The Use of an Alternate Name for Potassium Chloride in Food Labeling; Draft Guidance for Industry; Availability

September 17, 2019 Via regulations.gov Dockets Management Staff (HFA-305) Food and Drug Administration 5630 Fishers Lane, Rm. 1061 Rockville, MD 20852 Re:The Use of an Alternate Name for Potassium Chloride in Labeling; Draft Guidance for Industry; Availability; Docket No. FDA-2019-D-0892 The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the U.S. Food and Drug Administrations (FDAs) draft guidance on the use of an alternate name for potassium chloride in labeling. From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies who help produce frozen foods and beverages for todays food service and retail marketplace and serve as economic pillars within their communities throughout the U.S. The frozen food industry contributes approximately $56 billion to U.S. GDP and accounts for 670,000 U.S. jobs. In addition to our members strong role in economic growth, AFFI members share a commitment to transparently communicating information about the nutritional content and ingredients in the foods they produce and sell. Executive Summary AFFI strongly supports FDAs efforts to consider alternative names for potassium chloride in food labeling, as we believe such efforts are important in encouraging the use of this ingredient as a tool in sodium reduction. AFFI members have been working towards reducing sodium in frozen foods for many years. Many of our member companies have completed internal sodium reduction initiatives, resulting in sodium reductions in some products of up to 20 to 30 percent. As our members look to make further reductions in the sodium content of the foods they make and sell, there are a number of barriers, including the limited number of sodium alternatives available. Potassium chloride is one of the more promising sodium reduction tools. Todays consumer, however, is increasingly looking for products with simple and streamlined ingredient statements featuring easily recognizable and premium ingredients, including salt or sea salt. In our members experience, many consumers find potassium chloride unappealing as an ingredient, perhaps based in part on the similarity between the terms chloride and chlorine. This makes it particularly prudent for the agency to consider alternative naming options that are more consumer-friendly and likely to encourage companies to use, and consumers to select, this ingredient in foods. As detailed further in the comments that follow, AFFI strongly supports the use of potassium salt as an alternative name for potassium chloride. Our members do not expect that the availability of the term FDA proposes in the draft guidance potassium chloride salt will encourage companies to use this ingredient or consumers to select foods that contain this ingredient. The draft guidance, therefore, would not achieve its primary public health objective of encouraging sodium reduction in the food supply and in consumers diets. We ask FDA to recognize in the final guidance that potassium chloride may appropriately be identified as potassium salt in the ingredient statement. We believe this approach is consistent with consumer understanding and FDAs common or usual name regulation and is more likely to achieve the underlying public health goals of the draft guidance. Please see the attached document for AFFI's detailed comments.