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# The FDA Wrote Salt Into 139 Food Recipes. Now You May Swap It.
- URL: https://www.freemarketsreport.com/the-fda-wrote-salt-into-139-food-recipes-now-you-may-swap-it/
- Published: 2026-10-16T02:27:09.000Z
- Updated: 2026-10-16T02:33:10.000Z
- Description: FDA finalized a rule letting manufacturers replace salt in 139 standardized foods, three and a half years after proposing it. The recipe mandate, the cost, the bear case and one stock idea.
- Author: Michael A. Gayed, CFA

**For years the federal government has written the recipe for your sour cream, your canned tuna and your bread, and the recipe says to add salt. This week it finally said you may use something else. I think that sentence should embarrass everyone who ever called this a free market for food.**

## Key Highlights

- **The rule:** FDA issued a final rule letting manufacturers use salt substitutes in foods whose standards of identity name salt as a required or optional ingredient.[1](#fn-1), [2](#fn-2)
- **The scale:** Before the rule, 139 standards of identity allowed or required salt but did not permit substitutes.[1](#fn-1) The rule amends 80 directly and reaches 59 more through cross-references.[3](#fn-3)
- **The calendar:** The rule was posted in the Federal Register on October 13 and takes effect December 14, 2026, after a proposal in March 2023.[2](#fn-2) Objections to the dairy provisions are due November 12.[3](#fn-3)
- **The cost:** FDA monetizes neither benefits nor costs, because compliance is voluntary; it estimates a minor label change at $4,269 to $14,679 per product and a reformulation at $3,000 to $1.5 million per formulation.[4](#fn-4)
- **The idea:** ADM (ADM) sells reduced-sodium ingredients and posted a 51% rise in Nutrition operating profit to $172 million in the second quarter.[5](#fn-5)

Let me start with what a standard of identity is, because most people have never heard the term and everyone has eaten the result.

FDA describes these standards as rules that often spell out what a food must contain, what is optional, and sometimes the amount of each ingredient or the method of production.[1](#fn-1) The stated purpose is to protect consumers and promote honest dealing. Fair enough. A jar labeled mayonnaise should be mayonnaise.

But a recipe mandate does something else too. It freezes the recipe. If the government says the cheese must contain salt, then the cheesemaker who wants less sodium cannot get there by swapping an ingredient. Before this week, 139 of these standards allowed or required salt and did not permit substitutes.[1](#fn-1) Manufacturers who wanted a lower-sodium version had few options.

Read that again. For years the same government told Americans to eat less sodium while keeping the legal recipe for dozens of staple foods stuck on salt.

## The surface story

The rule lets manufacturers replace some or all of the added sodium chloride with safe and suitable ingredients. The rule sets no minimum replacement level.[3](#fn-3) It does not list approved substitutes, which FDA says is meant to leave room for future innovation. The substitute still cannot change the basic nature and essential characteristics of the food.[6](#fn-6)

FDA frames the move as part of its Make America Healthy Again agenda and its voluntary sodium reduction goals.[1](#fn-1) The affected foods include cheese, bread, canned vegetables, mayonnaise and salad dressing.[3](#fn-3)

![Timeline from the March 2023 proposal to the December 14, 2026 effective date of the FDA salt substitute rule](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart1_timeline-4.png)

Source: Food Business News, Oct. 14, 2026[2](#fn-2); FoodIngredientsFirst, Oct. 14, 2026[3](#fn-3); FDA constituent update, Oct. 9, 2026[1](#fn-1).

Now the part the headline buries. This rule was proposed in March 2023 and finalized in October 2026\. That is about three and a half years for a rule whose entire effect is to say: you may. It imposes no requirement on anyone. FDA's own analysis says there are no regulatory costs, because nothing is mandated if a manufacturer chooses not to use the flexibility.[7](#fn-7)

I am glad it happened. I am also asking what a permission slip costs when it takes three and a half years to sign.

## The quiet second document

The press release is the headline. The economic analysis is the document that matters, because it shows how the agency sees its own rule.

