INFANTS Act Mandates Quarterly Testing for Toxic Metals in Baby Food

The Improving Newborns’ Food and Nutrition Testing Safety Act of 2025, or INFANTS Act, sets new federal rules requiring manufacturers of food intended for children up to 24 months old—including infant formula—to regularly test their products for harmful contaminants like lead, cadmium, mercury, and arsenic. Under Section 3, these companies must develop detailed written plans for sampling and testing, perform these tests at least quarterly using internationally accredited labs, and keep meticulous records for at least two years.

Keeping Contaminants Out of the Crib

This legislation zeroes in on reducing exposure to toxic elements often found in soil and water, which can make their way into baby foods. Section 3 mandates that manufacturers not only test for lead, arsenic, cadmium, and mercury but also any other contaminants the Secretary of Health and Human Services flags in the future. They'll need a solid, documented sampling plan approved via guidance the Secretary must issue within 18 months. Once that guidance is out, companies have 180 days to get their testing programs up and running. Think of it as a regular check-up for baby food safety, designed to catch potential problems before products hit the grocery store shelves.

Faster Flags for Formula Fouls

Beyond heavy metals, the Act ramps up oversight specifically for infant formula. Section 7 requires formula makers to notify the Secretary within just 24 hours if they find dangerous pathogens like Cronobacter or Salmonella in their products, even if the formula hasn't left the factory yet. They must then work with the Secretary on disposal and provide samples for verification. Section 8 adds another layer for powdered formula, requiring manufacturers to set up environmental monitoring programs to ensure their cleaning procedures are effectively preventing contamination in production areas. Furthermore, Section 6 gives the Secretary clear authority to order mandatory recalls if infant or toddler food is found to be adulterated with contaminants, strengthening the power to pull unsafe products quickly.

The Compliance Cost

These new safety measures come with increased operational demands for food companies. They'll bear the costs of quarterly testing, detailed record-keeping (Sec 3), and potentially providing extensive records to the Secretary upon request, even instead of an on-site inspection (Sec 5). Failure to comply with these testing requirements means the food is automatically considered 'adulterated' under the law (Sec 4), carrying significant legal and market consequences. While aiming for greater transparency and safety, the requirement for companies to provide records within a 'reasonable timeframe' and 'manner' at their own expense (Sec 5, Sec 8) introduces a degree of uncertainty that could impact how smoothly these checks are implemented.