Feeding Infants in CACFP Child Care Programs

Infant Formula

The USDA requires that CACFP facilities with infants in their care must offer at least one type of iron-fortified infant formula [7 CFR 226.20(b)(2)]. A parent or guardian may choose to accept the offered formula or decline the offered formula and supply expressed breastmilk or an iron-fortified infant formula instead. This request is submitted by the parent/guardian to the CACFP facility using the CSDE's form, Accepting/Rejecting Infant Formula in the CACFP.


Definition of Iron-fortified Infant Formula  |   Creditable Infant Formulas
Purchasing Formula  |   Exempt Infant Formulas


Definition of Iron-fortified Infant Formula

The Food and Administration (FDA) defines iron-fortified infant formula as a product “which contains 1 milligram or more of iron in a quantity of product that supplies 100 kilocalories when prepared in accordance with label directions for infant consumption” [21 CFR 107.10(b)(4)(i)]. The number of milligrams (mg) of iron per 100 kilocalories (calories) of formula can be found on the Nutrition Facts label of infant formulas.

  • USDA Memo CACFP 06-2025: Feeding Infants and Meal Pattern Requirements in the Child and Adult Care Food Program; Questions and Answers 

Creditable Infant Formulas

CACFP facilities may use the criteria below to determine whether a formula is eligible for reimbursement.

  1. Ensure that the formula is not an FDA Exempt Infant Formula (refer to "Exempt Infant Formulas" below)
  2. Look for “Infant Formula with Iron” or a similar statement on the front of the formula package. All iron-fortified infant formulas must have this type of statement on the package.
  3. Use the Nutrition Facts label as a guide to ensure that the formula is iron-fortified. The nutritive values of each formula are listed on the product’s Nutrition Facts label. To be considered iron-fortified, an infant formula must have 1 mg of iron or more per 100 calories of formula when prepared in accordance with label directions.

The USDA requires that infant formulas must also meet the following FDA regulatory standards on infant formula:

  • the definition of an infant formula in section 201(z) of the Federal Food, Drug, and Cosmetic Act [21 USC 321(z)];
  • the requirements for an infant formula under section 412 of the Federal Food, Drug, and Cosmetic Act [21 USC 350a]; and
  • the regulations at 21 CFR 106 and 21 CFR 107.

These CACFP infant formula requirements are consistent with the Special Supplemental Nutrition Program for Women, Infants, and Children’s (WIC) infant formula requirements. This ensures that all infant formulas served in the CACFP meet nutrient specifications and safety requirements.

Purchasing Formula

CACFP facilities may purchase creditable infant formula online or in-person from retailers (e.g., local, regional or national vendors), pharmacies, and membership-based warehouses. If a formula is purchased outside of the U.S., it is likely that the formula is not regulated by the FDA. Infant formula imported into the U.S. as a result of the 2022 FDA Infant Formula Enforcement Discretion Policy may be served in the CACFP (refer to USDA Memo CACFP 01-2023 below). Infant formulas that are not regulated by the FDA are not creditable in the CACFP.

  • USDA Memo CACFP 01-2023: Creditability of Infant Formulas Imported Through the Food and Drug Administration’s 2022 Infant Formula Enforcement Discretion Policy in the Child and Adult Care Food Program.
  • Infant Formula (FDA)

Exempt Infant Formulas

An exempt infant formula is an infant formula labeled for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems, as defined in 21 CFR 107.3. The FDA's Exempt Infant Formulas Marketed in the United States by Manufacturer and Category webpage provides more information and a list of FDA Exempt Infant Formulas.

Formulas classified as exempt infant formulas by the FDA may be served as a part of reimbursable infant meal and snacks if the substitution is due to a disability and is supported by a medical statement signed by a state licensed healthcare professional or a registered dietitian.