FDA Sodium Reduction Targets: The Complete Guide
FDA's sodium targets are voluntary guidance, not requirements. Phase I, the Phase II draft, the binding sodium claim definitions, and why buyers ask for them anyway.
The FDA sodium reduction targets are probably the most misunderstood item in US food labeling, because the thing everyone calls a target is not a requirement. This guide sets out what Phase I finalised in October 2021, what the Phase II draft issued in August 2024 would ask for, how a category target is written and how to check a product against it, and where sodium genuinely is binding: the claim definitions in 21 CFR 101.61 and the rounding rules in 21 CFR 101.9. It is for a manufacturer or small producer deciding whether reformulation is worth the cost.
Two things it does not do. It does not reproduce the per-category numbers, which sit in FDA sodium targets by food category, and it does not walk the Nutrition Facts sodium line format in detail, which is covered in sodium nutrition label requirements.
Status first: what is binding and what is not
Get this straight first, because trade coverage often blurs it.
- The sodium reduction targets are voluntary guidance: FDA's current thinking on where sodium concentrations in the food supply should land. No manufacturer is legally obliged to hit them, and no product is misbranded for missing one.
- Phase I (Edition 1) was finalised in October 2021. It is final guidance, which still means voluntary. "Final" describes the document, not any obligation.
- Phase II (Edition 2) was issued as draft guidance on 15 August 2024, with the Federal Register notice on 16 August 2024. It remains draft as of September 2026, so it does not represent even FDA's settled thinking, let alone a duty.
- The sodium nutrient content claims in 21 CFR 101.61 are binding. Print "low sodium" on a package and the food must meet the regulatory definition or the label is out of compliance.
- The proposal to move the "low sodium" threshold from 140 mg down to 115 mg is proposed only. It sits inside the front-of-package proposed rule and has not taken effect. The binding definition today is 140 mg.
The practical reading: the targets carry commercial weight, and the claim definitions are law. Confusing the two costs money.
Why FDA is doing this at all
The case FDA makes is a population-level one. Average sodium intake in the United States is about 3,400 mg per day, roughly 50 percent above the recommended limit of 2,300 mg. That gap is not mainly about salt shakers. More than 70 percent of sodium intake comes from commercially processed, packaged and prepared foods, so the sodium a person eats was largely decided by a formulator.
That explains why FDA reached for category targets rather than consumer education. If the sodium is already in the product on the shelf, telling shoppers to eat less salt moves very little.
The 2025-2030 Dietary Guidelines for Americans, released 7 January 2026, keep the same headline number: less than 2,300 mg per day for ages 14 and older, with lower limits for children (under 1,200 mg for ages 1 to 3, under 1,500 mg for 4 to 8, under 1,800 mg for 9 to 13). They also advise avoiding highly processed foods that are salty or sweet. They changed no Daily Value: the DVs in 101.9 are unchanged, and changing them would take rulemaking.
How the FDA sodium reduction targets actually work
There is no single sodium limit. The targets are category-based, the design decision that makes the system workable and also makes it fiddly to apply.
For each food subcategory, FDA publishes two numbers, both expressed as milligrams of sodium per 100 g of food:
- A sales-weighted mean target: the average concentration the category should reach. Because it is sales-weighted, a high-volume product pulls the average harder than a niche one.
- An upper bound concentration: a ceiling for individual products. This is the number that matters most to a single manufacturer, since it identifies outliers.
Phase I set targets for 163 food subcategories. Those are usually described as sitting inside 16 overarching categories, but that grouping figure comes from a law firm summary rather than the guidance document itself, so treat 163 as the number you can rely on and 16 as an approximation. Phase II covers the same 163 subcategories of commercially processed, packaged and restaurant-prepared foods.
Here is a worked example using flavored potato and vegetable chips, the Phase II subcategory named in published summaries, converted to a hypothetical 28 g labeled serving to show how a per-100 g target lands on a panel. Compare it with the sodium line on the potato chips label example.
| Measure | Per 100 g | Per 28 g serving | Declared after rounding | %DV vs 2,300 mg |
|---|---|---|---|---|
| Phase II target mean | 480 mg | 134.4 mg | 135 mg | 6% |
| Phase II upper bound | 670 mg | 187.6 mg | 190 mg | 8% |
A product sitting exactly on the category mean is not automatically a low sodium food: 135 mg per 28 g slips under the 140 mg claim threshold by accident of serving size, not by design. The rounding rules also do real work, since 134.4 mg and 187.6 mg never appear on a label.