FDA's final regulatory impact analysis lists the monetized benefits as zero and the monetized costs as zero, across low, primary and high estimates, at both 3 and 7 percent discount rates.[8](#fn-8) That is not because the rule does nothing. It is because FDA says it lacks the proprietary data to estimate how many products will be reformulated, how much salt will be replaced, or how consumers will respond.[9](#fn-9)

The agency does give a cost range for a company that chooses to act. A minor labeling change costs an average manufacturer between $4,269 and $14,679 per product. A reformulation costs between $3,000 and $1.5 million per formulation.[9](#fn-9) That range is wide because salt does different jobs in different foods.

![Chart of FDA's estimated cost ranges for a label change and a reformulation under the salt substitute rule](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart2_cost.png)

Source: FDA final regulatory impact analysis, p. 13[9](#fn-9). Ranges are FDA's average-manufacturer estimates.

Notice the economics. FDA expects a company to reformulate only if the benefit, in added revenue, is at least as large as the cost.[9](#fn-9) That is the right test and it is a market test. No agency decides which cheese gets less salt. The firm that thinks shoppers will pay for it, or that wants to hit its own targets, does the math and decides.

It also tells you what to watch. If this rule matters, it shows up as reformulated products on shelves and re-labeled UPCs, not as a line in a government spreadsheet.

## The numbers

The scale of the old restriction is easy to state. There are 139 standards in play. The rule rewrites 80 of them directly and reaches 59 more through cross-references.[3](#fn-3)

![Chart showing 139 standards of identity split into 80 amended directly and 59 reached by cross-reference](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart3_scale.png)

Source: FoodIngredientsFirst, Oct. 14, 2026[3](#fn-3); FDA constituent update, Oct. 9, 2026[1](#fn-1).

The health argument that FDA leans on is also specific. More than 70 percent of the sodium Americans eat comes from foods where it was added during manufacturing and commercial food preparation.[10](#fn-10) That is the reason the lever sits with manufacturers rather than with the salt shaker at your table.

And here is the number I find most useful for judging how much this rule will change. When FDA issued voluntary sodium guidance in 2021, researchers found that sodium content across food categories fell by a median of only 3 percent, and some restaurant foods rose.[6](#fn-6) In 2024 the agency set new targets to bring average intake down over three years from more than 3,400 milligrams a day to 2,750.[6](#fn-6)

So voluntary goals moved the needle a little. Legal flexibility may move it more, because it removes a barrier rather than asking for good behavior. I would not bet the farm on a big move, though. FDA itself says the potassium chloride route has limits, since its bitter and metallic taste can constrain how much a manufacturer can use.[3](#fn-3)

## Who wins and who loses

Start with the clear winners. Any manufacturer of a standardized food that already wanted to cut sodium and could not do it legally. The dairy industry says so directly: the International Dairy Foods Association welcomed the rule and said it gives dairy manufacturers more flexibility to reduce sodium while maintaining product quality, safety and consumer expectations.[6](#fn-6)

Next, the ingredient suppliers. A rule that does not name approved substitutes lets flavors, flavor enhancers and mineral salts compete, as long as they meet the criteria.[3](#fn-3) Open categories invite competition. That is the whole point of writing a standard around function rather than around a list.

The consumer wins in a quieter way. If a company can sell a lower-sodium version under the traditional name, the shopper gets another choice on the same shelf.

Who loses? Not many people, and I want to be honest about that. The Center for Science in the Public Interest welcomed the change and urged the industry to follow through.[3](#fn-3) A rule that nobody has to follow and that regulators and advocates both applaud is a rare animal.

The loser, if there is one, is the bureaucratic habit. The old system assumed that the government knew the correct recipe for canned peas better than the firms making them. Allowing substitution quietly concedes that it did not.

## The free-market read

I want to steelman the case for standards of identity before I knock on it. Without them, a producer could dilute a product and still use the familiar name. A shopper cannot taste-test every jar in the aisle. A shared definition lowers the cost of trust. That is a real function, and markets have invented private versions of it, like brand names and certification marks.

