Australia New Zealand Food Standards Code – Standard 2.10.2 – Salt and salt products

The Standard organises around simple, bounded concepts with numeric limits. The definitions in 2.10.2,2 are the core legal concepts to apply when classifying a product.

• Salt. The Standard defines "salt" to mean the crystalline product consisting predominantly of sodium chloride, obtained from the sea, underground rock salt deposits or natural brine (2.10.2,2, definition of salt). When sold as "salt" the product must contain at least 970 g/kg sodium chloride on a dry basis, exclusive of permitted additives (2.10.2,3). That is a threshold of 97% sodium chloride on a dry weight basis.
• Reduced sodium salt mixture. Defined as a food prepared from a mixture of sodium chloride and potassium chloride, with limits of no more than 200 g/kg sodium and no more than 400 g/kg potassium (2.10.2,2). The Standard requires that any product sold as a reduced sodium salt mixture must meet that definition (2.10.2,4).
• Salt substitute. Defined by function and composition: it must be made as a substitute for salt; consist of substances that may be used as food additives for salt substitute under item 12 of the table to Schedule 15; and contain no more than 1.2 g/kg of sodium (2.10.2,2). The Standard requires that foods sold as a salt substitute must meet that definition (2.10.2,5).
• Iodised salt and iodised reduced sodium salt mixture. These are salt or reduced sodium salt mixtures containing specific iodine compounds (potassium iodide, potassium iodate, sodium iodide or sodium iodate) added in amounts equivalent to not less than 25 mg/kg and not more than 65 mg/kg of iodine (2.10.2,2). The Standard requires products sold using the term "iodised" to meet these specific compositional requirements (2.10.2,6; 2.10.2,7).

Labelling. For reduced sodium mixtures and salt substitutes the Standard prescribes that the required information is a declaration of sodium and potassium content, expressed per 100 g (2.10.2,8(1)). A manufacturer may include a declaration of the percentage reduction of sodium in the food relative to salt; the Standard explicitly states such a declaration is not a nutrition content claim or a health claim (2.10.2,8(2)-(3)). The Standard directs readers to Standard 1.2.1 for the labelling provisions.

Cross‑references and scope. The Standard repeatedly cross‑references other parts of the Code. The qualitative composition of salt substitute is tied to allowable substances in Schedule 15 (item 12). Labelling mechanics point to Standard 1.2.1. The Standard is expressed as part of the national Code and as applicable in New Zealand via the Food Act 2014 (NZ) (note 1 and note 2). The Amendment History and compilation notes record publication and the lone technical amendment correcting formatting (Amendment 161).

The Standard imposes legal content and labelling rules that fall on market actors who choose to sell foods under the specified names. The immediate legal obligations attach to any person or business that places a food on the market and labels or describes it as "salt", "reduced sodium salt mixture", "salt substitute", "iodised salt" or "iodised reduced sodium salt mixture" (see 2.10.2,3 to 2.10.2,7). Those actors will include, as applicable, manufacturers, packers, brand owners, importers, distributors and retailers who present foods under those descriptions.

Producers and processors. Producers of crystalline salt must ensure their product meets the compositional threshold of no less than 970 g/kg sodium chloride on a dry basis, exclusive of permitted additives, before using the name "salt" on packaging or in trade (2.10.2,3). Producers of reduced sodium salt mixtures must ensure formulations are prepared from sodium chloride and potassium chloride and meet the sodium and potassium limits (2.10.2,2; 2.10.2,4). Producers of salt substitutes must ensure ingredients are limited to substances permitted for that use in Schedule 15 item 12 and that sodium is no more than 1.2 g/kg (2.10.2,2; 2.10.2,5). Producers choosing to iodise must use only the specified iodine compounds at the specified iodine dosage range (2.10.2,2; 2.10.2,6; 2.10.2,7).