What Phase II would ask for
Phase I aimed to bring average intake from about 3,400 mg down to about 3,000 mg per day, roughly 12 percent, over two and a half years from the October 2021 issuance, putting the informal milestone around April 2024.
Phase II sets a lower goal: about 2,750 mg per day, roughly 20 percent below the pre-Phase I baseline, within three years after finalisation. That clock has not started. FDA's guidance page states that once Edition 2 is finalised it will replace Edition 1, so Phase I targets remain the operative set today.
On progress, FDA's 2022 data assessment found roughly 40 percent of the Phase I targets had been reached or were within 10 percent, and FDA said it would reassess about every three years. A July 2026 conference analysis presented at NUTRITION 2026, not peer reviewed, reported little measurable effect of the 2021 targets on new product launches across nine categories, with sodium rising in dry soups, popcorn, breads and corn snacks. Comments on the Phase II draft closed 13 January 2025 after an extension from 14 November 2024. FDA's 2026 Human Foods Program priority list and guidance agenda do not name sodium targets among the 2026 deliverables, the clearest available signal that finalisation is not imminent.
The binding part: sodium claim definitions in 21 CFR 101.61
This is the section that can make a label unlawful. Every definition below is current and enforceable. Individual food criteria are per RACC, with a per 50 g test when the RACC is 30 g or less or 2 tablespoons or less. Meals and main dishes are judged per 100 g.
| Claim | Individual foods | Meals and main dishes |
|---|---|---|
| Sodium free, no sodium, zero sodium | Less than 5 mg per RACC and per labeled serving, with no added sodium chloride or sodium-containing ingredient unless asterisked as adding a trivial amount | Less than 5 mg per labeled serving |
| Very low sodium | 35 mg or less per RACC | 35 mg or less per 100 g |
| Low sodium, low in sodium, little sodium, low source of sodium | 140 mg or less per RACC | 140 mg or less per 100 g |
| Reduced sodium, less sodium, lower sodium | At least 25% less per RACC than an appropriate reference food; must state the reference food, percent reduction and actual mg comparison; not allowed if the reference food already qualifies as low sodium | At least 25% less per 100 g |
| Light in sodium, lite in sodium (101.56) | At least 50% less sodium than the reference food | Same test, on a per 100 g basis |
| Lightly salted (101.56(g)) | 50% less sodium added than normally added to the reference food; if not low sodium, must say so | Same principle |
| Salt free | Permitted only if the food also qualifies as sodium free | Same |
| Unsalted, no salt added, without added salt | No salt added in processing, and the food it resembles is normally processed with salt; if not sodium free, must state that it is not a sodium free food, or not for control of sodium in the diet | Same |
The last two are the ones people get wrong. "No salt added" and "unsalted" are process claims, not level claims. They say nothing about how much sodium the food contains, which is why the regulation forces the disclaimer when the product is not sodium free. A no-salt-added canned bean with naturally occurring sodium is a legitimate no-salt-added product and is still not a low sodium one. Run a candidate claim through the claim validator before it goes on artwork.
Sodium on the panel: Daily Value and rounding
The sodium Daily Value is 2,300 mg for adults and children 4 and older. For children 1 through 3 it is 1,500 mg, which matters if you make toddler food, because the same milligram count produces a much larger %DV. Infant labels carry no sodium %DV at all.
Rounding under 21 CFR 101.9(c)(4) works in three bands:
- Less than 5 mg: declare 0 mg.
- 5 to 140 mg: round to the nearest 5 mg.
- More than 140 mg: round to the nearest 10 mg.
The %DV is calculated against 2,300 mg to the nearest whole percent. The band boundary at 140 mg is no accident: it lines up with the low sodium claim threshold, so products near a claim decision get finer resolution. The DV calculator handles rounding and percentage together, and the FDA Daily Value chart covers where 2,300 mg comes from.
Why voluntary sodium targets still matter commercially
Treating voluntary as optional is the expensive mistake. Two forces turn these targets into something like a specification.
The first is procurement. Retailers and institutional buyers increasingly write sodium ceilings into supplier specifications, and the FDA category numbers are the obvious reference point: public, category-specific and neutral. A target FDA cannot enforce becomes a term a customer enforces by contract.
