Why does one milk carton carry an “under 2 years” line while the almond drink next to it says “under 5”? Turn either carton over and find the nutrition panel. The Food Standards Code picks the age with a mechanical test on two of its numbers, protein and fat, and neither number is read off your child. The reason for the lines is a different matter, and the regulator states it: FSANZ says “Children need sufficient protein and energy for normal growth and development.”
Both lines are mandatory. Whichever carton you are holding, its line says the product isn’t a complete milk replacement for a child younger than a stated age.
The two cartons are Pauls Trim Low Fat Milk and So Good Unsweetened Almond, 1 L. Each brand publishes its nutrition information per 100 mL, so you can set the two side by side:
| Per 100 mL | Pauls Trim Low Fat Milk | So Good Unsweetened Almond |
|---|---|---|
| Protein | 3.2 g | 0.6 g |
| Fat | 1.2 g | 1.4 g |
| Energy | 194 kJ (46 Cal) | 69 kJ (16 Cal) |
| Calcium | 113 mg | 120 mg |
What the Code asks for
Standard 1.2.3 is short on this: you’ll find that if a food is listed in the Schedule 9 table, “the corresponding advisory statement in Column 2 of that table is required”. Column 2 of that table is headed “Advisory statement indicating that …”, so what has to be on the carton you pick up is a statement with that meaning. Schedule 9 doesn’t hand over a fixed sentence, so the sentence on your carton can differ from the one on the next brand’s.
Two entries in that table matter for the cartons you are comparing. Item 2 covers a beverage made from cereals, nuts or seeds that contains less than 3% m/m protein, and it attaches the statement that the product is not suitable as a complete milk replacement for children under 5 years. Item 3 attaches a statement of the same form, naming “under 2 years” instead, to a nut, seed or cereal beverage with no less than 3% m/m protein and no more than 2.5% m/m fat, and to milk, or a soy analogue of it, with no more than 2.5% m/m fat.
The table was last amended on 1 September 2016, to bring nuts and seeds into items 2 and 3, and has stayed as it is since.
Read the milk limb again. For milk, item 3 has one condition: fat, at no more than 2.5% m/m. You won’t find a protein test in it.
One item for each carton
If you are holding the Pauls Trim, it is cow’s milk, so item 2 can’t reach it, because item 2 is about cereals, nuts and seeds. Its fat is 1.2 g, under the 2.5 line, so item 3’s milk limb applies and the age is 2.
If your carton is the So Good, the almond drink is a nut beverage with 0.6 g of protein, well under 3, so item 2 applies and the age is 5. Item 3’s nut limb can’t apply to it, because that one needs protein of no less than 3% and 0.6 isn’t. Its other limb covers milk and soy, and almond is neither.
One item per carton, and the panel numbers explain which. The almond drink gets “under 5” for having 0.6 g of protein where item 2 draws its line at 3% m/m.
What a glass of each holds
Pour a 250 mL glass from each and the “under 5” carton carries more fat in it than the “low fat” one. Both brands print a 250 mL serving and a full per-serve column, so these are the brands’ own figures, which you can check on their pages, and not a multiplication of the table above:
| Per 250 mL serving, as printed | Pauls Trim Low Fat Milk | So Good Unsweetened Almond |
|---|---|---|
| Fat, total | 3.0 g | 3.5 g |
| Protein | 8.0 g | 1.4 g |
| Energy | 485 kJ (116 Cal) | 173 kJ (41 Cal) |
| Calcium | 283 mg (35% RDI) | 300 mg (37% RDI) |
- Fat: 3.5 g in a glass of the almond drink against 3.0 g in the Trim. The plant drink has slightly more fat per glass than the low-fat milk, and item 2 asks about protein only.
- Protein: 8.0 g in the Trim against 1.4 g in the almond drink, 5.7 times as much.
- Energy: 173 kJ against 485 kJ, a little over a third as much from the almond drink.
For the milk, 8 g of protein isn’t a figure to maximise. NHMRC says “After 12 months of age the consumption of cow’s milk should be limited to around 500 mL because of the high protein and low iron content … and the risk of reducing diversity in the diet.” Two 250 mL glasses is that limit.
Calcium is the second row where the almond carton prints the higher figure, and unlike fat it is the one that looks like a nutritional match when you read across the row. FSANZ says “Generally, plant-based milk alternatives don’t have the same nutrient content as cow or goat milk. Milk generally contains higher levels of protein and a wider range of vitamins and minerals”, and that these beverages “are permitted to have vitamins and minerals added in amounts similar to milk” (FSANZ). The word is “permitted”. One row that matches doesn’t make the two cartons match, and the protein row is the one the Code’s test reads.
For scale on the fat in the low-fat milk: NHMRC puts the usual fat content of full-cream milk at 4% and the Trim panel shows 1.2 g per 100 mL, roughly a third of that. Percent and grams per 100 mL aren’t the same unit, as the next section explains, so this is a comparison for scale only.
The unit that does not match
The Code’s thresholds are m/m, which means grams per 100 grams. The panels are grams per 100 millilitres. A litre of a drink doesn’t weigh exactly a kilogram, so the two aren’t interchangeable, and Peeka couldn’t find a density for either product. That means a panel figure can’t be called the Code’s figure.
It doesn’t change either answer, and the arithmetic shows why. For the Trim’s 1.2 g of fat per 100 mL to reach 2.5 g per 100 g, converting between volume and mass would have to roughly double it. For the almond drink’s 0.6 g of protein to reach 3 g per 100 g, the conversion would have to roughly quintuple it. Nothing about turning millilitres into grams does that to a drink. Both cartons sit far enough from their thresholds that the mismatch can’t tip them, though a figure close to a line would be harder to call.