But notice what this rule shows. The standards did not only prevent fraud. They also prevented improvement. A mandated recipe protects the shopper from a bad substitute and also locks out a good one. The only way out was a petition and a multi-year rulemaking.

Here is how I think about it. A price tells a producer what customers want. A mandated recipe tells a producer what a regulator wanted in some earlier decade. When the two diverge, the producer cannot respond. The correction here arrived years late, and only because the agency chose to move.

Pro-market does not mean pro-incumbent, and I should say where that cuts. A rule like this can help large firms with big reformulation labs more than small producers. FDA's own numbers show a reformulation can cost up to $1.5 million per formulation.[9](#fn-9) A company with a dozen standardized products and a small food-science team will find that hard. The flexibility is open to all, but the ability to use it is not evenly spread.

I also do not want to oversell the health claim. FDA says it expects public health benefits only if manufacturers decide reformulation is profitable, and it declined to put a number on them.[9](#fn-9) The agency cites a study estimating that a 4 percent annual drop in sodium intake could prevent 280,000 to 500,000 deaths over ten years, then says this rule applies to only a portion of packaged food and should not be expected to deliver similar levels.[9](#fn-9) Good. That is honest. I wish more agencies wrote that plainly.

## The bear case

I could be wrong about how much this changes, and the bear case is simple.

First, it is voluntary. A company can ignore the rule, and many will. Reformulation costs money, risks a taste complaint, and requires new labels. If shoppers do not reward a lower-sodium version, the shelf will look the same in a year.

Second, the dairy provisions are not settled. Properly filed objections can stay them, and objections are due November 12.[3](#fn-3) The effective date of December 14 is not guaranteed for every category.

Third, salt does more than make food taste good. It also controls microbial growth.[3](#fn-3) Replacing it is not a free swap, and FDA warns that substitutes must serve the functions of the salt they replace.

Fourth, potassium chloride is the obvious substitute and it has a taste ceiling. The ingredient that works best for sodium reduction is the one with the metallic aftertaste, which is why the real fight will be over flavor science.

## The Idea: ADM (Archer-Daniels-Midland)

This is not advice. It is a way to ask who gets paid when a legal barrier to reformulation comes down, and I will tell you up front that the connection is partial.

**What it does.** ADM is a very large agricultural processor, and it also runs a flavors and ingredients business. In May, Food Dive reported that ADM will invest $26 million to expand its Erlanger, Kentucky, facility and raise capability by 40 percent, after a $15 million expansion there in 2025.[11](#fn-11) The same report says ADM focuses its formulation work on five pillars including reduced sodium, and that it uses a flavor modulation tool called Tastespark along with potassium chloride, potassium salt and a specialized sea salt blend to cut sodium.[11](#fn-11)

**Why the policy helps.** The causal chain is short. Reformulation was blocked by a recipe mandate in 139 foods. The mandate is being lifted. Companies that want to lower sodium now need ingredients and the people who can make them taste right. ADM sells that kind of help, and the company said in May it is seeing unprecedented demand for reformulation.[11](#fn-11)

![ADM second quarter 2026 operating profit by segment with year over year growth](https://storage.ghost.io/c/be/1b/be1bb8f3-f534-4eb9-b00d-09ff49598e5f/content/images/size/w1000/2026/10/chart4_adm.png)

Source: FoodIngredientsFirst, ADM Q2 2026, Aug. 4, 2026[5](#fn-5).

**The data point.** In the second quarter of 2026, ADM reported Nutrition operating profit up 51 percent to $172 million, with Flavors named as the driver. Ag Services and Oilseeds rose 129 percent to $867 million and Carbohydrate Solutions rose 22 percent to $411 million. Revenue was $22.68 billion, and ADM raised its full-year adjusted earnings outlook to $5.15 to $5.60 per share from $4.15 to $4.70.[5](#fn-5)

**What the market may be missing.** Probably nothing about this rule, and I want to be clear about it. Nutrition is the smallest of ADM's three segments by operating profit, and the stock moves mostly on crush margins and biofuels. Perplexity Finance shows ADM at $82.93 after the close on October 15, a market capitalization of about $40.0 billion and a price-to-earnings ratio of 22.72, against a 52-week range of $55.58 to $88.75.[12](#fn-12) The shares have already run a long way. What I am pointing at is a small, durable tailwind inside the segment that is growing fastest.

