The Proposed Front-of-Package Sodium Label
FDA has not changed the front of your package. It has proposed a Nutrition Info box at 90 FR 5426 with Low, Med and High sodium bands. What the bands would mean in milligrams, why serving size decides them, and which sodium rules bind you today.
Almost every question about the front of package nutrition label sodium rule starts from the same wrong premise: that it exists. It does not. FDA published a proposed rule on 16 January 2025 at 90 FR 5426, docket FDA-2024-N-2910, that would create a new 21 CFR 101.6 and require a small monochrome "Nutrition Info" box on the front of most packaged foods. The box would carry three nutrients, and sodium is the middle one. None of it binds anyone, and no packaged food sold in the United States carries it today.
This article covers the sodium half of that proposal: how the box would sort a product into Low, Med or High, what those bands work out to in milligrams per serving, and why the band depends as much on serving size as on recipe. It also separates the proposal from the sodium rules that bind you now, the nutrient content claim definitions in 21 CFR 101.61. For the whole box rather than the sodium row, see FDA front-of-package nutrition label, and for scope and exemptions, front-of-package label requirements.
How the proposed front of package nutrition label sodium bands would work
The box is deliberately small. Proposed 101.6(a)(2) would put the heading "Nutrition Info" across the top in the largest type in the box, two column subheadings reading "Per serving" with the household measure in parentheses and "% Daily Value," then three nutrients in a fixed order: Saturated Fat, Sodium, Added Sugars. A banner at the bottom carries an FDA.gov attribution. Calories would not appear, and proposed 101.6(a)(4) would bar anything else from the box.
Each nutrient row would carry two things: the numeric percent Daily Value, and to its right one interpretive word. For sodium that word would be Low, Med or High. Proposed 101.6(a)(2)(iv) sets the cut points in percent Daily Value:
- Low: 5% DV or less.
- Med: 6% to 19% DV.
- High: 20% DV or more.
The proposal invents no new number. The percentage it would use is the one you already calculate and round for the Nutrition Facts panel under 101.9(c)(9) and 101.9(d)(7)(ii); FDA said it does not address calculation or rounding considerations because the existing rules cover them. The box would be a second presentation of a figure already on your label, plus one word.
It would also not be colour-coded. The proposal specifies all black or one colour of type and hairlines on a white or other neutral contrasting background, one easy-to-read type style, at least 8 point and no smaller than the net quantity declaration required by 21 CFR 101.7(h) and (i), in the upper third of the principal display panel. Whatever the colour mockups online suggest, it is not a traffic light scheme.
What Low, Med and High work out to in milligrams
The sodium Daily Value in 21 CFR 101.9(c)(9) is 2,300 mg for adults and children 4 and older, and the proposed box covers only foods marketed to that population. Converting the bands is one multiplication each.
| Band | Percent Daily Value | Sodium per serving |
|---|---|---|
| Low | 5% or less | 115 mg or less |
| Med | 6% to 19% | about 138 mg to about 437 mg |
| High | 20% or more | 460 mg or more |
Those milligram figures are derived arithmetic. The proposal defines the bands in percent Daily Value only, and that percentage is a rounded number, so the real boundary sits slightly off the clean conversion. Sodium amounts round first, under 101.9(c)(4): below 5 mg declare 0, from 5 to 140 mg round to the nearest 5 mg, above 140 mg to the nearest 10 mg. Working from the declared amount, 125 mg is 5.43% and declares as 5%, which is Low, while 130 mg is 5.65% and declares as 6%, which is Med. At the top, 440 mg declares as 19% and 450 mg as 20%. Compute instead from the unrounded analytical amount, which 101.9(d)(7)(ii) equally permits, and the cut lands back on 460 mg. Two manufacturers with the same lab report could legitimately print different words.
