FDA Sodium Targets by Food Category Explained
Learn how FDA sodium targets work by food category, including Phase I, the Phase II draft, upper bounds, target means and product comparisons.
FDA sodium targets are voluntary concentration goals set for food categories, not mandatory sodium limits for individual products. FDA publishes a sales-weighted mean target and an upper bound for each covered subcategory, both expressed as milligrams of sodium per 100 g of food.
That distinction matters when a customer or buyer asks whether your product "meets the FDA sodium target." A single product cannot meet or miss a category mean in the same way it can pass or fail a regulated nutrient content claim.
This article explains how the category system works, how many categories it covers, what Phase I finalized and what the Phase II draft proposes, what the numbers mean for an individual product, and how to identify your category. For the broader picture, including binding sodium claim definitions and Nutrition Facts rules, see FDA sodium reduction targets. Everything below is voluntary guidance. None of it creates a labeling obligation.
How FDA sodium targets by food category are built
For each food subcategory, FDA publishes two numbers. Both are expressed as milligrams of sodium per 100 g of food.
- A sales-weighted mean target. This is the average sodium concentration FDA would like the category to reach, weighted by sales volume. High-volume products therefore count more in the average than low-volume specialty products. It is a statistic about a market, not a specification for one product.
- An upper bound concentration. This number addresses the high end of the category, meaning products with sodium concentrations well above others in the same category. It is the closest thing in the guidance to a per-product figure, but it is still voluntary.
Two structural points are especially important.
First, FDA sodium targets are concentrations, not per-serving amounts. The guidance states them per 100 g of food so products with different serving sizes can be compared on the same basis. Your Nutrition Facts panel declares sodium per labeled serving. You therefore cannot compare the two directly without converting your product data.
A category target also does not tell you what sodium number should appear on your Nutrition Facts panel.
Second, one product cannot meet or miss a mean target by itself. A mean is a property of a group. Some products will be above it and some below it. What FDA is asking to move is the sales-weighted average of the category.
How many food categories do the FDA voluntary sodium targets cover?
Phase I established targets for 163 food subcategories. Phase II covers the same 163 subcategories of commercially processed, packaged and restaurant-prepared foods.
Those 163 subcategories are commonly described as falling within 16 overarching categories. Be careful with that second figure. It appears widely in trade and law firm summaries but does not come from the guidance text itself. If you are completing a specification or customer questionnaire, 163 subcategories is the figure to cite.
The phrase "restaurant-prepared" also matters. The guidance is not limited to packaged retail foods. That broader scope explains why some subcategory names describe a preparation rather than a type of package.
Phase I and Phase II FDA sodium targets: final versus draft
Phase I and Phase II are sometimes discussed as though they were one changing requirement. They are separate documents at different stages, and only Phase I is currently final guidance.
| Phase I (Edition 1) | Phase II (Edition 2) | |
|---|---|---|
| Status | Final guidance, voluntary | Draft guidance, voluntary |
| Issued | October 2021 | 15 August 2024, Federal Register notice 16 August 2024 |
| Intake goal | About 3,000 mg per day, from a baseline of about 3,400 mg, roughly a 12 percent reduction | About 2,750 mg per day, roughly 20 percent below the pre-Phase I baseline |
| Timeframe | Two and a half years from issuance, so roughly April 2024 | Three years after finalisation, a clock that has not started |
| Subcategories | 163 | 163 |
The Phase I document is titled "Voluntary Sodium Reduction Goals: Target Mean and Upper Bound Concentrations for Sodium in Commercially Processed, Packaged, and Prepared Foods." The word voluntary is part of the title itself, which is useful when a customer or buyer mistakenly treats the targets as a regulatory requirement.
Comments on the Phase II draft were originally due 14 November 2024 and were extended to 13 January 2025. The draft has not been finalized.
FDA's guidance page states that once Edition 2 is finalized, it will replace Edition 1. Until that happens, the Phase I category numbers are the operative guidance, while the Phase II numbers remain proposed targets that should not be treated as settled.
