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Salt Claims Made on Foods

Labelling of food is governed by the general labelling legislation Directive 2000/13/EC . This prohibits labelling which misleads the consumer to a material degree. Specifically in the context of claims, it also prohibits labelling which suggests that a foodstuff possesses special characteristics when in fact all similar foodstuffs possess such characteristics. Therefore, for example low salt claims on foods which are naturally low in salt are not allowed unless the claim clearly communicates the fact that all other similar foodstuffs are also low in salt.

In addition to the requirements of the general labelling legislation Directive 2000/13/EC, claims on foodstuffs that concern salt are now also governed by Regulation (EC) 1924/2006 of the European Parliament and of the Council of 20 December 2006 on nutrition and health claims made on food. 

It is strongly recommended that food business operators wishing to make claims familiarise themselves with Regulation (EC) 1924/2006 in its entirety.

What nutrition claims can I make about salt?

Nutrition claims for salt are permitted, but the amounts mentioned shall be those of the food as sold. Where appropriate, this information may relate to the foodstuff after preparation, provided that sufficiently detailed preparation instructions are given e.g. salt claims for dried soups should be made about the product in its re-hydrated ready-to-eat form.

Article 8 restricts salt claims to those listed in the Annex to Regulation (EC) 1924/2006 and relevant claims and conditions of use are as follows:

LOW SODIUM/SALT: A claim that a food is low in sodium/salt, and any claim likely to have the same meaning for the consumer, may only be made where the product contains no more than 0.12g of sodium, or the equivalent value for salt [0.3g] per 100g or per 100ml. For water, other than natural mineral waters falling within the scope of Directive 80/777/EEC, this value should not exceed 2 mg [0.002g] of sodium per 100ml.

VERY LOW SODIUM/SALT: A claim that a food is very low in sodium/salt, and any claim likely to have the same meaning for the consumer, may only be made where the product contains no more than 0.04g of sodium, or the equivalent value for salt [0.1g] per 100g or per 100ml. This claim shall not be used for natural mineral waters and other waters.

SODIUM FREE or SALT FREE: A claim that a food is sodium-free or salt-free, and any claim likely to have the same meaning for the consumer, may only be made where the product contains no more than 0.005g of sodium, or the equivalent value for salt [0.0125g], per 100g.

REDUCED [SODIUM/SALT]: A claim stating that the content in [sodium/salt] has been reduced, and any claim likely to have the same meaning for the consumer, may only be made where the reduction in content is at least 25% compared to a similar product.

However, note that article 9 restricts comparative claims like ‘reduced salt’–

“…. a comparison may only be made between foods of the same category, taking into consideration a range of foods of the same category. The difference in the quantity of a nutrient and/or the energy value shall be stated and the comparison shall relate to the same quantity of food”.

Therefore, to make a comparative claim for salt e.g. “reduced salt rashers”, the product in question must be reduced in comparison with a range of similar non-salt reduced products from different brands.

NATURALLY/NATURAL: Where a food naturally meets the conditions laid down in the Annex to the Regulation for the use of a nutritional claim, the term ‘naturally/natural’ may be used as a prefix for the claim. E.g. if a food naturally has a salt content less than 0.3g then it could bear the claim “Naturally Low Salt”.

NOTE ON USE OF NUTRITION CLAIMS: In order to comply with the general labelling legislation Directive 2000/13/EC, as stated at the start of this section, a salt claim would have to be worded so that it did not imply that the product was any different to similar products on the market. This applies in particular to foods that naturally meet the conditions of any of the claims in the annex to the Regulation. Hence, “lettuce is naturally low in salt” or “lettuce is low in salt” would be an legal claim but not “our lettuce is naturally low in salt” or “brand name lettuce is low in salt” since the latter wording implies that other lettuce is not low in salt and breaches the general labelling legislation.

For other allowed claims and conditions refer to Regulation (EC) 1924/2006

When do foods have to comply with Regulation (EC) 1924/2006?

Regulation (EC) 1924/2006 applies from the 1 st July 2007 . Article 28 allows foods that are placed on the market or labelled prior to 1 st July 2007 which do not comply with the Regulation to be marketed until their expiry date, but not later than 31 st July 2009 . Foods labelled and place on the market after 1 st July 2007 must comply with the nutrition labelling requirements of the Regulation unless otherwise derogated.

Brand names and trade marks of products that make or imply a claim are no longer allowed unless the food complies with the provisions of the Regulation. However, products bearing trade marks or brand names existing before 1 st January 2005 which do not comply with the Regulation may continue to be marketed until 19 th January 2022 after which time the provisions of the Regulation apply.

Future work on the Regulation will bring in nutrition profiles. By 19 th January 2009 the Commission and Member States must establish the nutrient profiles that are acceptable for foods that bear claims. There are two derogations. Firstly foods referring to reduced sodium/salt shall be allowed to bear that claim without reference to the nutrient profile for sodium/salt. However, the other nutrients in the salt reduced food must meet the nutrient profile. Secondly, nutrition claims can be made on a food where one of its nutrients exceeds the nutrient level set in the nutrient profile providing that a statement appears wit the claim that the product is ‘High’ in that particular nutrient. Foods bearing claims will not have to meet the nutrient profile until 24 months after their adoption which at the latest will be around January 2011 but could be sooner if the nutrient profiles are adopted before the latest date of 19 th January 2009 .

NOTE ON USE OF NUTRITION CLAIMS: Any nutrition claim made on a food means that the food business operator must apply a nutrition panel to the product in the group 2 format as laid down in Directive 90/496/EEC. This includes the requirement to label sodium content. In addition if the claim is for salt rather than sodium then the amount of salt to which the nutrition claim relates shall also be stated in the same field of vision as the nutrition information and be expressed in accordance with Article 6 of Directive 90/496/EEC.

FSAI would consider the labelling of ‘salt equivalents’ in g per 100g or ml under the nutrition panel where the sodium value is multiplied by 2.5, as meeting this requirement. This is also recommended but is not required in law) for claims involving sodium, to help the consumer to clearly understand the sodium claim.

Other Salt Labelling

The European Communities (Nutrition Labelling for Foodstuffs) Regulations, 2005 (S.I. No. 65 of 2005) regulates nutrition claims on food labels and sets out the format for nutrition labelling. Nutrition labelling is voluntary but is compulsory where a nutritional claim is made on the label. However, if a label carries nutrition labelling, even when it is not required, it must comply with the Regulations.

Where a nutrition claim is made for sodium, the information layout required is referred to as Group 2 in the Regulation and is as follows:

Nutrition Information Per 100g Per serving (40g)
Energy 1150kj/270kcal

700kj/170kcal

Protein

13g

9g

Carbohydrate

(of which sugars)

46g

(18g)

25g

(14g)

Fat

(of which saturates)

3.5g

(0.6)

3.5g

(1.5g)

Fibre 29g 12g

Sodium

0.9g

0.4g

The FSAI would like the food industry, on a voluntary basis to label 'salt equivalents' in the same field of view as the nutrition panel. 

Last reviewed: 20/3/2009

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