Search Crunchy

Search for categories and articles

Is Baby Formula FDA Regulated?

📅 Updated February 2026⏱️ 5 min readNEW

TL;DR

The FDA does not approve infant formula before it is sold. Instead, manufacturers must submit a premarket notification 90 days before launch to prove they meet strict guidelines under the Infant Formula Act. While the FDA tightly controls nutritional content, they have historically lagged on enforcing strict limits for heavy metals, prompting new 2025 crackdowns following concerning independent test results.

🔑 Key Findings

1

The FDA requires a 90-day premarket notification but does not explicitly "approve" formulas.

2

Every formula sold in the US must meet minimum (and sometimes maximum) levels for 30 essential nutrients.

3

A 2025 Consumer Reports investigation found heavy metals or harmful chemicals in nearly half of 41 tested infant formulas.

4

Under California's new AB 899 law (effective 2025), formula manufacturers must publicly disclose their heavy metal test results.

The Short Answer

The FDA does not approve infant formula. Instead, they require a 90-day premarket notification before a new formula hits the shelves.

During this window, the FDA reviews the manufacturer's data to ensure the product meets strict nutritional and safety standards. If a formula fails to meet the legal requirements, the FDA can deem it "adulterated" and block it from the market.

Why This Matters

Most parents assume there is a rigorous FDA stamp of approval on every can of formula. There isn't—the system relies heavily on manufacturers self-testing and self-reporting to ensure compliance. Companies must prove their formulas support infant growth, but the FDA doesn't run the initial premarket tests themselves.

While the nutritional standards are ironclad, the system has glaring blind spots. The 2022 Abbott recall exposed major flaws in how the FDA inspects facilities for bacterial contamination like Cronobacter. This gap in oversight led to a massive nationwide shortage. Baby Formula Recalls

Furthermore, the FDA has historically dragged its feet on establishing strict limits for heavy metals in formula. A 2025 Consumer Reports investigation found concerning levels of heavy metals and chemicals in nearly half of 41 tested formulas. This finally prompted the FDA to announce new initiatives to ramp up their own testing protocols. Heavy Metals Baby Formula

What's Actually Required by the FDA

The Infant Formula Act of 1980 (and its subsequent updates) sets the rules of the road. Here is exactly what manufacturers must legally do before feeding your baby:

  • 30 Essential Nutrients — The FDA mandates exact minimum (and some maximum) levels for 30 specific nutrients, ensuring the formula provides complete nutrition.
  • Premarket Notification — Brands must submit their recipe, manufacturing processes, and safety assurances 90 days before selling.
  • Good Manufacturing Practices (cGMPs) — Facilities must be regularly audited, and every batch must be tested for pathogens like Salmonella and Cronobacter before shipping.
  • Shelf-Life Testing — Companies must conduct ongoing testing to prove the nutrients remain stable and potent throughout the product's entire expiration window.

What to Look For

Green Flags:

  • Clean Label Project Purity AwardThis third-party certification tests for over 400 contaminants, including heavy metals that the FDA misses. Safest Formula Brands
  • Made in an FDA-registered facilityThis ensures the manufacturing plant is subject to routine US health inspections.
  • Meets FDA nutrient requirementsLegitimate European formulas are great, but illegally imported ones bypass FDA safety checks entirely. European Vs American Formula

Red Flags:

  • Third-party online sellersBuying imported formula from unverified websites means the product bypassed FDA supply chain oversight and might have been stored in extreme heat.
  • No heavy metal transparencyThanks to California's AB 899 law, as of 2025, formula makers must publicly post their heavy metal test results. If a brand hides this data, skip it.

The Best Options

If you want formulas that go above and beyond the baseline FDA requirements—specifically for heavy metal testing and clean ingredients—here are top picks. Safest Formula Brands

BrandProductVerdictWhy
BobbieOrganic Infant FormulaClean Label Project certified, rigorously tested for heavy metals. Is Bobbie Good
ByHeartWhole Nutrition FormulaOwns their entire manufacturing process for ultimate quality control. Is Byheart Good
KendamilClassic & OrganicEuropean formula that legally meets FDA standards and imports safely.