Why serving size decides the band as much as the recipe
The band is a per-serving test and says nothing about concentration. Serving size is not a free choice either: it comes from the Reference Amount Customarily Consumed in 21 CFR 101.12(b), converted to a household measure under 101.9(b). The RACC fixes the weight, so the only open question is what concentration it takes to cross 460 mg at that weight.
| Category and RACC | Concentration needed to reach High | Concentration that keeps you at Low |
|---|---|---|
| Snack crackers, 30 g | 1,533 mg per 100 g | 383 mg per 100 g |
| Breads and rolls, 50 g | 920 mg per 100 g | 230 mg per 100 g |
| Bagels, muffins, toaster pastries, 110 g | 418 mg per 100 g | 105 mg per 100 g |
| Yogurt, 170 g | 271 mg per 100 g | 68 mg per 100 g |
Read the first column down and the pattern is plain. A snack cracker has to clear 1,533 mg per 100 g before it shows High, and almost nothing on a shelf does. A bagel needs only 418 mg per 100 g, which is unremarkable bread dough. The categories that would land in High are the heavy-serving ones: bagels and large baked goods, soups, sauces sold by the cup, frozen entrees, canned goods eaten by the cupful. Chips, crackers, nuts and seasonings mostly would not, because their reference amounts are small, even though per 100 g they are among the saltiest things in the store. The Low band runs the same way in reverse: a 170 g yogurt has to come in under 68 mg per 100 g, so heavy-serving products have almost no room at the bottom.
The sodium rules that bind you today: 21 CFR 101.61
While the box remains a proposal, the sodium language you may put on a package is governed by 21 CFR 101.61, and those definitions are final and enforceable now. Under 101.61(a) a sodium or salt claim may only be made if it uses a term defined in that section as defined, meets the general requirements of 101.13, and appears on a food labeled under 101.9, 101.10 or 101.36.
| Claim | Individual foods | Meals and main dishes |
|---|---|---|
| Sodium free, no sodium, zero sodium | Less than 5 mg per RACC and per labeled serving, no sodium-containing ingredient unless asterisked | Less than 5 mg per labeled serving |
| Very low sodium | 35 mg or less per RACC, and per 50 g if the RACC is 30 g or 2 tablespoons or less | 35 mg or less per 100 g |
| Low sodium, low in sodium | 140 mg or less per RACC, and per 50 g if the RACC is 30 g or 2 tablespoons or less | 140 mg or less per 100 g |
| Reduced sodium, less sodium | At least 25 percent less per RACC than a reference food, with the reference food, percent difference and milligram comparison declared; barred if the reference food is already low sodium | At least 25 percent less per 100 g |
| Salt free; unsalted or no salt added | Salt free only if the food is sodium free; unsalted means no salt added to a food normally processed with salt, and if not sodium free it must say so | Same |
Note the number in the low sodium row: 140 mg. That is current law. The same January 2025 proposal would amend 101.61 to lower it to 115 mg or less per RACC, 115 mg per 50 g where the RACC is 30 g or 2 tablespoons or less, and 115 mg per 100 g for meals and main dishes, and would require any food bearing the claim to display Low for sodium in its box. FDA's stated reason is alignment: 115 mg is 5 percent of 2,300 mg, exactly the Low band.
Today the two do not line up. A food at exactly 140 mg per RACC may legally say low sodium, and 140 mg is 6.09 percent of the Daily Value, which declares as 6% and falls in Med. That mismatch is the clearest marker of proposal versus law. If you see 115 mg quoted as the low sodium limit, that is the proposal. Check your claim against the binding 140 mg figure with the claim validator before it goes to print.
How the voluntary sodium reduction targets relate, and why they are a different instrument
The third sodium programme people fold into this is FDA's voluntary sodium reduction goals. The three operate on different objects and carry different force.
| Instrument | Legal force | Measured against | What it controls |
|---|---|---|---|
| Proposed Nutrition Info box | Proposed rule, not in force | Percent DV per labeled serving | What appears on the front panel |
| Sodium claims, 101.61 | Final regulation, binding | Milligrams per RACC, or per 100 g for meals | Whether you may use a phrase like low sodium |
| Sodium reduction goals | Guidance, voluntary | Milligrams per 100 g of food | Nothing on the label; a reformulation goal |
The goals live in guidance, not regulation. Phase I, final guidance issued October 2021, aimed to bring average intake from roughly 3,400 mg per day to about 3,000 mg over two and a half years across 163 food subcategories. A Phase II draft issued 15 August 2024 would push that to about 2,750 mg per day, and Phase II is still draft. Neither edition requires anything of anyone.