FSANZ’s own consumer page says to check “the amount of protein in the Nutrition Information Panel” (FSANZ, Plant-based milk alternatives). That’s a fair first look for a plant drink, and the Code’s test is the m/m one.
The same FSANZ page describes the under-2 line as applying to products “that have adequate protein but are low in fat”. That’s a paraphrase, and it’s looser than the Code. For milk, the Code asks about fat alone. Use the FSANZ page for the fact that both lines are required on the label, and the Code’s table for when each one applies.
Why the lines exist
The test is mechanical, and the two documents behind it say what the line on your carton is for. If you are holding the almond drink, FSANZ’s answer to “Why do plant-based beverages have an advisory label?” is: “If beverages like almond or rice beverages are a regular part of a young child’s diet, other food sources of protein and energy need to replace the protein and energy otherwise provided by milk.”
If you are holding the Trim, NHMRC’s infant feeding guidelines describe a fat content of 0.1 to 2.5% against the usual 4% in full-cream milk, and say “In nutritional terms the 4% of fat in milk contributes up to 50% of its energy content. These lower energy and fat levels are not nutritionally suitable for children aged less than 2 years.” Its Table 9.2 gives the mechanism: “Dietary fat is an important source of energy and essential fatty acids and promotes the absorption of essential fat-soluble vitamins – restriction in infancy may adversely affect growth, development and myelination of the central nervous system”. The operative advice for parents is that low-fat and reduced-fat milks “are not recommended in the first 2 years of life”.
The numbers the test reads line up with those reasons: protein and energy for plant drinks, fat and energy for reduced-fat milk. Neither document explains why the cut-offs sit at exactly 3% and 2.5%. The Code’s 2.5% fat line and NHMRC’s “0.1 to 2.5%” range are the same number, and no source Peeka read links the two figures.
What the printed age leaves unanswered
“Complete milk replacement” is a narrow phrase. The line on the carton in your hand says what the product is not. It doesn’t tell you what to give instead, and the two lines don’t rank one carton against the other: the ages come from different panel numbers, and neither is a verdict on the drinks. A line that doesn’t rank the cartons also doesn’t make them equal. NHMRC names its preferred drinks for the second year of life as water and pasteurised full-cream milk, offered in a cup rather than a feeding bottle, and neither carton here is full-cream milk.
For a child under 12 months the answer is in NHMRC’s text, “Breast milk or infant formula should be the main drink in the first 12 months”, and “Consuming any other drinks in the first 12 months may interfere with an infant’s intake of breast milk or infant formula”. On cow’s milk specifically, NHMRC says it should not be given as a main drink to infants under 12 months, though for full-cream cow’s milk “small quantities may be given as part of solid foods, such as custards and on cereal”. That permission sits under the heading “Cow’s milk (full cream cow’s milk)”. Low-fat and reduced-fat milks are covered by a separate heading, and the advice there is that they “are not recommended in the first 2 years of life”, with no custards-and-cereal exception. A reduced-fat carton such as the Trim doesn’t inherit the full-cream permission.
On plant drinks, NHMRC says “Soy (except soy follow-on formula) and other nutritionally incomplete plant-based milks (e.g. rice, oat, coconut or almond milk) are inappropriate alternatives to breast milk or formula in the first 12 months.” After 12 months, the options it names are fortified soy drink, or calcium-enriched rice and oat drinks, and then only a full-fat variety, with other sources of protein and vitamin B12 in the diet, “under health professional supervision”. Almond isn’t on that second list. That’s an observation about what the document names, not a ruling on any particular almond drink.
So Good’s drink is made from almonds, a tree nut, and Schedule 9 (S9-3, table item 4) lists almond as a required name that must be declared as “almond”. FSANZ says these products “are not suitable for anyone allergic to the substance(s) from which the beverages are derived, such as soy or oats. Young children with an allergy/intolerance may be advised about a hypoallergenic formula, which is suitable as a complete milk replacement.” Its advice is to “Talk to a dietitian or doctor if you are considering drinking plant-based beverages, or giving them to a child as an alternative to milk.” A nutrition panel can’t answer an allergy question, and neither can this post.
From the Code’s text to Peeka’s own arithmetic
Not all of this stands on the same ground.
- Firmest, the Code’s own text. Items 2 and 3, the m/m thresholds and the “advisory statement indicating that” wording, read from the in-force legislation.
- Firm, and the source that states reasons: FSANZ. It is the regulator’s consumer page, last updated 26 November 2025, and it carries the rationale for the lines, the allergy note and the referral. One narrow point stands: its wording “that have adequate protein but are low in fat” is a looser paraphrase of the under-2 trigger than the Code’s item 3(c), which tests fat alone.
- Firm but different in kind, NHMRC. It’s national guidance and the publication page lists it as current, but it was written for health workers, isn’t law, and dates from 2012 with a 2015 revision. The sections quoted here are the unrevised ones.
- Peeka’s own read, not sourced. The observation that the Code’s 2.5% fat line and NHMRC’s “0.1 to 2.5%” range are the same number; no source links them. The unit arithmetic is Peeka’s own too: sound as arithmetic, resting on an assumption no one sourced, that volume-to-mass conversion for a drink can’t move a figure by a factor of two.
The other gap is the cartons themselves. The nutrition figures come from the two brands’ websites on 21 October 2026, and a website can lag a pack already on the shelf. The printed advisory sentence on each carton couldn’t be read from a web page, and since the Code asks for a statement with a given meaning and not fixed wording, yours may be phrased differently. The carton in your hand settles it: find the protein row, the fat row, then the advisory line, and see whether the age you find matches the pattern above.
General information, not medical advice. Chat with your GP, child health nurse or a dietitian.