Salt reduction targets: salt returns to the forefront of the agenda

2016 was the year in which sugar took prominence in the battle against obesity. 2017 has seen salt return to the forefront of the agenda with Public Health England's (PHE) publication of its 'Salt Reduction Targets for 2017'.

The publication follows targets published previously in 2006, 2009, 2011 and 2014. These were devised in response to advice that a reduction in average adult salt intakes to 6g per day (with lower levels set for children), would lower blood pressure levels and reduce the risk of cardiovascular disease.

The 2017 targets (the 2014 targets were to be achieved by 2017) have been published as part of the wider sugar reduction and reformulation programme (part of the commitment in 'Childhood Obesity: Plan for Action' published in August 2016). As with the Plan for Action (which describes the reduction as a 'challenge' to producers), the targets remain 'aims' and are not mandatory. In this context, research by Consensus Action on Salt and Health suggests that bread rolls are the only manufactured foodstuff likely to meet the salt reduction targets for 2017 which were set in 2014.

The salt reduction targets relate to both individual product categories (focusing on the most popular and highest salt content products) as well as particular meal groups in the 'eating out of home' sector. The focus is on the 10 most popular food groups purchased in the 'out of home' sector with the addition of a specific target for children's meals.

The stated purpose of the targets is to bring the salt content of products in the 'eating out of home' sector in line with the wider food industry, with PHE suggesting that many businesses in the sector have not worked towards achieving the 2017 targets despite the expectation that they should do so. Lobbying from the sector has seen the development of separate targets for eating out which reflects the higher levels of salt in products than those bought to be eaten at home.

The targets include:

• a list of 28 products or product categories perceived as the most popular highlighting the salt target for 2017 against that from 2012;
• meal v dish target – dish target is used for individual dishes which can be served as part of a meal or on its own. Meal target is based around a specific dish but includes sides and accompaniment;
• combination meals – combinations derived from a defined number of sides and accompaniments for a fixed price. Where there are a large number of combinations, a business will apply the targets to combination that customers are likely to make; and
• general exclusions – the targets cover standardised items i.e. reproducible products offered for at least 30 days in a year. Self-service and create your own fall outside the targets.

By way of illustration:

1. 'Meal Target – Sauce based main dishes'

• Curry main meals: Includes all curries of South/Southeast Asian origin (e.g. Indian, Thai) served with side dishes and accompaniments – 4g salt or 1600mg sodium.
• All other sauce based main meals: includes all dishes cooked in a sauce (e.g. chilli con carne, sweet and sour chicken)/excludes sauce based pasta dishes and dishes with a gravy or sauce added after cooking – 3.2g salt or 1300mg sodium.

2. Children's main meals

Includes all main meals aimed primarily at children – 1.8g salt or 720mg sodium.

PHE scientific officers suggest that where a dish does not fit within a 'Meal target', one should look at whether it falls within the general dish target. For example, noodle soups do not fit under a 'meal target' and in the view of PHE come under the Soup category 9.1 of Table 1 (dish target) despite being an eating out of home product. The targets for this category are: 0.53g salt or 210mg sodium (average r) and 0.63g salt or 250mg sodium (maximum).

If a product had a salt content much higher than the maximum target, the view of PHE is to query which component of that product is contributing most to the salt content of the dish. PHE may then recommend that the manufacturer considers the constituent ingredients of the product, and the respective categories that these relate to, rather than one target for the entire dish. For example, for bowl food, the soup component would fit under the soup category and, say, dumplings under category 19.1 "Other cereals" in Table 1. Manufacturers may wish to consider if this would be appropriate for your dishes where it's difficult for them to achieve the target just for e.g. soups.

In terms of a business trying to achieve the salt targets, PHE would recommend that manufacturers' calculate a sales weight average for salt target for their dishes or, if not possible, to calculate a simple average and use this to compare to the average salt target for the relevant category. Where it is difficult for an individual product to meet the targets PHE would suggest using the maximum salt target figure for those.

The aim for a business ought to be for their sales weighted average to meet that target; and for no individual product to exceed the maximum. However, because there can be technical or other difficulties associated with this, businesses can say they have met the target(s) for an individual sub-category if 95% of products or volume sales meet the targets and if efforts have been made to reduce salt in the remaining 5% of products or volume sales to a minimum.

What is clear from the guidance is that there is not (and cannot realistically be) a 'one size fits all' approach (certainly as regards to food targeted at adults). There is recognition at PHE and in Government that, to date, attempts to reduce salt content by reference to targets have been relatively unsuccessful. This is not necessarily because of a lack of will, but rather a lack of realism as to the targets with respect to the eating out of home sector. Even with the inclusion of specific targets directed towards that sector, the guidance we have obtained from PHE is that manufacturers may need to think more laterally and to take a focused approach on the parts of product which are high in salt. The targets remain just that; targets and aims. There is nothing mandatory although since this issue forms part of the wider Plan For Action, future legislation cannot be ruled out.

This article was written by Jamie Cartwright. For more information, please contact Jamie on +44 (0)1483 252618 or at jamie.cartwright@crsblaw.com.