Salt Substitutes in Standardized Foods
Can food makers use salt substitutes in standardized foods now?
Not yet, in the US. FDA published the final rule allowing salt substitutes in standardized foods on October 13, 2026 (91 FR 65040), but it takes effect on December 14, 2026. [1] Until then the current 21 CFR standards of identity apply. Most of them do not allow salt substitutes. A few already do, such as the low-sodium cheese standards.
Approach: I checked the current eCFR food standards (21 CFR Parts 100-169) and the FDA Federal Register records, then read the final rule on GovInfo and FDA's announcement.
What the final rule does
- It adds a new subpart C, "Flexibility in Standardized Foods," to 21 CFR Part 130. New §130.30(c)(1) defines a salt substitute as "a safe and suitable ingredient (or combination of safe and suitable ingredients) that is used to replace some or all of the added salt (sodium chloride), to reduce sodium in the food, and that serves the functions of salt in the food" (Federal Register PDF, p. 65055).
- §130.30(b) adds a condition: the substitute "must not change the basic nature and essential characteristics of the food."
- The rule names no specific ingredients. Potassium chloride, yeast extracts, MSG, amino acids and dairy extracts are discussed only as possibilities.
- It amends 80 standards of identity across Parts 131-169 (dairy, cheese, bakery, cereal flours, pasta, canned fruits and vegetables, seafood, cacao, margarine, sweeteners, dressings and others). [1]
- FDA says 139 standards allowed or required salt but did not permit salt substitutes before this rule (FDA constituent update, Oct 9, 2026).
- Using salt substitutes is voluntary. FDA estimates no regulatory costs.
Conditions that still apply
- Safety: the rule does not approve any ingredient or exempt it from food additive rules. A substitute must be an approved food additive or GRAS for that use, and used at a level no higher than necessary (§130.3(d)).
- Labeling: there are no new labeling requirements. Substitutes go in the ingredient statement under their common or usual names, not as "salt substitute."
- Potassium chloride must be declared as "potassium chloride" or "potassium salt."
- MSG must be declared as "monosodium glutamate."
- Allergen rules apply.
- Potassium must appear on the Nutrition Facts label once it reaches 2% or more of the daily value.
- FDA declined to require a hyperkalemia warning.
- Dairy carve-out: anyone adversely affected can object to the milk and cheese amendments (Parts 131 and 133) until November 12, 2026. Proper objections can stay those provisions past December 14, and FDA will publish notice in the Federal Register of the objections it receives.
What applies until December 14, 2026
- The current eCFR text has no general salt-substitute provision.
- Two standards already allow it:
- Otherwise, the only option is the §130.10 modified-standard route. That requires cutting sodium enough to meet a §101.61 nutrient content claim, which FDA itself calls potentially impracticable.
This covers US FDA standards only. USDA-FSIS meat and poultry standards and other countries are outside it; I can check those next if useful.
Which foods does the FDA rule cover?
The rule lets 80 FDA standards of identity, across 15 parts of 21 CFR, use a salt substitute. Most of them are cheeses: 41 of the 80. The rule was published at 91 FR 65040 and takes effect December 14, 2026. [1] I counted the 80 myself from the amendatory text, and the total matches the figure FDA gives for the rule. The panel document lists every section, the standard's name and the exact paragraph changed.
Approach: I used the rule's record in FDA's Federal Register filings, then read the amendatory text section by section in the published Federal Register PDF (91 FR 65055-65070).
| 21 CFR Part | Foods covered | Count |
|---|---|---|
| 131 Milk and cream | Acidified milk, cultured milk, sour cream, acidified sour cream, eggnog | 5 |
| 133 Cheeses | From asiago to Swiss and emmentaler, including cheddar, mozzarella, cream cheese, dry curd cottage cheese, parmesan, the process cheese foods and spreads, and the soft-ripened and semisoft classes | 41 |
| 136 Bakery | Bread, rolls, and buns | 1 |
| 137 Cereal flours | Self-rising flour, self-rising white corn meal | 2 |
| 139 Pasta | Macaroni products, noodle products | 2 |
| 145 Canned fruits | Applesauce, figs | 2 |
| 150 Fruit butters | Fruit butter | 1 |
| 155 Canned vegetables | Green and wax beans, corn, peas, tomatoes, tomato concentrates, catsup, certain other canned vegetables, mushrooms | 8 |
| 156 Vegetable juices | Tomato juice | 1 |
| 158 Frozen vegetables | Frozen peas | 1 |
| 161 Fish and shellfish | Canned oysters, Pacific salmon, wet pack shrimp, tuna | 4 |
| 163 Cacao | Chocolate liquor, breakfast cocoa, sweet chocolate, white chocolate, milk chocolate | 5 |
| 166 Margarine | Margarine | 1 |
| 168 Sweeteners | Cane sirup, maple sirup, sorghum sirup, table sirup | 4 |
| 169 Dressings | Mayonnaise, salad dressing | 2 |
Points that affect how you use the list:
- Wording varies by standard. Most now read "salt or salt substitute." For many natural cheeses the permission applies only "where the curd is salted" during cheesemaking.