Importers. Imports described as any of the named products will need to meet the same compositional and labelling criteria when placed on the Australian or New Zealand market, because the Standard is part of the Code and is incorporated or adopted under the New Zealand Food Act 2014 for NZ (note 2).

Brand owners and retailers. A brand owner who markets a product under one of the prescribed names must ensure the product meets the corresponding definition and that the label contains the required declarations for reduced sodium mixtures and salt substitutes (2.10.2,8(1)). Retailers and wholesalers who repackage or relabel products will similarly need to ensure compliance before sale.

Regulators and enforcers. The document is made under the Food Standards Australia New Zealand Act 1991 (Cth) and forms part of the Code (note 1). The Standard does not itself set out enforcement mechanisms or penalties. For New Zealand, the Code provisions apply through incorporation or adoption under the Food Act 2014 (NZ) (note 2). Users should therefore expect enforcement and compliance oversight to be carried out under the implementing food laws and regulatory frameworks that give effect to the Code in each jurisdiction.

Consumers. The Standard changes what product names mean in the marketplace and prescribes additional labelling information for particular product classes. Consumers will see mandatory sodium and potassium declarations for reduced sodium salt mixtures and salt substitutes, and optional percentage reduction statements whose legal status is set out in the Standard (2.10.2,8).

The Standard creates a set of affirmative duties tied to product naming and a narrow labelling duty for two product classes. It does not itself state enforcement powers or penalties, and it leaves broader labelling form and presentation to Standard 1.2.1.

Duties imposed by the Standard

• Duty to meet compositional definitions when using product names. If a food is sold as "salt", it must meet the definition of salt and contain no less than 970 g/kg sodium chloride on a dry basis, exclusive of permitted additives (2.10.2,3). Equivalent obligations apply for "reduced sodium salt mixture" (must be prepared from a mixture of sodium chloride and potassium chloride and must contain no more than 200 g/kg sodium and 400 g/kg potassium) (2.10.2,2; 2.10.2,4), for "salt substitute" (must meet the definition including sodium ≤ 1.2 g/kg and consist of substances permitted under Schedule 15 item 12) (2.10.2,2; 2.10.2,5), and for the iodised variants (must contain one of the listed iodine compounds at an iodine content equivalent to 25-65 mg/kg) (2.10.2,2; 2.10.2,6; 2.10.2,7).
• Duty to declare specific nutrient content on labels for two classes. For reduced sodium salt mixtures and salt substitutes the label must declare sodium and potassium content, expressed per 100 g (2.10.2,8(1)). The Standard directs that the labelling provisions are set out in Standard 1.2.1, so the specific manner and placement of the declaration will be governed by that labelling standard.

Permitted statements and limits on claim characterisation

• Optional percentage reduction statement. The label may state the percentage reduction of sodium relative to salt (2.10.2,8(2)). The Standard explicitly states that such a percentage reduction declaration is not a nutrition content claim or a health claim (2.10.2,8(3)). This changes how that particular statement is categorised for claim‑related rules in the Code, because it is expressly excluded from the nutrition content/health claim classification in this context.

Cross‑references that create secondary duties

• Additives and allowable substances. The definition of salt substitute requires use only of substances that may be used as food additives in relation to salt substitute in accordance with item 12 of the table to Schedule 15 (2.10.2,2). That creates a duty to check Schedule 15 item 12 for permitted substances when formulating a salt substitute.
• Labelling forms and presentation. The Standard refers to Standard 1.2.1 for labelling provisions (2.10.2,8, note). Use of the pack‑level nutrition panel, font sizes, ingredient lists and mandatory advisory statements may be governed by Standard 1.2.1 and other Code provisions.

Rights and tolerances

• The Standard confers no express private rights of action and contains no tolerance or enforcement regime within the text provided. It does, however, permit an optional dietary information statement (percentage reduction) and defines compositional boundaries that allow manufacturers to choose product forms consistent with labelling and naming. The Standard’s definitions thereby create safe harbours for market players who conform to the numeric thresholds and allowed compounds.

