What’s New for Vitamin D Fortification and Labelling?

September 20, 2016

Vitamin D is a nutrient of public health concern according to the 2015-2020 Dietary Guidelines, so it has likely been on your radar.

Two new regulations will influence the amount of vitamin D that can be added to milk and plant-based alternatives and what people will see on food labels.

Milk Fortification

Since the 1930s, milk has been fortified with vitamin D to help prevent vitamin D deficiency rickets in children. In fact, milk is the number one food source of vitamin D in the American diet, based on what people actually report eating in the U.S. The Department of Health and Human Services (HHS) of the Food and Drug Administration recently amended the food additive regulations for the addition of Vitamin D2 and D3 to food. This amendment to the Generally Recognized as Safe (GRAS) regulation effectively doubles the level of fortification allowed in milk and expands the safe uses of vitamin D in “edible plant-based beverages intended for use as milk alternatives.” Under the final rule the following maximum levels of vitamin D are allowed in food:

  • Milk – 200 IU/cup (84 IU/100 grams)
  • Edible plant-based beverages intended as milk alternatives (i.e., soy, almond beverage) – 200 IUs per cup (84 IU/100 grams)
  • Edible plant-based yogurt alternatives –  151 IU per 6 ounces (89 UI per 100 grams)

Milk Labeling

Under the final rule for the Nutrition Facts label of FDA-regulated foods (effective July 26, 2016 and enforced as of July 26, 2018) the Daily Value (DV) for vitamin D has doubled to 20 μg (800 IU) to reflect current science. Percent Daily Value and actual amounts of vitamin D are now required to be included on the Nutrition Facts Panel of foods.

The Standard of Identity (SOI) for milk limits the voluntary addition of vitamin D to 100 IU per cup unless a nutrient content claim is made and has not changed. Therefore, if milk is fortified to the higher level (200 IU per cup) now allowed under GRAS, it is required to make a nutrient content claim for vitamin D on the label (i.e., High Vitamin D Milk). Milk alternative beverages have no SOI defining their composition, so are not required to make a nutrient content claim when fortified with vitamin D to the maximum level allowed.  

Since vitamin D can be synthesized in the skin from sunlight, insufficiency may be less of a problem if people didn’t spend so much time indoors, reside in northern latitudes or use sunscreen, among other things. For these and other reasons, many Americans may have insufficient vitamin D status, which experts say can lead to reduced calcium absorption and poor bone health. Few foods naturally contain vitamin D, so eating vitamin D-fortified foods can help people meet their needs for bone and musculoskeletal health.

Virtually all milk, some yogurts, some cheeses and many milk alternatives are currently fortified with vitamin D. As food companies may be changing the amount of vitamin D they add to foods, it’s even more important to educate people on food labels. 


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