- Canned wet pack shrimp (§161.173): paragraph (a) now includes salt substitutes, but the rule then stays paragraphs (a) and (c) indefinitely. In practice, the salt-substitute permission for that standard is suspended.
- Canned peas (§161.170 is salmon; peas are §155.170): the rule lifts a stay that has applied to paragraph (a)(2) since 1981, which is where the salt-substitute option sits.
- Margarine (§166.110(b)(2)): keeps the existing potassium chloride option for dietary margarine alongside the new salt-substitute option.
- Dairy (46 standards in Parts 131 and 133): these are the provisions open to objections until November 12, 2026.
- Methods-only changes don't count. Several other standards were amended only to update the AOAC methods of analysis they reference, with no salt-substitute change. These include fluid milk, the creams, half-and-half, flour, whole wheat flour, fruit jelly, preserves and jams, and frozen raw breaded shrimp. They are not among the 80 (91 FR 65056-65068).
How do salt substitutes have to be labeled?
FDA's final rule on salt substitutes in standardized foods (91 FR 65040, effective December 14, 2026) creates no new labeling requirements. A salt substitute is labeled like any other ingredient: by its own common or usual name in the ingredient statement, never under the generic term "salt substitute." [1] FDA says this in Response 11 of the rule (91 FR 65048).
Approach: I read the current 21 CFR Parts 101 and 133 labeling provisions in the eCFR and the FDA Federal Register record for the rule. I then read FDA's comment responses on labeling in the published rule (91 FR 65047-65049).
Ingredient statement
- Ingredients, including salt substitutes, must be listed by common or usual name in descending order of predominance by weight. This applies to foods that comply with standards of identity too. [4]
- FDA confirms that §101.4(b) requires a specific name, not a collective one, unless an exception exists. The rule defines "salt substitute" in new Part 130 subpart C but does not make it a collective name (91 FR 65048).
- Part 101 already has collective-name exceptions for some ingredient groups, such as leavening and dough conditioners, using "and/or" listings. [5][6] No such exception was created for salt substitutes. FDA treated comments proposing "and/or" labeling for salt substitutes under §101.4(b) as out of scope (91 FR 65052).
Specific ingredients
- Potassium chloride: must be declared as "potassium chloride" or "potassium salt" (Response 9, 91 FR 65047).
- MSG: must be declared as "monosodium glutamate," as §101.22(h)(5) requires (Response 10, 91 FR 65048).
- Protein hydrolysates: cannot be declared simply as "flavor," "natural flavor" or "flavoring." They must carry their specific common or usual name. [7]
- Allergens: if a substitute is or contains a major food allergen, the label must declare it under FD&C Act section 403(w) (91 FR 65048).
Nutrition Facts
- Potassium is a mandatory nutrient, listed after vitamin D, calcium and iron. [8]
- Below 2% of the RDI, potassium does not have to be declared. You can show it as zero, mark it with an asterisk and a footnote, or use a "Not a significant source of" statement. [9]
- FDA's position is that a potassium-based substitute triggers the potassium declaration at 2% or more of the daily value per serving (91 FR 65047).
What FDA declined to require
- No hyperkalemia warning. FDA reasoned that potassium content already appears on the label, and that warnings on so many foods would weaken their value (91 FR 65048-65049).
- No reformulation flag or front-of-pack potassium disclosure. You may add these voluntarily if they are truthful and not misleading under FD&C Act section 403(a)(1) (91 FR 65048-65049).
Claims you may make
- A "low sodium" claim still has to meet §101.61(b)(4).
- Potassium content claims follow §§101.13 and 101.54 (91 FR 65049).
Exception: low-sodium cheese standards Two standards already in force require an additional label statement, "______ added as a salt substitute," with the blank filled in with the common name of each substitute used:
The parts of the rule I read do not say whether these two statements are changed, so treat them as still applying. The new rule adds no comparable statement for the 80 newly amended standards.
I can check how USDA-FSIS handles salt-substitute labeling for meat and poultry next if useful.