Practical note on units and measurements

• The Standard uses a mix of units and bases. Definitions use g/kg and mg/kg thresholds; labelling is required per 100 g. Producers will need to ensure measurements are converted appropriately when preparing labels and when testing against composition thresholds. For example, a limit of 200 g/kg equals 20 g per 100 g.

The text of Standard 2.10.2 itself contains no penalty clauses, no express enforcement powers and no civil or criminal sanction schedules. The Standard is framed as an instrument under the Food Standards Australia New Zealand Act 1991 (Cth) and as part of the Australia New Zealand Food Standards Code (note 1). It is therefore a normative instrument within the Code. The Standard also notes that provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ) (note 2).

Consequences of the Standard’s silence on penalties

• The Standard sets mandatory compositional and labelling requirements but leaves operational enforcement, offences, penalties and compliance mechanisms to the Acts and administrative frameworks that incorporate or give effect to the Code in each jurisdiction. The document’s inclusion of commencement notices under section 92 of the FSANZ Act (see the Commencement note) indicates how the Standard was made effective, but the Standard does not itself specify how non‑compliance is to be punished.
• For practical compliance and regulatory risk analysis, a regulated entity should therefore consult the implementing food legislation and enforcement rules in the jurisdiction where the product is sold. The Standard does not identify the competent enforcement body or the sanctions that apply for breach of its provisions.

Areas where enforcement linkage is explicit in the Standard

• Jurisdictional applicability. The Standard explicitly states it is a Code standard under the FSANZ Act and that Code provisions are incorporated in or adopted under the New Zealand Food Act 2014 (NZ) (note 1 and note 2). That is the textual basis to expect that enforcement will flow through the statutory regimes that implement the Code.
• Labelling cross‑reference. The Standard directs users to Standard 1.2.1 for labelling provisions (2.10.2,8, note). Those cross‑referenced labelling rules may contain specific detailed requirements and, in the broader Code, mechanisms for enforcement of labelling offences may be located.

Practical implication

• Because the Standard imposes mandatory composition thresholds and labelling obligations but does not itself specify penalties, regulated parties should not treat compliance as merely advisory. Conformity is legally required under the Code. The enforcement pathway and applicable sanctions must be checked in the relevant food law and regulatory instruments that give effect to the Code in Australia and in New Zealand.

Standard 2.10.2 is not a freestanding statute. It is an element of the Australia New Zealand Food Standards Code and therefore operates in a network of cross‑references within the Code and in national implementing legislation.

Relationship to the FSANZ Act and the Code

• The Standard is explicitly an instrument made under the Food Standards Australia New Zealand Act 1991 (Cth) and forms part of the Australia New Zealand Food Standards Code (note 1). The Code is a consolidated body of standards. The Standard’s validity and effect as part of the Code flow from that Act and from the mechanisms used for commencement and Gazette notices under section 92 of the Act, as referenced in the Commencement note.

New Zealand incorporation

• The Standard expressly notes that the provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ) (note 2). That creates a textual link from this Standard to New Zealand’s food law framework and indicates that the Standard is applied in New Zealand via the Food Act’s adoption or incorporation mechanism.

Cross‑references inside the Code

• Labelling provisions. The Standard stipulates a specific labelling obligation for reduced sodium salt mixtures and salt substitutes and directs that the labelling provisions are set out in Standard 1.2.1 (2.10.2,8, note). That means the detailed labelling presentation, formatting and possibly the nutrition panel layout are governed by 1.2.1 and related labelling provisions within the Code.
• Permitted additives. The definition of salt substitute ties the allowable composition to substances permitted "in relation to salt substitute" in item 12 of the table to Schedule 15 (2.10.2,2). The legal acceptability of particular additive substances therefore depends on Schedule 15 item 12, which is not reproduced in this Standard. Users must consult Schedule 15 for substance‑level permissions.
• Claim classification. The Standard declares that a percentage reduction statement is not a nutrition content claim or a health claim (2.10.2,8(3)). That statement interacts with other Code provisions that regulate claims. Where those other Code provisions regulate nutrition or health claims differently, this Standard carves out the specific percentage reduction declaration from those classifications for the two product classes covered.

