Australia New Zealand Food Standards Code – Schedule 1 – RDIs and ESADDIs

The schedule distinguishes two types of intake standard. An RDI (Recommended Dietary Intake) appears where the scientific evidence for a nutrient is considered sufficient to establish a daily amount that meets the needs of nearly all healthy individuals in a given life‑stage group. An ESADDI (Estimated Safe and Adequate Daily Dietary Intake) is used where the evidence does not support a firm RDI, but a range or approximate value can be estimated for adequate intake without risk of toxicity. For example, biotin, pantothenic acid, vitamin K, chromium, copper, manganese and molybdenum are all designated ESADDIs in this schedule. This distinction matters for compliance: an ESADDI carries greater scientific uncertainty, which may affect how regulators assess a product’s labelling or fortification levels. The schedule covers 13 vitamins and 11 minerals, but only three age brackets: adults, children aged 1-3 years, and infants. There are no separate values for adolescents, older adults, pregnant or lactating women. Those groups are addressed elsewhere in the Code or in other interpretive documents. The adult column in the tables (column 3) does not define the age threshold for “adult”, leaving that to be determined by other provisions. The conversion factors for vitamin A (S1‑4) and vitamin E (S1‑5) are a further key concept. For provitamin A, synthetic and natural beta‑carotene have different conversion factors (6 and 12 µg per 1 µg retinol equivalents respectively), while beta‑apo‑8′‑carotenal and its ethyl ester both use 12. For vitamin E, the conversion factors vary by chemical form: dl‑alpha‑tocopherol requires 1.36 µg per 1 µg alpha‑tocopherol equivalents, whereas dl‑alpha‑tocopheryl acetate requires 1.49. Importantly, the table for vitamin E includes forms such as d‑alpha‑tocopherol concentrate and mixed tocopherols concentrate for which no conversion factor is given; subsection 5(1)(b) directs the user to determine a factor “by the composition of the form”. This introduces a judgment call for manufacturers and potentially a point of regulatory dispute. The schedule also contains notes referring to natural forms that may have conversion factors not provided in the tables, which adds compliance ambiguity.

The schedule directly affects any person or business that manufactures, imports, labels or sells food in Australia or New Zealand where the food contains added vitamins or minerals, or where it makes a nutrient content claim (such as “good source of vitamin C” or “high in calcium”). In practice this includes packaged food producers, supplement manufacturers, infant formula makers, meal replacement product companies, and food service operators who market products with nutrition claims. It also affects retailers, who must ensure that products on their shelves comply with the Code, and enforcement agencies such as state food safety authorities and the New Zealand Ministry for Primary Industries. For small businesses, the compliance burden can be disproportionally high because verifying that a product meets the correct RDI or ESADDI for each age group requires understanding the conversion factors and the different values. A product targeted at adults and children may need separate calculations if claims are made for both groups. Regulatory affairs staff, food technologists, and labelling consultants need to refer to this schedule when developing nutrition information panels or substantiating claims. The schedule also indirectly affects consumers, because the values determine the format and meaning of nutrition content claims on packaging. However, the schedule itself does not mandate any particular label layout; it is a data source. Imported food products must also comply if they are sold in Australia or New Zealand, so international food companies that export to these markets must align their nutrient declarations with the schedule’s values. In New Zealand, the schedule is incorporated or adopted under the Food Act 2014 (NZ), as noted in the text, so the same compliance obligations apply under that jurisdiction. Given the schedule is part of a trans‑Tasman code, differences in enforcement or interpretation between the two countries may create additional costs for businesses operating across the ditch. The amendment history shows that even small typographical corrections require formal gazettal, so stakeholders must monitor each amendment to ensure their references are current.

