What is “10% of the RDI” a percentage of? On a baby food it is a smaller number than the same words carry under the Code’s “any other food” column, and the Food Standards Code is the reason. It chooses which RDI column applies from who the food is for, and because the baby column sits below the any-other-food column in every Schedule 1 entry, the number behind the percentage on a baby food isn’t the one behind it on a food in that general column. The rule that sets the bar for a baby food is section 2.9.2-10 of Standard 2.9.2.
Which vitamin and mineral statements can a baby food make?
Section 2.9.2-10 sets conditions on two kinds of vitamin or mineral claim on a food for infants, and puts a percentage on each. For the first, that the vitamin or mineral is present, 2.9.2-10(2) reads: “A claim as to the presence of a vitamin or mineral in a food for infants may be made if the food contains in a normal serving at least 10% RDI or ESADDI, as appropriate, for that vitamin or mineral.” For “good source”, 2.9.2-10(3) reads the same way with 25% and “a reference quantity of the food” in place of a normal serving.
“Food for infants” has a definition. It is a food intended or represented as a source of nourishment for infants, and it leaves out infant formula products, formulated meal replacements, formulated supplementary foods and unprocessed fruit and vegetables. An “infant”, under Standard 1.1.2, is a person under 12 months. So the rule covers a food marketed to a baby, and a loose, unprocessed banana is outside it.
Which RDI is the percentage taken from?
The percentage is only half of it. The other half is the RDI, a daily reference amount that the Code lists for each vitamin and mineral, and the Code lists it three times. Section 1.1.2-10 says which column applies: Column 5 of the Schedule 1 tables for a food for infants, Column 4 for a food intended or represented as suitable for children aged 1 to 3 years, and Column 3 for any other food.
Take iron, whose RDI figures sit in the minerals section of Schedule 1. The arithmetic below is ours: 10% and 25% of the figures the Schedule prints. The Code does not print the results.
| Food is for | RDI for iron | 10% (presence claim) | 25% (good source) |
|---|---|---|---|
| Infants from 6 months | 9 mg | 0.9 mg | 2.25 mg |
| Children aged 1 to 3 years | 6 mg | 0.6 mg | 1.5 mg |
| Any other food | 12 mg | 1.2 mg | 3 mg |
Read down the table and the same four words, “10% of the RDI”, ask for 0.9 mg, then 0.6 mg, then 1.2 mg. A milligram is a thousandth of a gram, so the baby-food bar is nine-tenths of one of those. In proportion, it is three-quarters of the bar on an ordinary food, and the toddler bar is half. A serving carrying 1 mg of iron would clear the first two and miss the third. (That 1 mg is a made-up round number to show the effect, not a figure from any pack.)
One more wrinkle on that first row. The Code gives infants two iron figures: 9 mg for infants from 6 months and 3 mg for infants under 6 months. At 3 mg the 10% bar drops to 0.3 mg. Which of the two applies looks to turn on the age the pack is recommended for. That is our reading, not a sentence either instrument states. Under 2.9.2-7(2), a label must not recommend a food for infants under the age of 4 months, and under 2.9.2-7(3)(c) a pack recommended for infants under 6 months carries the warning “Not recommended for infants under the age of 4 months”. So a pack the 3 mg figure could apply to is one recommended for 4 to 6 months, and it carries that warning.
Now set the 9 mg beside the toddler column’s 6 mg. Iron is the one entry in Schedule 1 where the infant figure is higher than the figure for children aged 1 to 3 years, and the only one where the infant figure is split by age. Vitamin A, vitamin C (30 mg and 30 mg), vitamin D and zinc tie across those two columns, and every other entry is lower for infants. Against the “any other food” column the pattern is complete: across every one of the 24 entries in Schedule 1, the infant figure sits below the figure for any other food. That phrase is a term of art in 1.1.2-10(3). It means a food that is neither a food for infants nor a food for children aged 1 to 3 years, so a toddler pouch on the same shelf isn’t in it.