Scope limits within broader food law

• The Standard is restricted to composition and labelling of specified salt products. It does not set out hygiene, contaminant limits, sampling regimes, registered food business requirements, or inspection and seizure procedures. Those matters are handled under other Code standards and under implementing food laws in the various jurisdictions. The Standard’s cross‑references make clear that additional requirements may apply elsewhere in the Code.

Practical consequence

• Compliance with the Standard requires attention to other parts of the Code and to the statutory instruments that adopt or enforce the Code in each jurisdiction. Specific obligations about labelling presentation, additive permissibility, and enforcement are located outside the text of this Standard and must be checked in the cross‑referenced instruments.

The compilation includes a short amendment history and publication metadata. The Standard as presented is a consolidation in force on 1 March 2016.

Publication and initial amendment

• Standard 2.10.2 was published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00485 - 2 April 2015). This is recorded in the Amendment History summary.

Subsequent amendment recorded in the compilation

• Amendment No. 161 is recorded against section 2.10.2,3. The FRLI registration number and gazette references given are F2016L00120 and FSC10322 dated February 2016, with a commencement date of 1 March 2016. The description of that amendment is "Correction to formatting of section text" and the effect line records that 2.10.2,3 was amended (Amendment 161). The compilation states it contains amendments up to Amendment No. 161 and that it was prepared by Food Standards Australia New Zealand on 1 March 2016.

Compilation metadata and uncommenced amendments

• The compilation notes explain that uncommenced amendments or provisions ceasing to have effect may be reflected as shaded boxed text in the Standard where applicable. It also states that the compilation is prepared to reflect amendments that have commenced and that the Federal Register of Legislative Instruments will contain the authoritative registration and amendment history.
• The compilation includes a list format for amendments, with the specific table entry referencing the formatting correction to 2.10.2,3 as the only substantive amendment recorded in the table presented.

What the Amendment History does not show

• The Amendment History in the provided text lists only the original publication and a single formatting correction to section 2.10.2,3. It does not record any substantive policy amendments to the numeric thresholds, definitions, or labelling rules beyond that publication and formatting fix, as of the compilation date 1 March 2016.

Practical reading

• Users should rely on the Federal Register of Legislative Instruments and the Gazette notices referenced in the compilation for the authoritative amendment register and for any subsequent amendments after 1 March 2016. The Standard as compiled incorporates the stated amendments up to the stated date.

The supplied compilation of Standard 2.10.2 does not contain any judicial decisions, reported enforcement actions, or litigation annotations. The text of the Standard, its notes, and the Amendment History do not reference any court or tribunal decisions, nor do they provide examples of enforcement matters. The compilation therefore records no litigation history.

Implications of the absence of litigation material in the compilation

• The Standard itself is a normative regulatory text and not a case law digest. The absence of litigation material in this compilation does not mean there has been no enforcement activity or no judicial consideration of the Code or related issues. It simply means that no litigation history is recorded within this specific Standard document as prepared on 1 March 2016.
• Users analysing legal risk should therefore not assume litigation silence implies absence of enforcement risk. To assess the real world enforcement and adjudication environment, readers must consult enforcement agency records, tribunal and court databases, and decisions that might interpret the Code, its cross‑referenced provisions and their interaction with national food law.

Where to look for litigation and interpretive guidance

• For cases and contested enforcement outcomes that might involve product naming, compositional tests or labelling disputes under the Code, search state and territory tribunal and court records in Australia, federal courts where relevant, and New Zealand courts and tribunals for matters under the Food Act 2014 (NZ) where the Code has been adopted. Administrative decisions and recalls may also be recorded by regulators. The compilation does not provide those sources.

