IDFA Offers Guidance on Vitamin D3 Milk Fortification

September 29th, 2016


Category: Dairy, Policy

milk jugs450x299(IDFA) – The Food and Drug Administration last month announced updated food additive regulations that would allow manufacturers of milk and plant-based milk and yogurt alternates to add more vitamin D to their products. IDFA has prepared a memo for members to provide further guidance on the implications for dairy products and labeling requirements for products with higher levels of vitamin D3 for milk.


With FDA requiring changes to the Nutrition Facts label, the Daily Value (DV) reference amounts of many nutrients, including vitamin D, were revised. The recommended daily amount of vitamin D doubled from 400 IU (10 mcg) to 20 mcg. The chart below shows the impact on the % DV and the nutrient content claim based on the change.


Food Additive Updates

The revisions to the food additive regulations will allow milk companies to add higher levels of vitamin D3 to milk and continue to claim that the product is an excellent source of vitamin D. This allowance for increased vitamin D levels is effective immediately.

To match the Daily Value increase, the food additive regulations for vitamin D3 will allow companies to double the previous maximum level of vitamin D3, with increases up to 84 IU per 100 grams of milk or 800 IU per quart of milk. However, no changes were made to the standard of identity for milk, which still provides for only 400 IU of vitamin D per quart of milk. Products fortified with higher levels milk must include a nutrient content claim, such as “high vitamin D milk.”

Read the memo, “Impact of Recent Nutrition Labeling and Vitamin D3 Food Additive Regulation Amendments on Labeling of Vitamin D Milk,” for a better understanding of the options and labeling requirements.

Impact on PMO

IDFA also plans to meet with FDA’s milk safety staff to discuss the impact of this change on the Pasteurized Milk Ordinance, specifically in the Appendix “O” section of vitamin fortification. IDFA will request regulatory discretion for higher levels of vitamin D3 that match the amended food additive provisions for milk.

For more information, contact Cary Frye, IDFA vice president of regulatory and scientific affairs, or Michelle Matto, IDFA’s nutrition and labeling consultant, at

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