Schedule 1 does not on its own create duties or rights; those arise from the standards that cross reference it. The most important duty is that when a food’s label states a percentage of daily intake for a vitamin or mineral (e.g. “contains 50% of the RDI of iron”), that percentage must be calculated using the RDI or ESADDI values in this schedule for the appropriate age group. Under Standard 1.2.8 of the Code, nutrient content claims and percentage daily intake declarations are directly tied to these figures. A manufacturer therefore has a duty to ensure that the declared values are accurate with respect to the schedule. Conversely, the schedule gives manufacturers a right to rely on these standardised values as a safe harbour: if the values are correctly used, the labelling is presumptively compliant on that aspect. For vitamin A and vitamin E, the conversion factors in S1‑4 and S1‑5 impose a duty to convert the actual chemical forms present in the food into the required units (retinol equivalents and alpha‑tocopherol equivalents). Using a different conversion factor not specified in the table, or applying the wrong one for a particular form (e.g. using the factor for d‑alpha‑tocopherol when the product contains dl‑alpha‑tocopherol), exposes the manufacturer to potential enforcement action for mislabelling. The schedule also creates a duty for anyone adding vitamins or minerals to food to check whether the added amount for any age group exceeds an ESADDI upper level? The schedule does not provide upper levels; those are elsewhere. But the ESADDI value itself provides an adequacy benchmark; adding nutrients far above the ESADDI without an RDI may attract scrutiny. The right to use ESADDIs as the basis for claims is more constrained because ESADDIs imply less scientific certainty, and regulators may require additional justification for claims. Manufacturers also have a duty to keep up with amendments. The schedule’s footnote about uncommenced amendments appearing as shaded text in future compilations means a business relying on a compilation that is not the latest may inadvertently use outdated values. Finally, the schedule’s note that natural forms may have conversion factors not provided in the table imposes a duty on manufacturers of products with natural vitamin E or provitamin A to determine an appropriate factor based on composition, which is effectively a self‑regulatory obligation with no bright‑line rule.

This schedule does not prescribe any penalties. Penalties for non‑compliance arise from the Food Standards Australia New Zealand Act 1991 (Cth) and corresponding state and territory food acts, as well as New Zealand’s Food Act 2014. A breach of a standard in the Code is a criminal or civil penalty offence in most Australian jurisdictions. For example, selling food with a false or misleading nutrition content claim based on the wrong RDI can attract fines for the company and, in serious cases, custodial penalties for individuals. In New Zealand, maximum penalties for non‑compliance can reach NZ$500,000 for individuals and NZ$5 million for bodies corporate under the Food Act 2014, depending on the nature of the breach. Enforcement agencies include state and territory food authorities (e.g. NSW Food Authority, Victorian Department of Health) and the New Zealand Ministry for Primary Industries. The standard is enforced through audits of labels, product testing, and response to consumer complaints. Because the schedule is purely numerical, disputes often turn on whether the correct conversion factor was used or whether the age group applied was appropriate. A manufacturer who mistakenly uses the adult RDI for a product intended for children aged 1-3 years could be penalised if a claim implies a higher nutrient contribution than the children’s RDI would support. The schedule’s inclusion of ESADDIs for some nutrients means an enforcement officer may need to determine that “es” in “ESADDI” stands for “estimated safe and adequate”, and that using an ESADDI as if it were an RDI could be misleading. No specific litigation history is reported for this schedule, but general food labelling cases in Australia and New Zealand have involved disputes over the accuracy of daily intake percentages. The schedule itself is unlikely to be litigated directly; more likely it will be used as evidence in a prosecution under another provision. The technical nature of the conversion factors and age groups also means that expert evidence is frequently needed to establish whether a food business correctly complied. The cost of defending or contesting such a case can be high, creating a compliance burden that larger firms can absorb more easily than small competitors.

Schedule 1 is explicitly made under section 92 of the Food Standards Australia New Zealand Act 1991 and is part of the Australia New Zealand Food Standards Code. Its most direct interaction is with section 1.1.2-10 of the Code, which is the provision that references this schedule for the purposes of nutrition information. Standard 1.1.2 sets out definitions and general principles, and the schedule provides the specific numeric values required by that standard. The schedule also interacts with Standard 1.2.8 (Nutrition information requirements). Under that standard, when a label declares the quantity of a vitamin or mineral as a percentage of the daily intake, the percentage must be calculated using the corresponding RDI or ESADDI from this schedule. Standard 1.3.2 (Vitamins and minerals) governs the addition of vitamins and minerals to food, including permissible forms and maximum levels. The RDIs and ESADDIs in this schedule are used as benchmarks for those addition limits. For example, the maximum permitted level of a vitamin in a fortified food may be expressed as a multiple of the RDI. Schedule 1 also interacts with Standard 2.9.1 (Infant formula), which has specific nutrient requirements for infants. The schedule provides separate values for infants (with a split for iron based on age) that infant formula products must meet. Note that the schedule only gives values for infants overall and for children aged 1-3; there are no separate infant values for each month or for preterm infants. In New Zealand, the Code is adopted under the Food Act 2014 (NZ), as noted, so the schedule has direct legal effect there. The schedule may also be referenced in the Australia New Zealand Therapeutic Goods Administration’s guidelines for complementary medicines and supplements. It interacts with trade practices law: using the wrong RDI could constitute misleading conduct under the Australian Consumer Law (ACL), enforceable by the ACCC. The conversion factors in S1‑4 and S1‑5 specifically interact with any regulation that requires nutrient values to be expressed in retinol equivalents or alpha‑tocopherol equivalents. The amendment history shows corrections to cross‑references (Amendment 161 fixed notes to S1‑2 table), demonstrating the interconnectedness: a mistake in a note could affect the legal interpretation of multiple standards. The schedule does not itself interact with individual’s rights to food choice; it is a technical tool for ensuring consistent labelling.

