Advocacy: "High Sodium Content" labeling
When foods contain high levels of certain nutrients, they must write "See nutrition information for sodium content."
Recently, I wrote a letter advocating for changes to this. I sent it to the FDA, my State legislature, and my representatives in U.S. Congress.
The Letter
I changed the 2nd paragraph for whom the letter was addressed to
Potential identifying information has been removed
Title 21 of the Code of Federal Regulations has restrictions for what foods can be labeled as "low sodium", and requires unassertive labeling when salt, fat, or other nutrient content is above a certain threshold.
I would like to see more informative and clearer labeling requirements for high nutrient content. Please read my letter below, and please consider preparing and supporting [State] legislation that would seek such changes. Advocating federally would also be great. I have not reviewed State law on this topic. Thank you!
I would like changes to labeling that would add two new rules:
- Above a certain threshold, rather than a "see nutrition [label]", there should be a sodium (or other nutrient) breakdown. This would show sodium-per-serving, sodium-per-container, and % of daily recommended dosage of sodium. For example, a bag of chips with two servings and 200mg sodium per serving should list: 200mg/serving, 400mg/bag, 10% daily recommended dosage per serving. Of course, the details should be modified to be consistent with current medical knowledge, and a more concise labeling format should be determined.
- Above a certain threshold, there should also be a label that lists "high [sodium, fat] content. See nutrition label."
I feel #1 above should be a much lower level, perhaps where heart disease risks begin. I feel #2 should be a higher threshold where heart disease or other health risks are substantive if consumed regularly. I believe a standardized structure, and possibly colors should be used to highlight this important health information.
I do not know what nutrient levels these requirements should be at. That should be determined by medical professionals.
21 CFR 101.13(h)(1) states that if a nutrient level is surpassed, then "food must bear a statement disclosing that the nutrient exceeding the specified level is present in the food as follows: “See nutrition information for ____ content”".
I find this grossly inadequate for communicating health information. I'm [over 30] years old and have never in my life known that "See nutrition information for" labels meant that the product was high in the given nutrient, until I happened upon these rules a couple days ago.
One example product of concern that may give misleading information is Spaghettios bearing the "Healthy Kids" label that boasts about certain nutrients (calcium, percentage of daily vegetables) but does not prominently disclose the sodium content of 1070mg per can or 600mg per 1 cup serving.
Also, I take issue with spaghettios listing one can as more than one serving. But that's a topic for another day.
See https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.13
Thank you for your consideration, [name redacted] [location redacted]