This private blog replaces the earlier archives I had posted on the Internet and includes various memos sent to the clients of the VitaminLawyer.com (now the Vitamin Consultancy). It includes archived copies of memos from 2004 through 2007 and subsequent memos will be posted as they are issued.
Sodium and the DSHEA Label Listing Sodium in the Supplement Facts Box
Sodium Chloride -- table salt -- is listed as Generally Recognized As Safe (GRAS) as are a number of other forms of sodium.
Sodium as a nutrient must be shown on the Nutrition Facts label 
Sodium, like other nutrients, has a Daily Value -- the DV is under 2300 mg/day. The regulations require you to disclose the level of sodium in the product. You regularly see sodium disclosed on the Nutrient Facts Label for ordinary foods.
For a DSHEA product Supplement Facts Label there is a list of what must be included at 21 CFR 101.36(b)(2)(i)(B). This requirement includes disclosing Sodium if present.
However, whether something is present may depend on how it is measured and how the measurement is rounded. There are rounding-down rules for the SF label. 
So, if the product has less than 5 mg per daily serving (which is about 1/3 of 1% of the DV) the percent can be rounded down to zero and does not need to be included. (pg 129)
How much sodium is in a serving of your product? That is the question. I can help you figure that out. -- for sodium or any other ingredient. For my regular retainer clients I am adding an SOP section on rounding rules...
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