
  • Defined timelines.
  • A mechanism for public commitment by industry to the targets.
  • A plan for monitoring progress by a body other than the food industry.
  • A plan for independent evaluation of the success of the program with the option of taking stronger measures as necessary depending on progress.

Previous Interactions with Food Industry Stakeholders

In September 2009, Health Canada and the Food Supply Sub-Committee of the SWG held meetings with the food industry, and other interested stakeholders, to inform them about the need to reduce the amount of sodium in commercially prepared foods and of the work being done by the SWG. Information provided during these meetings was the first step towards broader discussions on specific sodium reduction targets for processed foods and foods sold through foodservice establishments.

In November and December 2009, Health Canada's Food Directorate conducted eight meetings with food industry stakeholders to inform them of Health Canada's approach to reducing sodium in foods, and to initiate discussion on the proposed draft sodium reduction targets for the first set of food categories (Group I).

Between February and March 2010, the Food Directorate sought written feedback from industry on the draft sodium reduction targets that were developed for Group I; this consultation was posted on the Health Canada website, and 53 written submissions were received from industry stakeholders. This feedback was used to help revise the Group I targets and to develop targets for the second set of food categories (Group II). For the purpose of establishing step-wise reductions and for monitoring progress in sodium reduction, interim milestones have been established as sales weighted averages (SWA), to be achieved by the ends of 2012 and 2014 respectively, as well as final targets to be achieved by the end of 2016 (see Appendix A for the full set of draft sodium reduction targets).

Health Canada's Approach to Setting Sodium Reduction Targets

The 2012 and 2014 milestones proposed in Appendix A are in the form of SWAs while the final 2016 targets are listed as both a SWA and a maximum target. By the end of 2016, a company should aim to meet both the 2016 SWA and the maximum target for each food category. It is important to note that in adopting a SWA, the majority of maximums have been set higher than they would have been without the SWA. The 2016 SWAs are set such that if achieved by the food industry, the SWG's interim goal of a population average sodium intake of 2,300 mg sodium per day will be met, assuming no change in eating patterns. The Canadian Community Health Survey 2.2 (2004) was used as the basis for estimating sodium intake.

The purpose of also having maximums is to encourage the elimination of the highest sodium products in a category. Monitoring of sodium reduction progress will help determine if the maximum target for 2016 will need to be adjusted downward while continuing to ensure public health goals will be met.

In deciding to take this approach, several factors were considered. Targets had to be set at a level that would not only lower sodium intakes to the 2016 interim sodium reduction goal established by the SWG, but would also not compromise the safety, quality, and variety of foods available to Canadians, including in remote Northern communities. The approach thus provides companies the ability to plan their sodium reduction efforts according to which products are most amenable to reformulation or discontinuation, as well as to get the most impact for achieving the targeted weighted average sodium content in each product category within their portfolio. Lastly, it was important to have easily understood end targets against which achievement can be measured while still being able to measure progress before 2016. Nevertheless, as recommended by the SWG, manufacturers should seek to lower the sodium content of their products to meet the voluntary targets and go beyond them over time to the lowest level possible, taking into considerations factors like microbial safety, quality and consumer acceptance.

In order to monitor progress towards sodium reduction where milestones and end targets have been set as SWAs, Health Canada will be calling on companies to provide, at intervals, sodium content and other nutrition data from their products' Nutrition Facts tables, as well as sales volume data for each product. The latter information would, of course, be kept in confidence.

Definitions

Maximum
Maximum means that sodium content of all processed foods in each category should fall below those levels by 2016.
Sales Weighted Average (SWA)
The SWA is the average of the sodium levels of all products in a category weighted by their volume market share. The proportion of the market is measured as the kilogram volume sales of product rather than the dollar value. As such, to meet a target a company must reduce the sodium levels in their products in a given category such that the weighted average is equal to or lower than the SWA target.

Note that the targets were developed based on Nutrition Facts table sodium declarations which are subject to rounding rules and regulatory compliance tolerances.

New Request for Industry Feedback

Health Canada is again seeking industry feedback on the proposed sodium reduction targets, this time relating to both the Group I and II prepackaged processed food categories.

Please refer to the draft targets set out in Appendix A, and submit your responses to the questions below by January 31, 2011. Feedback is required by this date to allow sufficient time for Health Canada's review of responses, and to allow for the finalization of targets for all food categories by the end of March 2011.

Health Canada will be holding a webinar on January 14, 2011, to provide an overview of the proposed targets and answer questions. If you are interested in registering for the webinar, please email us at sodium@hc-sc.gc.ca.

Following the webinar, representatives from Health Canada will also be available to meet upon request during the month of January - either by teleconference or in person in Ottawa - to discuss issues related to the draft targets.

Please send your meeting request to sodium@hc-sc.gc.ca.