FDA's 2026 Human Foods Program priority list and guidance agenda do not name sodium targets among the 2026 deliverables.
There is also evidence available on progress. FDA's 2022 data assessment found that roughly 40 percent of the Phase I targets had been reached or were within 10 percent. FDA said it would reassess progress about every three years.
A July 2026 conference analysis presented at NUTRITION 2026, which was not peer reviewed, reported little measurable effect of the 2021 targets on new product launches across nine categories. It reported sodium concentrations rising in dry soups, popcorn, breads and corn snacks.
What an FDA sodium target says about your individual product
A category target is not a per-product sodium cap. There is no sodium number that your product can exceed and thereby breach the voluntary guidance.
For an individual product, the two numbers have different meanings:
- The mean target is not a product limit. It describes where the sales-weighted average of the entire category should land. Individual products above the mean are expected because some products must sit above an average.
- The upper bound is more relevant to an individual product. It identifies products at the high end of the category's sodium distribution. If your product is above it, that is useful commercial information because your product is an outlier within the category. It is still not a legal limit, and exceeding it does not make a product misbranded or adulterated.
The Phase II draft provides an example that shows how the numbers work. Flavored potato and vegetable chips have a target mean of 480 mg of sodium per 100 g and an upper bound of 670 mg per 100 g.
Those are the only illustrative target values quoted here because they are the only pair carried in the source used for this article. The remaining values for the 163 subcategories are in the guidance document itself, which is where you should obtain the number for your own product category.
The conversion also shows why these numbers should not be confused with Nutrition Facts values or sodium claims.
At 480 mg per 100 g, a 50 g portion contains 240 mg of sodium. At 670 mg per 100 g, the same 50 g portion contains 335 mg.
Both are well above the 140 mg threshold that 21 CFR 101.61 sets for a "low sodium" claim on an individual food. That claim applies per reference amount customarily consumed and, when the reference amount is 30 g or less or 2 tablespoons or less, per 50 g as well.
A product sitting exactly at its category target mean can therefore be an ordinary product that cannot truthfully call itself low sodium. The voluntary category targets and regulated nutrient content claims are different systems and are not calibrated to each other.
You can check where a candidate claim lands with the claim validator.
How to find your FDA sodium target food category
The category tables are in the guidance documents, not the Code of Federal Regulations. There is therefore no CFR section you can use to look up your target. Finding the right subcategory is a matching exercise.
- Start with the food, not the brand. Subcategories are based on what the food is and how it is prepared. Describe the product as a food technologist would, such as a flavored extruded corn snack, a shelf-stable soup concentrate or a cured sliced meat.
- Decide where you fall within the retail and foodservice scope. Phase II covers commercially processed, packaged and restaurant-prepared foods. Some categories describe a preparation rather than a package.
- Convert your sodium value to mg per 100 g before comparing it. If your analytical data is per serving, divide the sodium amount by the serving weight in grams and multiply by 100. Comparing a per-serving figure directly with a per-100 g target is a common arithmetic error and will usually make the product look better than it is. The RACC lookup gives you the reference amount your serving size is built from if you need to work back to a gram weight.
- Accept that some products have no matching category. The 163 subcategories provide broad coverage, but they are not universal. If your product does not match a subcategory, there may be no FDA sodium target to compare it with. That is an acceptable answer on a customer questionnaire.
- Record the subcategory and why you selected it. Keep a one-line record of your category match and the date of the guidance edition you used. If a buyer asks again later, you will not need to repeat the matching exercise.
Multi-component products are more difficult. A frozen meal containing sauce, starch and protein, for example, might plausibly fit a composite category or several component categories. Choose the category that best describes the food as sold, and document the alternative you considered and rejected.
FDA voluntary sodium targets do not create labeling obligations
FDA voluntary sodium targets do not change what must appear on your food label. There is no target disclosure to add, no symbol or statement to print, and no target-related record you are required to keep.
