In response to my last post on salt regulations, several commenters expressed some further points that are worth addressing. Much of it amounts to the argument that the regulations are, from the consumer’s perspective, a free lunch.

Commenter JzB argues that, for the most part, lowering that lowering salt in packaged foods will not result in significant taste changes, and to the extent it does, it can be fixed by adding salt:

So some of the salt is there for good reason, but the amounts used are overkill. I’m suggesting reductions of 25 to 50% will be transparent, or close to it. And also adjustable on the plate, if so desired.

The notion that reductions in sodium of the scale argued for by the Institute of Medicine can be achieved without significantly impacting the food as experienced by the consumer is, I believe, incorrect. In agreement with me is the actual  IOM report:

Current and ongoing industry reformulation has demonstrated that substantial reductions in sodium can be achieved based on existing technology and science. However, given the need to significantly reduce the sodium content of the food supply to achieve recommended population intake levels, additional innovations and research will be necessary to secure reductions while maintaining product taste, texture, safety, and shelf life.

These innovations will be necessary because, as the study points out, companies have already been taking advantage of the low hanging fruit in sodium reduction:

…some of the “easy” food reformulations to reduce the sodium content of processed foods have been achieved by the major food manufacturing companies, and in these cases, efforts to continue lowering the sodium content now require more creative and intense efforts.

You certainly get the sense when reading the report that the authors do not believe that the regulations will be simple, costless, or that our understanding of if and how the regulations will work is anywhere near certain. And remember, these assessments are from advocates for the regulation; it is almost certain that representatives of the food industry would be even less sanguine.

Another point that supporters of the salt regulation have made is that if you slowly reduce your salt intake, you won’t notice the decrease in saltines of foods. The IOM report, however, cautions that this a) this is far from certain, and b) may not apply to all foods:

…while data from perceptual studies may point the way to quantitative levels at which changes in the presence of a substance may not be perceived, much is yet to be learned about the application of such work to the wide range of food products and to other practical considerations in the real world….

Elsewhere they offer even more reasons to worry that sodium cannot be reduced without consumers tasting the difference:

First, the time course of changes in preference for salty foods in response to changes in salt intake is not well understood. Second, there are questions on the extent of a salt reduction that can be accomplished in a single reformulation without greatly altering the palatability of food…Third, it is unknown whether individuals are able to acclimate to lower-sodium foods when some high-sodium foods remain part of their diet.

The last point in the above quotation is worth unpacking a little. The report cites some disagreement among IOM committee members about whether exceptions to salt regulations should be made for certain foods. This discussion highlights that when faced with the possibility that their relatively lighter-touch regulation won’t work, some of the study’s authors would be willing to recommend more draconian measures:

…it is not known whether sensory accommodation would occur if salt were reduced in a single product category such as soup of bread or if the majority of the diet were low in sodium but consumers occasionally consumed foods that might be exempted from sodium reduction (anchovies, olives, etc.). This gap in current knowledge has been a concern for some committee members in determining whether exemptions should be considered for salty foods consumed in small quantities.

In previous quotations, the authors worry that it may be impossible to lower the sodium to a level acceptable in some foods, and here they recognize that the availability of these foods could prevent people from having their salt tolerance lowered. If foods like anchovies or olives aren’t amenable to sodium reduction without significantly altering their palatability, some of the committee members seem okay with those foods being effectively banned. This shows that the failure of a relatively lighter-touch regulation may simply lead policymakers to take a harder line with more draconian regulation. If you’re looking for the next slippery slope, this is a good place to start.

The problems mentioned above do not even get at the possibilities of public choice problem of allowing special exemptions, higher food prices due to higher R&D costs for food producers, increased barriers to entry, increased incentives for industry consolidation, lower levels of future innovation in new food choices, and that regulators will make “mistakes”  and set suboptimal levels.

If you want to argue that the benefits of these regulations outweigh the costs, that’s an argument to have. But let’s be realistic about the costs. The old maxim is a useful one: there is no such thing as a free lunch.

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