Schedule 1 was originally published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00491). Since then it has been amended three times in compilation No. 3 (as at 29 November 2018). Amendment 161, which commenced on 1 March 2016, amended the entry for vitamin E in the table to S1‑2 and replaced the notes to that table to correct cross‑references. This indicates that even footnote references were considered significant enough to require a formal amendment. Amendment 168, with effect from 13 April 2017, corrected typographical errors in the entry for vitamin C in the table to S1‑2 and repealed and substituted subsection S1‑5(2) (the table and related note for vitamin E conversion factors) to update the list of tocopherol compounds. The shift from the original to the new table for vitamin E conversion factors changed the specified compounds, which would have required manufacturers to check whether their products used any of the newly listed forms. Amendment 182, commencing 29 November 2018, corrected typographical errors in S1‑4 (vitamin A conversion factors) and S1‑5 (vitamin E). The amendment history does not describe the nature of the errors, but the fact they warranted correction through the gazette process shows the level of precision expected. All amendments were made under section 92 of the FSANZ Act unless otherwise noted. The compilation notes that uncommenced amendments or provisions ceasing to have effect may be shown as shaded boxed text in future compilations. This means a diligent reader must consult the latest compilation on the Federal Register of Legislation, not merely the text provided at any point. The abbreviation “rs” (repealed and substituted) appears for the vitamin E section, confirming that Amendment 168 entirely replaced the previous subsection. The abbreviation “am” (amended) is used for smaller changes. New Zealand stakeholders need to follow the New Zealand Gazette notices as well. The fact that there have been only three amendments in the first few years suggests the schedule is relatively stable, but any future changes (e.g. updating RDIs based on new science) would have significant compliance cost implications.

The schedule itself has not been the subject of any reported litigation in Australia or New Zealand. This is unsurprising given its nature as a technical reference table; disputes tend to arise over the application of the schedule in conjunction with other standards. For instance, a case might involve a manufacturer who used the adult RDI for iron (12 mg) when the product was intended for children aged 1-3 years (6 mg) and made a “high iron” claim, leading to a prosecution for misleading labelling. In such a case, the tribunal or court would refer to Schedule 1 to determine the correct value. No such cases have been recorded in the public domain directly citing this schedule. The lack of litigation may also reflect the fact that enforcement agencies typically issue rectification notices or infringement notices before matters reach court. The compensation culture in Australia and New Zealand is not as active as in the United States; class actions over nutrient labelling errors are rare. However, the schedule could be indirectly relevant in a private action under the Australian Consumer Law for false or misleading representations about the nutritional attributes of a food. A plaintiff would need to show that the claimed percentage of RDI was wrong, and Schedule 1 would be the benchmark. Because the schedule is a legislative instrument, a court would take judicial notice of its contents. The schedule’s conversion factors for vitamin A and vitamin E could be litigated if a manufacturer used the wrong factor for a natural form not listed in the tables. The notes in both S1‑4 and S1‑5 state that natural forms may have conversion factors not provided, which creates an area of interpretive uncertainty. This could lead to a dispute over whether a particular natural form is covered by an entry or requires a self‑determined factor. No case law on this point exists yet. The amendment history shows corrections to typographical errors, which could have caused legal uncertainty if the error was substantial, but again no litigation appears to have resulted. Overall, the schedule’s litigation history is a blank slate, but that does not mean it is risk‑free; it simply means that compliance disputes are resolved administratively or through other enforcement mechanisms.