Standard 2.10.2 is compact but contains several fine‑grained drafting points that create practical compliance traps if overlooked. This section isolates those particulars and explains the direct mechanical implications as stated in the Standard.

"Dry basis" for salt composition (2.10.2,3)

• The requirement that salt contain no less than 970 g/kg sodium chloride "on a dry basis" means moisture content is excluded from the basis of the calculation. Producers must ensure that compositional testing reports and declarations reflect dry weight calculations, not wet weight. This affects laboratory analysis method selection and reporting formats.

"Exclusive of permitted additives" for salt (2.10.2,3)

• The sodium chloride threshold for salt is stated to be exclusive of permitted additives. That phrasing allows for certain additives to be present without counting against the 970 g/kg NaCl minimum, but it requires clarity on which additives are "permitted". The Standard does not list them in this provision, so producers must check the Code’s schedules and additive permissions to determine which additives may be present and whether their mass is excluded from the NaCl calculation.

Unit mismatches between definitions and labelling (2.10.2,2; 2.10.2,8)

• The definitions use g/kg and mg/kg thresholds while the labelling requirement for reduced sodium salt mixtures and salt substitutes requires declarations per 100 g (2.10.2,8(1)). Producers must convert between g/kg and per 100 g when doing compliance testing and label preparation. For example, 200 g/kg equals 20 g per 100 g, and 25 mg/kg equals 2.5 mg per 100 g.

Restricted list of iodine compounds and tight iodine range (2.10.2,2; 2.10.2,6-7)

• Iodised products are limited to four specific compounds and to an iodine content equivalent between 25 mg/kg and 65 mg/kg. Use of alternative iodine sources, or departures from that specified range, would fail the definition for "iodised" as used in the Standard. Producers must ensure analytical methods report iodine content and that the iodine source is one of the enumerated salts.

Composition requirement for reduced sodium salt mixture limits formulation flexibility (2.10.2,2)

• The definition requires that a reduced sodium salt mixture be prepared from sodium chloride and potassium chloride. Other mineral salts or flavouring matrices are not included in the definition. If a manufacturer uses additional salt types or significant mineral ingredients, the product may not meet the definition even if the numeric sodium and potassium concentrations are within limits.

Salt substitute definition ties ingredients to Schedule 15 item 12 (2.10.2,2)

• A "salt substitute" must consist of substances that may be used as food additives "in relation to salt substitute" under item 12 of the table to Schedule 15. That creates a dependency on Schedule 15 for permitted substances. The Standard does not reproduce Schedule 15, so manufacturers must consult it directly to confirm additive permissibility before calling a product a salt substitute.

Percentage reduction statement not a nutrition content or health claim (2.10.2,8(3))

• The Standard expressly states a percentage reduction declaration is not a nutrition content claim or a health claim. That legal classification may relieve manufacturers from certain claim substantiation rules, but it does not relieve them from meeting other labelling obligations in Standard 1.2.1. Do not treat the statement as free of regulatory consequence; check the presentation, prominence and accuracy obligations in Standard 1.2.1.

Narrow scope of the Standard , other regulatory requirements remain (entire Standard)

• The Standard regulates compositional definitions and a limited labelling requirement. It does not address hygiene, contaminants, allergen labelling, food safety management systems, recall procedures or many other regulatory requirements that apply to foods generally. Compliance with this Standard does not equate to full regulatory compliance for a food business.

Terminology and market descriptions

• The Standard regulates what can be sold as "salt" and related names. Using alternative descriptions or ambiguous marketing language could create legal uncertainty. Conversely, strict use of the defined names imposes precise compositional limits that may require reformulation, analytical documentation and label changes.

The Standard prescribes a limited set of mandatory actions. Below is a practical, source‑grounded checklist that follows from the text and the cross‑references in the Standard. Each step points back to the relevant clause in the Standard that creates the obligation.

