Since the publication of a statement on filled and imitation milks by this Committee in 1972,1 there have been both a proliferation of fabricated products that simulate milk and changes in regulations concerning them. Currently,"substitute" milk is defined by the Food and Drug Administration as nutritionally equivalent to whole or skim milk based upon its content of only 14 on 15 nutrients, omitting many nutrients that are recommended as necessary components of infant formula.2 There is no current requirement that these products undergo testing to evaluate their biologic activity or the bioavailability of these components. Fabricated products that simulate milk but do not meet the standard of identity for substitute milk proposed in 19783 must be labeled as "imitation" milk.
Neither substitute nor imitation milks meet the nutritional requirements for infant formula as proposed by this committee and incorporated into the Infant Formula Act of 1980. They should not be used as a major source of nutrition for infants. Popularity, extravagant claims, and special marketing practices cannot make white liquids nutritionally equivalent to infant formula.