Several traps await the unwary in Schedule 1. First, the schedule provides only three age brackets. There is no separate RDI for toddlers beyond 3 years, adolescents, adults over 70, pregnant women, or lactating mothers. If a product targets a specific sub‑population not covered, the manufacturer must either use the adult value (which may be inappropriate) or rely on other provisions in the Code. The absence of a specific value does not mean the schedule is silent; it means the user must look elsewhere. Second, the iron values for infants split into two sub‑categories: 9 mg for infants from 6 months, and 3 mg for infants under 6 months. This is the only split in the schedule; all other nutrients have a single infant value. A manufacturer of infant formula must apply the correct sub‑category or risk non‑compliance. Third, the conversion factors for vitamin A are not all equal. Synthetic beta‑carotene has a factor of 6 µg per 1 µg retinol equivalents; natural carotenes require 12 µg. Using the wrong factor will miscalculate the vitamin A activity and could cause a product to be either under‑ or over‑declared. The note in S1‑4 warns that natural forms may have conversion factors not provided, so a product with a unique carotenoid (e.g. from algae or palm fruit) may require a bespoke factor. Fourth, the vitamin E conversion table in S1‑5 explicitly lists some forms with fixed factors (e.g. dl‑alpha‑tocopherol at 1.36) but leaves d‑alpha‑tocopherol concentrate, mixed tocopherols concentrate, and d‑alpha‑tocopheryl acetate concentrate without specified factors, referring to paragraph (1)(b) which says the factor is determined by composition. This creates a compliance risk: should a manufacturer analyse the composition each batch? Or can they use a factor from a recognised pharmacopoeia? The schedule does not answer this. The note says natural forms may have conversion factors not provided, adding to the uncertainty. Fifth, the schedule does not define the term “adult”. If a product is targeted at persons aged 12 and over, should the adult or child value apply? There is no guidance in this schedule; the answer lies elsewhere in the Code, but it is easy to miss. Sixth, the schedule’s ESADDI values for nutrients like chromium, copper, manganese and molybdenum are described as “estimated” and “adequate”, not “recommended”. Using an ESADDI as a substitute for an RDI when making a percentage claim could be challenged by regulators as misleading because it implies a stronger scientific basis than exists. Seventh, the schedule’s reference to “retinol equivalents” means that if a product contains added preformed retinol and beta‑carotene, the two must be combined using the conversion factors. A common mistake is to add retinol content directly without converting carotene. Eighth, the compilation note warns about uncommenced amendments appearing as shaded text. A business that downloads a compilation and does not check the date may overlook a future amendment that has already been published but not yet commenced, leading to double‑counting or incorrect values. Finally, the schedule applies in both countries, but differences in enforcement discretion between Australian states and New Zealand could lead to inconsistent outcomes for identical labels.

Compliance with Schedule 1 is not a standalone task; it requires integrating its values into a broader food regulatory compliance framework. The first step is to identify which nutrient(s) your product contains or for which you intend to make a claim. For each vitamin or mineral, note its status as RDI or ESADDI and the applicable values for each target age group. If you market the product to multiple age groups (e.g. “suitable for the whole family”), you must ensure the nutrition information panel and claims are accurate for each group. This may require separate calculations. For vitamin A, calculate the total retinol equivalents by summing the retinol content (in µg) and the provitamin A carotenoids converted using the factors in S1‑4. Synthetic beta‑carotene must be divided by 6, natural carotenes divided by 12. Keep a record of which conversion factor you used and the basis (e.g. supplier specification, analysis). For vitamin E, identify the exact chemical form(s) present. If the form is listed in the table with a specified conversion factor, use that. If it is a concentrate or mixed tocopherols not listed, determine the factor based on composition, preferably by an accredited laboratory using a validated method. Document the reasoning and the analytical data. For any claim expressed as a percentage of the RDI or ESADDI, divide the declared amount in the specified units by the relevant value from the schedule and multiply by 100. Ensure the age group used is clearly identified on the label (e.g. “% daily intake for adults”). If the product is intended for infants or young children, you must use the infant or child values (and the iron split for infants). For iron, confirm whether the product is for infants under 6 months (3 mg) or from 6 months (9 mg). Periodically check the Food Standards Australia New Zealand website for new amendments to Schedule 1. The compilation date on the Federal Register of Legislation should be verified before finalising label artwork. If an uncommenced amendment exists, decide whether to comply early or plan for a later transition. For products sold in New Zealand, ensure that any New Zealand‑specific adoption instruments are reflected. Consider engaging a food regulatory consultant to audit your calculations. For small businesses, the cost of this compliance can be significant relative to product margins, but the alternative (prosecution, recall, reputational damage) is worse. Maintain comprehensive records of all calculations, conversion factors used, and supporting analytical reports, as these will be needed if an enforcement officer queries the label. Finally, if you use natural forms of vitamin E or provitamin A not covered by the tables, obtain expert advice or a scientific determination of the appropriate conversion factor; do not guess.