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Potential risks for children associated with the introduction of a fat (consumption) reduction factor
provided by fat in the diet. Since fat provides 9 kcal / g, the fat consumption would be
44 g / day. For a 10 kg bodyweight child this would be a consumption of 4.4 g fat / kg bw / day.
This is higher than the maximum fat consumption of 3.3 g / kg bw / day for an adult that was
used as a basis for the introduction of the FRF.
As children get older their energy requirement on a bodyweight basis is lower. Potential fat
consumption can be assessed for an example of a child aged 10 years. According to European
Recommended Dietary Allowances, at this age an average body weight is 30 kg and an average
energy requirement is 68 kcal / kg bw [CEC, 1993]. In order to assess potential consumption
for a child with an average energy intake consuming a diet high in fats, it was assumed that 50%
of the energy requirement was from fat. This assumption leads to a conservative (but not
unrealistic) estimate of 3.8 g fat / kg bw / day. This figure is very similar to the upper limit of
fat consumption of 3.3 g / kg bw / day that was used as a basis for the introduction of the FRF.
The Fat (Consumption) Reduction Factor is to be introduced because it has been demonstrated
that total daily fat consumption by European adults does not exceed 200 g fat / person / day.
For the conventional 60 kg adult this is 3.3 g fat / kg bw / day. Infants and children have a
higher fat intake than adults on a body weight basis, which may range, for high fat diets, from
6.5 - 3.8 g fat / kg bw / day, considering the energy requirements of infants and children from 6
months to 10 years of age. The fact that the experimentally determined migration should be
divided by the FRF in order to test compliance with the SML, might imply the need for a lower
FRF for infants and children because they may consume more fat on a body weight basis. In
practice, however, the FRF will not be applicable to a number of the foods they consume.
In the case of milk, ready-to-feed infant formulae and pre-packaged baby foods, the FRF is not
applicable because these foods all contain less than 20% fat. In the case of dry powdered
formulae or liquid concentrates, even if the standard FRF for adults were to be applied to the dry
powder or concentrate to assess compliance of the packaged product with any SML, the large
dilution with water to make it ready-to-feed would ensure that the concentration in the product
as consumed by the infant would be far below the respective SML. Therefore, in practice, no
special FRF is needed for infants in relation to consumption of milk, infant formulae or pre-
packaged baby foods.