Please note that no submissions of information or comments will be attributed to a specific person or company/association without prior consent, and that no identified Confidential Business Information will be released under any circumstance.

Feedback Questionnaire on Proposed Sodium Reduction Targets

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Please return your completed Feedback Questionnaire by January 31, 2011. Submissions are absolutely necessary by this date to allow us sufficient time to finalize targets by the end of March. Earlier responses would be greatly appreciated to accelerate the review process.

Responses can be emailed to sodium@hc-sc.gc.ca or faxed to 613-941-6636 (Attn.: Sodium)

  • Respondent Name:
  • Company or Organization:
  • Address:
  • City:
  • Province:
  • E-mail:
  • Telephone #:
  • Affiliation:
    • Food Industry Association
    • Private Company
    • Health Non-Governmental Organization
    • Consumer Group
    • Academia/Research
    • Government
    • Health Professional
    • Private Citizen
    • Other (please specify)

Appendix A lists the Draft Sodium Reduction Targets for prepackaged foods by Food Category. Note that foods prepared by restaurants and foodservices are not included as these will be addressed at a later date.

Questions by food category

  1. Please list all Food Categories that apply to products manufactured, imported and/or distributed by your company and provide examples of products for each category.

    For each of the corresponding Food Categories, please answer the following questions and include any relevant details where applicable. (If you submitted feedback on a category in a previous consultation and there is no change to your comment, please do not re-submit the information but make note of your previous submission beside the category.)

  2. Does salt and/or sodium play a functional role in this product category or in specific products within this category other than taste? If so, please elaborate.
  3. Is the proposed 2016 sodium reduction target, set as a maximum, achievable by 2016?
    1. If so, would you be able to achieve still greater reductions? Please elaborate.
    2. If not, please explain why the target is not achievable (e.g. technical or flavour reasons, food safety concerns, too big a change too quickly), and explain what target you would consider achievable.
    3. Are there any tools or resources that could be developed to help you achieve the 2016 sodium reduction targets?
  4. For the purpose of establishing step-wise reductions and for monitoring progress in sodium reduction, we have proposed interim milestones as sales weighted averages (SWA) to be achieved by the ends of 2012 and 2014 respectively, leading to the final targets to be achieved by the end of 2016. In general, the interim milestones reflect a step-wise, equally spaced reduction for each time point toward the 2016 goal. However, in a number of cases, individual decisions were made to reflect the characteristics of the category. These decisions were based on feedback received from industry with regards to technical challenges that exist for certain categories of food.
    1. Are the proposed 2012 and 2014 milestones achievable? Please elaborate.
    2. Should interim milestones for this category represent an equal % reduction every two years? If not, please explain why and what you propose instead.
  5. Have you already lowered the sodium in this product category or in specific products within this category? If so, please provide details on what sodium reductions have been achieved and when.

General Questions

  1. Do you determine the sodium level declared in the Nutrition Facts table of your products by:
    • Lab analysis?
    • Calculation (using the sodium content information for each ingredient as provided by the ingredient supplier)?
    • Calculation (using software and pre-existing databases)?
    • Other methods? Please explain.
  2. Should any of the listed food categories be modified (e.g., could some foods be grouped together to reduce the number of food groups)?
  3. Are any food categories missing and if so, could targets from existing similar food categories be applied?
  4. Are there research gaps that prevent your company/industry from reducing sodium in the foods you manufacture or distribute? If so, please identify these gaps.
  5. Do you plan on promoting your sodium reductions? If so, please provide details on how you intend to do so.
  6. Do you have any further comments or suggestions on:
    1. How to effectively reduce the sodium content of the diets of Canadians?
    2. How the food industry can be supported in reaching the proposed sodium reduction targets?

Monitoring and Evaluation

  1. Health Canada is considering the development of a commitment website that would showcase companies' commitment to, and progress towards, meeting the sodium reduction targets.
    1. Would your company be willing to publicly commit to meeting the interim milestones and/or 2016 targets?
    2. Do you have any suggestions on the wording or structuring of a commitment template that would be used to gather information for this website?
    3. Are there any other considerations that Health Canada should take into account in setting up this program?
    4. If your company signs up to the commitment program, would you be willing to provide update reports that indicate your progress towards meeting the targets?
  2. Health Canada intends to collect label information to measure progress towards the 2012 and 2014 milestones in a manner similar to the data collection undertaken to establish the baseline values in 2009-2010.
    1. Are there mechanisms that could be put in place for your company to share information with Health Canada on the sodium levels in your products? Please elaborate.
    2. What is the most effective way for Health Canada to obtain this information from you?
  3. Do you have any further comments or suggestions on:
    1. How to obtain commitment from the food industry on meeting sodium reduction targets?
    2. Monitoring and evaluation of the implementation of the sodium reduction targets?

Thank you for taking the time to respond to this questionnaire.