The second is the front-of-package proposed rule. Sodium is one of its three nutrients, alongside saturated fat and added sugars, and each would carry an interpretive word: Low at 5% DV or less, Med at 6 to 19% DV, High at 20% DV or more. In sodium terms that puts the High line at 460 mg or more per serving and the Low line at 115 mg or less. Nothing about that box is in force, and FDA leadership signalled in March 2026 that significant changes, including a possible re-proposal, are on the table. But it tells you which side of 460 mg a formulator would rather be on, and reformulating twice is worse than reformulating once. See the FDA front-of-package nutrition label proposal, and what counts as high sodium on a nutrition label for the consumer-facing version of the same arithmetic.
A practical check for manufacturers
Working out where a product sits takes four steps.
- Find the right subcategory. With 163 of them, close is not good enough, and a product that could plausibly sit in two may face two different ceilings. Pick the one matching how the product is formulated and sold, and write down why.
- Convert your data to mg per 100 g. Divide the sodium in milligrams by the gram weight and multiply by 100. Use the unrounded analytical value, not the rounded label declaration.
- Compare against the upper bound first, then the mean. The upper bound tells you whether you are an outlier. The mean is a category-level goal, so one product above it is not necessarily a problem, especially for a small producer whose volume barely moves the average.
- Re-run the claim tests separately. Hitting a category target says nothing about whether you can claim "low sodium." Different denominators, per 100 g versus per RACC.
Reformulation levers
The options are limited, and each has a labeling consequence.
- Stepwise salt reduction. Cutting sodium gradually across production runs is the standard approach, and changes no other label element.
- Partial replacement with potassium chloride or other mineral salts. This changes the ingredient statement and, at meaningful levels, the potassium declaration. Potassium is mandatory on the current panel, so this is a relabeling event, not just a formula change.
- Reworking sodium-bearing functional ingredients. Sodium arrives through leavening agents, phosphates, preservatives and flavor systems, not only salt. In some products these contribute more than the added salt, and are easier to trim without perceived flavor loss.
- Do not reach for serving size. Serving sizes are set by RACC in 21 CFR 101.12 (see FDA serving size requirements), so you cannot shrink a serving to improve the sodium figure, and the per 100 g targets are immune to that trick by design.
Once the sodium number is settled, the panel is the easy part. Build the Nutrition Facts label, with correct sodium rounding and %DV, in the label generator, and check any sodium claim against the current 101.61 definitions with the claim validator before artwork goes to print.
Frequently asked questions
Are the FDA sodium reduction targets mandatory?
No. They are voluntary guidance. Phase I is final guidance issued in October 2021; Phase II is still draft as of September 2026. Exceeding a target does not make a food misbranded. What is mandatory is the sodium declaration on the Nutrition Facts panel and the claim definitions in 21 CFR 101.61.
Has the low sodium threshold changed to 115 mg?
No. The binding definition of "low sodium" is still 140 mg or less per RACC. The 115 mg figure appears in the front-of-package proposed rule, which would align the claim with the proposed Low band of 5% DV. That proposal has not been finalised, so 115 mg has no legal effect. On a long development cycle it is reasonable to design toward 115 mg as insurance, while labeling against the 140 mg rule actually in force.
What are the FDA sodium reduction targets 2026 status and next steps?
As of September 2026, Phase I remains the operative guidance and Phase II (Edition 2) is still a draft. FDA's guidance page states that Edition 2 will replace Edition 1 once finalised, but no finalisation date has been announced, and sodium targets do not appear among FDA's 2026 Human Foods Program priority deliverables or on its 2026 guidance agenda.
Does hitting a category target let me say the product is low sodium?
Not by itself. Category targets are expressed in mg per 100 g. The low sodium claim is tested per RACC, or per 50 g when the RACC is 30 g or less or 2 tablespoons or less, and per 100 g for meals and main dishes. Depending on serving weight, a product can sit under its category upper bound and still be nowhere near 140 mg per serving, or the reverse.
Do the sodium targets cover restaurant food?
Yes. Both editions address commercially processed, packaged and prepared foods, and Phase II explicitly covers restaurant-prepared foods across its 163 subcategories. That scope follows from the rationale: more than 70 percent of sodium intake comes from these sources, so a packaged-grocery-only program would miss much of the problem.