The mechanical difference is the denominator. The targets are milligrams per 100 g of food, as a sales-weighted mean per category plus an upper bound for individual products. The box is per labeled serving. Take the Phase II draft target for flavoured potato and vegetable chips, a mean of 480 mg per 100 g and an upper bound of 670 mg per 100 g. At a 30 g serving the mean gives 144 mg of sodium, 6% of the Daily Value, which lands in Med; even the upper bound gives 201 mg, 9%, still Med. The target does real work on concentration while the box, at that serving size, barely moves.
The two are complementary, not translations of each other. A buyer asking about target compliance is asking a per-100-g question about voluntary guidance; a buyer asking what word would appear on your front panel is asking a per-serving question about a rule that does not yet exist. The full picture on the goals is in FDA sodium reduction targets.
Where the rule actually stands
The honest status, because much of the coverage reads as though this were settled. The proposed rule published 16 January 2025 at 90 FR 5426, docket FDA-2024-N-2910, RIN 0910-AI80. The comment period was set to close 16 May 2025 and was extended to 15 July 2025. FDA received tens of thousands of comments and reported widespread support for front-of-package labeling alongside sharply varying views on the box's content and design.
Since then the Spring 2025 and 2026 Unified Agendas listed the rule at Final Rule Stage with a projected final rule date of May 2026. That date passed with nothing published. In January 2026 FDA's Human Foods Program deliverables said it would analyse comments and prepare options for leadership. In March 2026 the Commissioner said publicly that current leadership did not like the plan it had inherited, and the Deputy Commissioner said everything was on the table and that meaningful changes could require re-proposing the rule for a second round of notice and comment. In July 2026 the agenda again listed it as a priority final rule anticipated for the remainder of 2026, with no date committed. As of 21 September 2026 there is no final rule.
If it were finalised as proposed, the compliance clock would run three years from the final rule's effective date for businesses with 10 million dollars or more in annual food sales, and four years for businesses below that. Neither clock has started, because neither can start until a final rule publishes. The sensible posture is to know your sodium percent Daily Value per serving and which band it would fall in, and treat that as intelligence rather than a deadline. To get that number, build the panel first: the nutrition label generator calculates the sodium milligrams and the percent Daily Value per serving that any future box would have to use.
Frequently asked questions
Do I have to put a front-of-package sodium label on my product?
No. The Nutrition Info box is a proposed rule published 16 January 2025 at 90 FR 5426, docket FDA-2024-N-2910. It has not been finalised. No packaged food in the United States is required to carry a front-of-package nutrition box, and no compliance date exists, because the clock only starts once a final rule takes effect.
How much sodium would count as High?
20 percent of the Daily Value or more. Against the 2,300 mg sodium Daily Value in 21 CFR 101.9(c)(9) that converts to 460 mg or more per labeled serving. The proposal defines the band in percent Daily Value only, so computing from the rounded declared amount puts the practical cut between 440 mg, which declares as 19 percent, and 450 mg, which declares as 20 percent.
Is the low sodium limit 140 mg or 115 mg?
140 mg. Under 21 CFR 101.61(b)(4), final and binding today, low sodium means 140 mg or less per reference amount customarily consumed, and 140 mg or less per 100 g for meals and main dishes. The 115 mg figure comes from the January 2025 proposal, which would lower the limit to match the 5 percent Low band. Until a final rule publishes, formulate against 140 mg.
Would the box be colour-coded like a traffic light?
No. The proposal specifies all black or one colour of type and hairlines on a white or other neutral contrasting background, in one easy-to-read type style at 8 point or larger. The Low, Med and High signal would come from the words, not from colour, which distinguishes it from the warning-octagon and colour-coded schemes used in several other countries.
Are the voluntary sodium reduction targets the same as the Low, Med and High bands?
No, and they are not measured the same way. The targets are voluntary guidance written as milligrams per 100 g of food, with a sales-weighted mean and an upper bound for each of 163 subcategories. The proposed bands are a rule, not in force, written as percent Daily Value per labeled serving. A product can meet its category target and still fall in High, or miss it and fall in Med, depending on its reference amount.
Why would salty snacks look better than bread under this scheme?
Because the band is per serving, not per 100 g, and serving sizes come from the reference amounts in 21 CFR 101.12(b). Snack crackers have a 30 g reference amount, so they need more than 1,533 mg of sodium per 100 g to reach High. Bagels and muffins have a 110 g reference amount, so 418 mg per 100 g is enough. The same concentration produces a different word depending entirely on how much counts as one serving.
