Labeling Rules
For Young Children's Foods
by Paula Kurtzweil

     How much fat should we eat to stay healthy? For adults, the
answer is clear: The Dietary Guidelines for Americans tell us to
restrict fat to no more than 30 percent of our total calorie
intake.
     But for infants and toddlers, the answer is less
straightforward; the Dietary Guidelines don't apply to children
under 2. In fact, health experts advise against restricting fat
in young children's diets because they need the calories and
nutrients fat provides to grow and develop properly.
     For this reason, FDA and the U.S. Department of
Agriculture's Food Safety and Inspection Service have established
special rules to govern the labeling of foods for children under
4. (USDA regulates labeling of meat and poultry products. FDA
oversees labeling of all other foods.)
     Just as for other foods, the regulations require labels for
foods for young children to include information about nutrients
important to health--for example, fat, sodium, carbohydrate,
protein, vitamins and minerals. This is to help parents choose
foods that contain the appropriate kinds and amounts of nutrients
their children need.
     But the new regulations forbid labels for foods for children
under 2 to carry certain nutrition information because the
presence of the information may lead parents to wrongly assume
that certain nutrients should be restricted in young children's
diets, when, in fact, they should not.
     In addition, the labels for foods for children under 4
cannot show how the amounts of some nutrients correspond to Daily
Values--recommended daily intakes. The reason is because Daily
Values for some nutrients, such as fat, fiber and sodium, have
not been established for children under 4. This is because
current dietary recommendations do not specify appropriate levels
for young children. FDA has set Daily Values only for vitamins,
minerals and protein for this age group because the National
Academy of Sciences has established appropriate levels of these
nutrients for this age group in the Recommended Dietary
Allowances. FDA incorporated those recommendations in the Daily
Values. (See "'Daily Values' Encourage Healthy Diet" in the May
1993 FDA Consumer.)

Up-to-Date Label
     These labeling requirements stem from the Nutrition Labeling
and Education Act of 1990, which, among other things, requires
labels of most foods--including those for children under 4--to
carry nutrition information.
     The children's nutrition labeling rules apply to most foods
whose labels suggest that the food is intended for infants and
toddlers. This includes infant cereals, infant strained meats,
vegetables and fruits, "junior" foods, teething biscuits, and
infant and "junior" juices. The regulations do not apply to
infant formula, which has special nutrition labeling
requirements.
     Many foods for infants and toddlers have carried some
nutrition information since at least the 1970s, when voluntary
nutrition labeling went into effect. But now, for many such
foods, the  information is required and more pertinent to today's
health concerns. (See "Good Reading for Good Eating" in the May
1993 FDA Consumer.)

Importance of Fat
     Concerns about excessive fat and cholesterol intake for most
of the population don't apply to children under 2, however. Fat
is one of six nutrient categories essential for proper growth and
development. (The others are protein, carbohydrate, water,
vitamins, and minerals.) At no other age does fat play such an
important role as in infancy and early childhood, a period of
rapid growth and development. Dietary fat serves as:
     a source of energy (infants and toddlers have the highest
energy needs per kilogram of weight of any age group)
     a carrier for the fat-soluble vitamins A, D, E, and K and as
an aid in their absorption in the intestine
     the only source of linoleic acid, an essential fatty acid.
     Fat also gives taste, consistency, stability, and
palatability to foods and converts to body fat, which is
necessary to hold organs in place, absorb shock, and insulate the
body from temperature changes.
     Some parents fail to realize fat's importance for young
children. According to a Gerber Products Co.'s telephone survey
of 1,076 adults, nearly one in five respondents said they reduce
the amount of fat in their baby's diet.
     Yet, according to Virginia Wilkening, a registered dietitian
and consumer safety officer in FDA's Office of Food Labeling,
case reports have shown that limiting fat intakes in very young
children can cause them to "fail to thrive."
     "Babies need fat and cholesterol in their diets for proper
growth and development," Wilkening said. "Parents should be aware
of this and avoid reducing fat in their young children's diets."

Restrictions
     For foods for children under 2, the amount of saturated fat,
polyunsaturated fat, monounsaturated fat, cholesterol, calories
from fat, and calories from saturated fat in the food cannot be
listed on the label.
     Labels of foods for children under 2 also cannot carry most
of the claims about a food's nutritional content--such as "low-
fat" and "low-cholesterol"--that labels of other foods can. (See
"A Little 'Lite' Reading in the June 1993 FDA Consumer.) And,
they cannot carry the eight FDA-approved health claims about the
relationship between a nutrient or food and a health problem--for
example, dietary fat and cancer--that other labels can. (See
"Starting This Month, Look for 'Legit' Health Claims on Foods" in
the May 1993 FDA Consumer.)

Allowed Facts
     What information is allowed? The following is a list of
dietary components about which information is allowed on the
Nutrition Facts panel on the labels of foods for children under
2. Information usually appears on the side or back of the package
and is mandatory for underlined components.
     total calories
     total fat
     sodium
     potassium
     total carbohydrate
     dietary fiber
     soluble fiber
     insoluble fiber
     sugars
     sugar alcohol
     protein
     vitamin A
     vitamin C
     calcium
     iron
     other essential vitamins and minerals. (Information about
them is mandatory only when they are added to enrich or fortify a
food, or when a claim is made about them on the label.)
     Labels for foods for children 2 to 4 also must give the
amount of cholesterol and saturated fat per serving. They can
voluntarily provide the calories from fat and calories from
saturated fat, and the amount of polyunsaturated and
monounsaturated fat per serving.
     The %Daily Values for protein and vitamins and minerals
present in significant amounts must be listed. This helps parents
see how a serving of food fits into their child's total daily
diet. The amount of other nutrients is given in grams or
milligrams.

Serving Size
     The serving size, under "Nutrition Facts," is the basis on
which manufacturers declare the nutrient amounts and %Daily
Values on the label. It is the amount of food customarily eaten
at one time--not necessarily the amount recommended by dietary
guidelines.
     The serving size is based on FDA- and USDA-established lists
of "Reference Amounts Customarily Consumed Per Eating Occasion."
FDA has established 11 groups of foods specially intended for
children under 4. USDA has four such groups.
     The serving size must be stated in both common household
units and metric measures--for example, for dry instant cereal,
"1/4 cup (15 g)."
     These standardized serving sizes make it easier to compare
the nutritional quality of similar foods.

Nutrient and Health Claims
     FDA and USDA's regulations also extend to label claims.
     Among the few allowed in children's nutrition labeling are
claims that describe the percentage of vitamins or minerals in
the food as they apply to the Daily Values for children under 2--
for example, "provides 50 percent of the Daily Value for vitamin
C." This type of claim also is allowed in the labeling of dietary
supplements for children under 2.
     Also allowed for foods for children under 2 are the claims
"unsweetened" and "unsalted." FDA believes that for foods for
this age group, these claims refer to taste and not nutrition.
     Two claims--"no sugar added" and "sugar free"--are approved
only for use on dietary supplements for children under 2 because
they often contain added sugar.
     If presented with sound evidence, however, FDA will consider
allowing other nutrient content claims, as well as health claims,
in the labeling of foods for children under 2.
     These and other rules are intended to help consumers select
the best foods for children. The absence of some information
allowed in labeling for other foods can help them do that. 

Paula Kurtzweil is a member of FDA's public affairs staff.