The Bottom Line

1. The FDA regulates, but doesn't "approve." They review manufacturer notifications to ensure brands meet 30 strict nutrient requirements before going to market.

2. Heavy metals are still a blind spot. While the FDA is finally ramping up testing in 2025 and 2026, you should actively look for brands that voluntarily do third-party purity testing. Arsenic In Baby Formula

3. Be careful with imports. Legally imported European formulas are perfectly safe, but buying them off gray-market websites bypasses all FDA safety nets. European Vs American Formula

FAQ

Does the FDA test baby formula for heavy metals?

Historically, the FDA's "Closer to Zero" initiative focused heavily on baby food, leaving formula with vague guidelines. However, following a 2025 Consumer Reports investigation, the FDA launched new initiatives to aggressively test infant formulas for lead, arsenic, and PFAS. Lead In Baby Formula

Can the FDA recall baby formula?

Yes. If a formula is found to be contaminated or nutritionally deficient, the FDA can mandate a recall. Manufacturers are also legally required to notify the FDA within 24 hours if they initiate a voluntary recall. Baby Formula Recalls

Are European formulas FDA approved?

No formula is technically "FDA approved," but many European brands are now FDA compliant. During the 2022 shortage, the FDA relaxed rules to allow certain European brands (like Kendamil and HiPP) to be sold legally in the US, provided they met FDA nutritional standards. Why European Formula Expensive


References (9)
  1. 1. regulations.gov
  2. 2. fda.gov
  3. 3. fda.gov
  4. 4. nationalacademies.org
  5. 5. cbsnews.com
  6. 6. reedsmith.com
  7. 7. nih.gov
  8. 8. powershealth.org
  9. 9. fda.gov

🛒 Product Recommendations

Organic Infant Formula

Bobbie

Clean Label Project certified and rigorously tested for heavy metals beyond FDA requirements.

Recommended
Whole Nutrition Formula

ByHeart

Owns their entire manufacturing process for ultimate quality control and safety.

Recommended
👌
Kendamil Classic

Kendamil

A European formula that legally meets FDA standards and imports safely.

Acceptable

Nara Organics Whole Milk Infant Formula

Nara Organics

Launched in 2025, this is the first US-made FDA-registered formula to use organic whole milk (not skim) as its base, retaining natural Milk Fat Globule Membrane (MFGM). It holds the Clean Label Project Purity Award and is free from palm oil, soy oil, and corn syrup.

Recommended
Kabrita Goat Milk Infant Formula

Kabrita

As of 2024, this is the first and only European goat milk formula to meet all FDA requirements for long-term sale in the US. It is naturally easier to digest than cow milk and uses a clean lactose-based recipe without corn syrup solids.

Recommended

Pepticate Syneo

Pepticate

An excellent alternative for cow's milk allergy, this extensively hydrolyzed formula uses whey protein (better taste) and lactose rather than the high corn syrup solids found in competitors like Nutramigen. It is FDA-authorized and legally imported.

Recommended
Supreme A2 Infant Formula

Aussie Bubs

Winner of the Clean Label Project Purity Award, this formula uses A2 beta-casein milk which is gentler on digestion. It avoids palm oil and corn syrup, relying on a clean fat blend that tests show is free from concerning levels of heavy metals.

Recommended
Organic Premium Infant Formula

Baby's Only

Formerly a toddler-only brand, their reformulated infant product is a Clean Label Project Purity Award winner. It uses organic lactose as the primary carbohydrate and is packaged in PFAS-free canisters.

Recommended

Signature ProCare

Kirkland (Costco)

The best budget-friendly option, receiving a 'safe' rating in Consumer Reports' 2025 testing with little to no detectable heavy metals. It uses lactose as the primary sweetener and includes 2'-FL HMO prebiotics similar to name brands.