Four more nutrients, all genuine RDIs in Schedule 1, show the gap against the any-other-food column (the three RDIs are listed as infant / 1 to 3 years / any other food):
| Nutrient | RDI | 10% bar, infant food | 10% bar, any other food |
|---|---|---|---|
| Folate | 75 µg / 100 µg / 200 µg | 7.5 µg | 20 µg |
| Thiamin | 0.35 mg / 0.5 mg / 1.1 mg | 0.035 mg | 0.11 mg |
| Calcium | 550 mg / 700 mg / 800 mg | 55 mg | 80 mg |
| Vitamin C | 30 mg / 30 mg / 40 mg | 3 mg | 4 mg |
Vitamin C has a quirk: the infant and 1-to-3-years figures are the same, so those two bars match. Thiamin’s gap is the widest of the four: 0.035 mg on a baby food against 0.11 mg on anything else, more than three times. Folate is close behind, at 7.5 µg against 20 µg.
Does a lower bar mean a weaker food?
Nothing here says a claim on a baby food is misleading, or that a food clearing the lower bar is a worse food. What Standard 2.9.2 reaches here is how a baby food may be presented. Section 2.9.2-9(1): “A food must not be represented as being the sole or principal source of nutrition for infants.” That is a bar on what may be said about a food. The percentage lines up across columns and the milligrams don’t.
That matters the moment you compare labels. Hold a baby-food claim up against one on a food in the general column and you’re comparing a percentage of one number with a percentage of another. The words match, and 0.9 mg of iron against 1.2 mg is the gap behind them.
Where the general claims table sends baby foods
For most foods, the nutrition content claims table in Schedule 4 sets the vitamin and mineral condition: a serving with at least 10% of the RDI, and at least 25% for “good source”. Its entry carves food for infants out and says: “For food for infants, the food satisfies the condition for making a claim under subsection 2.9.2-10(2).” The cell names subsection 2.9.2-10(2) and nothing else.
The narrow version of what that does: for food for infants the entry sets a condition of its own, satisfying 2.9.2-10(2), and Standard 1.2.7 itself steps aside for a claim the Code expressly permits (1.2.7-6(a)). That isn’t the same as saying 1.2.7 has nothing to do with baby foods. It does not list food for infants among the products barred from nutrition content claims, and 1.2.7-8(a) still bars a claim that refers to “the prevention, diagnosis, cure or alleviation of a disease, disorder or condition”.
Three ceilings on what a pack may say
Standard 2.9.2 also limits what a baby food may claim in three places.
For a fruit-based food for infants, 2.9.2-10(4) bars a claim of more than 60 mg of vitamin C or more than 150 µg of folate per 100 g. That caps the claim, not the content: a fruit purée may hold more than 60 mg of vitamin C per 100 g, and the pack still may not say so.
For a cereal-based food for infants, 2.9.2-10(5) says that if a vitamin or mineral has been “used as a nutritive substance” in it, a claim must not say a normal serving contains more of it than the amount specified for it in the table to section S29-11, in Schedule 29.
A protein claim has its own test. Under 2.9.2-8(2) a food for infants may be called a source of protein only if at least 12% of its average energy comes from protein. That is a share of energy, with no RDI involved.
How firm each piece is
Three parts are hard rule. The wording of 2.9.2-10(2) and (3), the 10% and 25% figures, and the column assignment in 1.1.2-10 are written law, and you can read each one yourself on the legislation page.
One part is softer. Which column a given pack falls under depends on “intended or represented”, the Code’s words for who the food is for, and that is a judgement about the pack in your hand, not a number printed on it. The Schedule’s iron split by infant age works the same way. Our arithmetic is the softest of all: 10% and 25% of the Schedule’s figures, but it is ours. So this post can hand you the bar, and it can’t tell you what any product’s iron, folate or calcium figure is, or whether that figure clears it. For that you need the pack, and nobody read one for this post.
What a baby food can’t compare
Section 2.9.2-10(1) bars a claim comparing a food for infants’ vitamin or mineral content with that of any other food, unless Standard 2.9.2 expressly permits it elsewhere. The bar isn’t special to baby food: Standard 1.2.7-9 says “A claim that directly or indirectly compares the vitamin or mineral content of a food with that of another food must not be made unless the claim is permitted by this Code.” A pouch can state that iron is present. It can’t say it has more iron than another food. The 10% in a baby food’s claim is always a percentage of the baby column.
General information, not medical advice. Chat with your GP or child health nurse.
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