**The risks, and what proves it wrong.** The thesis is wrong if reformulation under this rule turns out to be minimal, which the voluntary design makes entirely possible. It is wrong if sodium-reduction ingredients are a rounding error against ADM's commodity businesses, which on today's mix they probably are. And it is wrong if biofuel margins, which helped lift the second quarter, reverse and swamp everything else. I would rather hand you a modest, honest idea than a loud one.

## What to watch next

Three dates and one shelf check.

November 12\. Objections to the dairy provisions are due, and a filed objection can stay them.[3](#fn-3) Watch whether any are filed.

December 14\. The rule takes effect.[2](#fn-2) That is when a reformulated product can legally appear under a traditional name.

Later this year. FDA says it will issue a report on progress against its Phase I sodium targets.[1](#fn-1) That report will show whether voluntary goals plus flexibility are moving anything.

And the shelf check. In the first half of next year, look at the labels on bread, mayonnaise and canned vegetables. If you start seeing potassium chloride or new flavor systems where salt used to be, the rule worked. If the labels are unchanged, it was a permission nobody wanted.

A government that writes the recipe for your sandwich has no business being surprised when the sandwich stops improving. Take the recipe mandates off, one standard at a time.

## Sources

1. [FDA constituent update, Oct. 9, 2026](https://www.fda.gov/food/hfp-constituent-updates/fda-issues-final-rule-salt-substitutes-standardized-foods?ref=freemarketsreport.com) (fda.gov)
2. [Food Business News, Oct. 14, 2026](https://www.foodbusinessnews.net/articles/31176-fda-rule-adds-flexibility-in-using-salt-substitutes?ref=freemarketsreport.com) (foodbusinessnews.net)
3. [FoodIngredientsFirst, Oct. 14, 2026](https://www.foodingredientsfirst.com/news/fda-salt-substitutes-sodium-reduction.html?ref=freemarketsreport.com) (foodingredientsfirst.com)
4. [FDA final regulatory impact analysis, pp. 5 and 13](https://www.fda.gov/media/195699/download?ref=freemarketsreport.com) (fda.gov)
5. [FoodIngredientsFirst, ADM Q2 2026, Aug. 4, 2026](https://www.foodingredientsfirst.com/news/adm-q2-results-food-ingredients.html?ref=freemarketsreport.com) (foodingredientsfirst.com)
6. [Food Dive, Oct. 14, 2026](https://www.fooddive.com/news/fda-salt-substitutes-sodium-reduction-food/832970/?ref=freemarketsreport.com) (fooddive.com)
7. [FDA final regulatory impact analysis, p. 5](https://www.fda.gov/media/195699/download?ref=freemarketsreport.com) (fda.gov)
8. [FDA final regulatory impact analysis, Table 1](https://www.fda.gov/media/195699/download?ref=freemarketsreport.com) (fda.gov)
9. [FDA final regulatory impact analysis, p. 13](https://www.fda.gov/media/195699/download?ref=freemarketsreport.com) (fda.gov)
10. [FDA final regulatory impact analysis, p. 11](https://www.fda.gov/media/195699/download?ref=freemarketsreport.com) (fda.gov)
11. [Food Dive, ADM reformulation hub, May 28, 2026](https://www.fooddive.com/news/adm-reformulation-ingredients-solutions-erlanger-kentucky/821384/?ref=freemarketsreport.com) (fooddive.com)
12. [Perplexity Finance, ADM quote and ratios](https://www.perplexity.ai/finance/ADM?ref=freemarketsreport.com) (perplexity.ai)

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