Recommended

Goat Infant Formula

Kendamil

Unlike the cow version, this uses whole goat milk fats which naturally contain A2 proteins for sensitive tummies. It is free from palm oil and soy oil, and legally meets all FDA nutritional standards.

Recommended
👌

Aptamil Gold+ Infant Formula

Aptamil

A leading New Zealand brand that is now FDA-authorized for US sale. It features a high quality prebiotic blend (GOS/FOS) and fish oil for DHA, offering a safe, regulated alternative to gray-market imports.

Acceptable
👌

Member's Mark Infant Formula

Sam's Club

Manufactured by Perrigo (like many store brands), this generic option tested cleanly in 2025 reviews for heavy metals. It offers a low-cost lactose-based profile without the premium markup of Enfamil or Similac.

Acceptable
👌

Similac 360 Total Care

Similac

While major brands often face scrutiny, 2025 Consumer Reports testing found this specific line had low/safe levels of heavy metals. It contains five types of HMO prebiotics to closely mimic breast milk immunity benefits.

Acceptable
👌
Enfamil Gentlease

Enfamil

A widely available reduced-lactose option that passed 2025 heavy metal screenings with 'little to no detectable' contaminants. A safer mainstream choice for gassy babies than full corn-syrup based alternatives.

Acceptable
⚠️

Enfamil NeuroPro (Ready-to-Use)

Enfamil

State of Florida 2026 testing detected concerning lead levels (13.47 ppb) in this specific ready-to-feed product, significantly higher than the 1-4 ppb found in other brands. Powdered versions tested lower but caution is advised.

Use Caution
🚫

Similac Alimentum

Similac

Consumer Reports' 2025 investigation found this hypoallergenic formula had the second-highest levels of inorganic arsenic (15.1 ppb) among all products tested. Parents should consider cleaner hydrolyzed options like Pepticate.

Avoid
🚫
EleCare Hypoallergenic

Abbott

Topped the 2025 Consumer Reports list for the highest levels of inorganic arsenic (19.7 ppb). As an amino acid-based formula for severe allergies, medical guidance is needed, but cleaner alternatives exist.

Avoid
🚫

ProSobee Soy Infant Formula

Enfamil

Soy formulas are naturally prone to higher heavy metal content; this product tested poorly for arsenic, cadmium, and mercury in multiple 2025/2026 reports. Additionally, it relies heavily on corn syrup solids.

Avoid
⚠️

Similac Sensitive

Similac

The first ingredient is corn syrup, comprising nearly all of its carbohydrate content. While it claims to help with 'sensitivity,' this high sugar load is nutritionally inferior to lactose-reduced formulas like Gentlease.

Use Caution
🚫

Soy Isomil

Similac

Like other soy options, it presents a higher risk of aluminum and cadmium contamination due to the nature of soy crops. It also uses corn syrup (39%) and sugar (10%) as primary ingredients.

Avoid
⚠️

Enfamil A.R.

Enfamil

Designed for spit-up, but Florida 2026 testing flagged this line for elevated mercury levels (3.13 ppb). Thickened alternatives with cleaner heavy metal profiles are safer choices for reflux.

Use Caution
🚫

Gray Market Holle

Holle

While the European product is excellent, boxes sold by third-party sites are NOT FDA-registered. They often lack English warnings and bypass temperature-controlled shipping, risking nutrient degradation.

Avoid
⚠️

Similac NeoSure

Similac

Listed as a 'worse choice' in recent 2025 heavy metal screenings due to elevated contaminant levels. Premature infants (the target demographic) are especially vulnerable to these environmental toxins.

Use Caution
🚫

Homemade Infant Formula

Generic

Absolutely unsafe. The FDA and CDC warn that homemade recipes lack critical nutrients like iron and contain unbalance ratios that can cause kidney failure, seizures, or fatal bacterial infections.

Avoid

💡 We don't accept payment for recommendations. Some links may be affiliate links.

📖 Related Research

👶

Explore more

More about Baby Formula

What's really in your baby's bottle