The inclusion of sub-categories within some of the product categories of the new salt model has provided better clarification. The sub-categories now take into account the diverse range of products, ingredients, recipes and technical issues that are applicable to some of the wider product categories e.g. ready meals.

Summary of comments:

The table below summarises areas where we feel the targets need revision, all other targets are felt to be achievable. The comments are a result of discussions with the M&S technical team.

The following lists category of food, followed by the FSA Proposed target in (salt per 100g), and then any relevant comments.

2. Reporting on progress

Marks & Spencer are in agreement with reporting on the salt content of our foods on an annual basis including maximum and average levels. This will be provided on a category basis as defined by the final salt model. It is important that the method of reporting is standardised across the food industry to ensure consistency in the way data is reported. We would suggest that a process and protocol for reporting are developed jointly with the FDF and BRC including a timeframe. An early understanding of the protocol would ensure that we are set up to deliver and can plan any additional resource requirements. We will also report on progress towards our internal targets and share any additional targets that we adopt.

It would be helpful for us to be provided with salt data from the independent surveys before they are published to check for any inconsistencies e.g. during the lapse in time between collecting the data and publishing, a product may have been reduced in salt and be in new packaging.

We would anticipate that the cost of reporting would arise from administrative and data management resource which would be additional, quantification is not possible until protocol is better understood.

3. Interim population targets

The establishment of an interim population target seems unnecessary and may result in confusion around the 2010 goal of 6g a day, especially by the media. It would be useful if the Food Standards Agency embarked on a consumer survey including urinary assessment data, to report on population progress towards the 2010 target (suggest results available by 2007). This would help to identify if the progress made by industry on salt reduction is parallel to the population change, and if not some explanation around why this is not the case.

Marks & Spencer remain committed to reducing salt in our foods and working to achieve our salt targets and will continue to do so not withstanding that we will not compromise the quality and safety of our products.