1. Classify the product according to the Standard’s definitions (2.10.2,2).

   • Decide whether the product will be sold as "salt", "reduced sodium salt mixture", "salt substitute", "iodised salt" or "iodised reduced sodium salt mixture".
   • If the product is to be sold under one of those names, proceed to the matching compositional checks and labelling checks below.

2. Meet the compositional thresholds for the chosen product name.

   • Salt: ensure sodium chloride content is no less than 970 g/kg on a dry basis, exclusive of permitted additives (2.10.2,3). Adjust manufacturing specifications and ingredient sourcing to meet that dry basis NaCl minimum.
   • Reduced sodium salt mixture: ensure formulation is prepared from only sodium chloride and potassium chloride and that sodium ≤ 200 g/kg and potassium ≤ 400 g/kg (2.10.2,2; 2.10.2,4).
   • Salt substitute: ensure the product consists only of substances permitted for that use in item 12 of the table to Schedule 15 and contains no more than 1.2 g/kg sodium (2.10.2,2; 2.10.2,5).
   • Iodised products: use only the permitted iodide/iodate compounds and ensure iodine is added at an amount equivalent to at least 25 mg/kg and at most 65 mg/kg iodine (2.10.2,2; 2.10.2,6; 2.10.2,7).

3. Ensure laboratory testing and reporting match the Standard’s metrics.

   • Use analytical methods that can report sodium, potassium and iodine content in the units used by the Standard (g/kg and mg/kg) and convert as needed for labelling per 100 g. For labelling calculations convert g/kg to per 100 g by dividing by 10.

4. Prepare labels that meet the specific declaration requirements.

   • For reduced sodium salt mixtures and salt substitutes, include a declaration of sodium and potassium content expressed per 100 g on the label (2.10.2,8(1)). Consult Standard 1.2.1 for the required format, placement and any other labelling mechanics referenced by this Standard.
   • If you include a percentage reduction of sodium relative to salt, ensure the calculation is accurate and be aware the Standard treats that declaration as not being a nutrition content claim or health claim (2.10.2,8(2)-(3)).

5. Check additive permissions and Schedule 15.

   • For salt substitutes, confirm that each additive or substance used is permitted for that specific use in item 12 of the table to Schedule 15, as required by the definition (2.10.2,2). Do not assume any additive is allowable without checking Schedule 15.

6. Document and retain evidence of conformity.

   • Maintain formulation records, supplier declarations, production records and test certificates that demonstrate the product meets the applicable definition and label declarations. The Standard’s obligations are composition and label based; documentary evidence will be necessary to demonstrate compliance to an enforcement agency.

7. Coordinate with import/export procedures.

   • If importing or exporting products labelled as any of the defined names, ensure the product meets the compositional definitions and labelling obligations that apply in the target market. The Standard is part of the Code and is adopted under the Food Act 2014 in New Zealand (note 2).

8. Monitor cross‑referenced Code instruments for additional obligations.

   • Check Standard 1.2.1 for detailed labelling requirements and Schedule 15 item 12 for permitted additives. The Standard’s requirements are expressed in relation to those other Code parts and compliance with this Standard requires alignment with them.

9. Update product names if composition cannot be met.

   • If a formulation cannot meet the compositional thresholds or additive permissions, do not sell the product under the restricted terms "salt", "reduced sodium salt mixture", "salt substitute", "iodised salt" or "iodised reduced sodium salt mixture". Use alternative truthful descriptors that do not invoke the defined product names.

10. Review the Amendment History and consolidated text.

• The compilation includes publication metadata and records Amendment 161 as a formatting correction (Amendment History). Check the Federal Register of Legislative Instruments or the Code consolidated text for any subsequent amendments after 1 March 2016. The Standard’s substantive content can change by later amendments.

These steps flow directly from the Standard’s text. The Standard is narrowly prescriptive: meet the numeric and compositional definitions when using the specified names and include the required sodium and potassium declarations for two product classes. For matters not addressed in this Standard, consult the cross‑referenced Code provisions and the food laws that implement the Code in each jurisdiction.