SGS Societe Generale de Surveillance : Global Regulatory Requirements for Baby Food

Baby food requirements vary around the world, but the desire to protect young children and promote healthy food is obvious. Many countries regulate this category, either as part of overall food regulation, or with baby food specific rules and guidelines.

Baby cereals and baby foods are commonly provided to infants that have been weaned and young children between the ages of one and three years. In some countries/ areas of the world, there are specific regulatory requirements, and for others these products are treated as any other food, with the possible exceptions of specific labelling or nutrient parameters. In comparison with infant formulas, these foods are not necessarily the sole or primary part of a diet, because other foods are slowly introduced. They are utilised in the transition from infant formula to adult food. Even so, children consuming these products are still developing and their daily diet must meet specific requirements. Hence, contaminants can cause more, and/ or permanent harm to this group because of their less developed immune system.

The American Academy of Paediatrics suggests that solid food should not be introduced until after a child is six months old. When solid foods are introduced to children, these foods are to be healthy and the child should be provided with a wide variety of foods and textures¹.

The real objective is healthy food, so this is the primary focus of their regulation. Since many of these foods are the same as those that will be eaten over the remainder of their lives, many countries' regulations include these foods as part of the overall food regulation requirements. As mentioned before, there are differences.

In the European Union (EU) these products do have some specific requirements for composition, such as protein, carbohydrate, fat, minerals, and vitamins, for some pesticides residues requirement levels below the standard 0.01 mg/kg not detected, labeling requirements, processing provisions and specific requirements for some additives. These regulations can be found in EU directive 2006/125/EC.² One of the labelling requirements is the presence, or absence, of gluten in products intended for infants below six months of age. Changes are forthcoming in the EU, on 20 July 2016 EU regulation 609/2013 will apply specific compositional and labelling rules for this category of products.

In 1981 a Codex Alimentarius standard was developed for Canned Baby Foods, STAN 73-1981, which was last updated in 1989. There is a Standard for processed Cereal-based foods for infants and young children, STAN 74-1981, a code of Hygienic Practice for foods for infants and children, CAC/RCP 21 -1979, and Codex Guidelines on formulated complimentary baby foods for older infants and young children, CAC/GL 8-1991. The standard states that the vitamins and minerals added to food must meet a country's requirements, and achieve as near to no pesticide residue as possible, with the products also being pathogen free.

There are specific maximum levels for some ingredients, established with a genuine concern about sodium levels. The only specific prohibition is that the product and its components shall not have been treated by ionizing radiation.³ The Code of Hygienic practices is concerned mainly with the practice of ensuring that the production process will produce a product that is safe for children to consume. The guidelines on formulation discuss some of the parameters for energy, fat, carbohydrates and protein. Energy density suggested is to be at least 4 kcal per gram on a dry weight basis. Protein should not be less than 6%, but not more than 15%, of the total energy of the product. At least 20% of the energy derived from fat is the desired level. For carbohydrates, sweeteners should be used sparingly and dietary fibres should be reduced to a level not exceeding 5g per 100g on a dry weight basis.

The United States (US) Food and Drug Administration (FDA) has almost no requirements for baby foods and generally includes these products with all foods. There are specific nutrient levels for children less than four years old, with specific parameters on how the nutrient facts panel must be displayed and what can be stated about the nutrients.⁴ As with all foods in the US, they are to be pathogen free, free of chemical contaminants, pesticide residues must meet the specific requirements and ingredients must be approved for use in foods. The US FDA established an inorganic arsenic action level of 10 parts per billion for apple juice.⁵

On 12 December 2012, South Africa issued a regulation to prevent the sale or import of any food other than formula, for infants less than six months old⁶. Much of this regulation concerns itself with the specific way foods can be marketed and labelled, in an effort to adhere to those recognised guidelines of not adding solid food into the diets of children less than six months old.

In New Zealand there has been pressure from consumer groups to adopt the pesticide residue levels established by the EU.⁷ It appears that in the most recent pesticide residue survey, in 2009, 30% of baby food had pesticide residues. The main concern about pesticide residues in baby foods is that they may affect a developing child and potentially disrupt endocrine and hormonal systems.

Testing of these products is similar to that of any other food product. Microbial and chemical contamination must be considered and tested for. Nutrient contents must be checked to ensure they are in compliance to the label statements and/or the regulations. Labels must be checked to make sure that they are in accordance with the requirements for the country in which they will be received. Processing requirements must take extra care to consider foreign materials and those materials that can cause choking, as young children are more susceptible. Choking is a common cause of injury and death in young children because their small airways are easily obstructed. Recalls on foreign materials in baby foods do occur, mainly due to glass fragments.

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Jim Cook
Food Scientific and Regulatory Affairs Manager
SGS North America, Inc.
|t +1 973 461 1493

1 American Academy of Pediatrics - Infant Food and Feeding

2 European Commission - Food - Food for Infants and Young Children

3 Codex Alimentarius International Food Standards

4 US FDA - Food Labelling Guide

5 US FDA - Arsenic in Apple Juice

6 Regulations Relating to Food Stuffs for Infants and Young Children Issued in South Africa on 6 Dec 2012

7 New Zealand Group Seeks Zero Tolerance for Pesticide Residues in Baby Food