A product that ignores the voluntary guidance entirely carries the same required label as a product reformulated to sit below its category upper bound.
The binding requirements for sodium come from regulation rather than the voluntary target guidance:
- Declaring it. Sodium is a mandatory line on the Nutrition Facts panel. Under 21 CFR 101.9(c)(9), it is stated in milligrams per serving with a percent Daily Value based on 2,300 mg for adults and children 4 and older.
- Rounding it correctly. Under 21 CFR 101.9(c)(4), sodium is declared as zero when a serving contains less than 5 mg, to the nearest 5 mg increment from 5 to 140 mg, and to the nearest 10 mg increment above 140 mg. The rounding rules apply the same way regardless of your category target.
- Declaring it accurately. Under 21 CFR 101.9(g)(5), a food is misbranded if the sodium content of the composite is more than 20 percent in excess of the value declared on the label, subject to analytical method variability. This is an enforceable sodium number associated with your label, and it is separate from the voluntary targets.
- Meeting the requirements for any sodium claim you make. The definitions in 21 CFR 101.61 for sodium free, very low sodium, low sodium, reduced sodium and other sodium claims are binding. If you print one of these claims, the food must meet its definition.
The practical distinction is that FDA sodium targets are voluntary category-level goals, while sodium declaration, rounding, accuracy and nutrient content claims are regulated labeling requirements.
Retail buyers and foodservice specifications may reference the voluntary targets, which gives you a commercial reason to know your category and sodium concentration. Once you have a sodium figure you trust, build the panel it belongs on with the nutrition label generator, which handles the per-serving conversion and 101.9(c)(4) rounding for you.
Frequently asked questions about FDA sodium targets
Are the FDA sodium targets mandatory for my food category?
No. The FDA sodium targets are voluntary guidance. Phase I is final guidance, which describes the status of the document rather than creating a mandatory product limit. Phase II is still a draft issued on 15 August 2024. A product is not misbranded merely because its sodium concentration sits above a category target, and missing a target does not itself trigger enforcement.
How many food categories do the sodium targets cover?
The FDA sodium targets cover 163 subcategories in both Phase I and the Phase II draft. The subcategories are often described as grouped into 16 overarching categories, but that grouping figure comes from secondary summaries rather than the guidance text itself. If you need to state the scope in a specification or questionnaire, 163 subcategories is the figure to use.
My product is above the target mean for its category. Is that a problem?
Not in a regulatory sense. The mean target describes where the sales-weighted average of an entire food category should land, so individual products can sit above it. The upper bound is more relevant when assessing whether an individual product is unusually high within its category, but even exceeding the upper bound carries no legal consequence under the voluntary guidance.
Why are FDA sodium targets in mg per 100 g when my label is per serving?
Because concentration allows products with different serving sizes to be compared on the same basis. Before comparing your product with an FDA category target, convert your sodium data to mg per 100 g. Comparing a per-serving sodium value directly with a per-100 g target uses different measurement bases and will usually make your product appear lower in sodium than it is.
Does meeting my category target let me say "low sodium" on the package?
No. "Low sodium" is defined in 21 CFR 101.61 as 140 mg or less per reference amount customarily consumed, with an additional per 50 g test when the reference amount is 30 g or less or 2 tablespoons or less. FDA sodium targets are voluntary category concentration goals. The claim definition is a binding test applied to an individual food.
Should I reformulate now for Phase II or wait?
That is a commercial decision, not a compliance requirement. Phase II remains draft, and its three-year timeframe starts only once it is finalized. FDA's 2026 priority list does not identify sodium targets among that year's deliverables. FDA's 2022 assessment, however, found that roughly 40 percent of Phase I targets had already been reached or were within 10 percent.
Where do I get the actual FDA sodium target for my subcategory?
Get the target from the applicable FDA guidance document. The category tables are published as part of the sodium reduction guidance rather than codified in the Code of Federal Regulations, so there is no CFR section containing your category target. Read the relevant subcategory line from the edition you are using and record that edition with your product specification.
