1. Legislative scaffolds for salt- reduction programs A new way of regulating business in the ‘nanny state’ era Belinda Reeve, Law Fellow, O’Neill Institute for National and Global Health Law

2. Bloomberg’s soda rule

3. The National Salt Reduction Initiative

4. The links between salt and health Excess saltHypertension Strokes and heart disease

5. Processed foods: The main source of dietary salt intake

6. The UK Food Standards Authority

7. Australian Food and Health Dialogue Nine food categories Twenty targets Approx. 42 participants

8. Effective?

9. Obstacles to public health regulation Nanny state rhetoric Economic productivity arguments A powerful food industry

10. Governments remain responsible for public health

11. A spectrum of regulatory options

12. Smart regulation Self-regulation Mandatory standards

13. Responsive regulation Mandatory standards Standards with discretionary punishment Enforced self-regulation Self-regulation Voluntary compliance

14. Legislative scaffolds ContentProcessesEnforcement Objectives Terms Conditions Administration Monitoring Review Incentives for compliance, Penalties for breaches

15. Improving the Dialogue: Phase 1 ContentProcessesEnforcement Greater range of targets Creation of maximum salt caps Encourage more participants Monitoring through baseline data on salt intake and food database Creation of High-Level Steering Committee with equal representation of interests Targets and caps are voluntary Warning label for new high-salt products

16. Improving the Dialogue: Phase 2 ContentProcessesEnforcement Salt reduction targets apply to specific manufacturers’ portfolios Creation of an independent regulator with a statutory mandate Regulator to monitor companies’ performance Mandatory compliance with average targets Failure to reformulate requires salt warning label Regulator can acquire information, ‘name and shame’, seek enforceable undertakings

17. Improving the Dialogue: Phase 3 ContentProcessesEnforcement Salt reduction targets apply to specific manufacturers’ portfolios Independent audit assessing participants’ performance and scheme performance overall Regulator seeks enforceable undertakings with penalties for non- compliance

18. Pie in the sky?

19. Thank you Belindareeve.com bhr7@georgetown.law.edu @Belindareeve