CHEATING BABIES

CENTER FOR SCIENCE IN THE PUBLIC INTEREST

TABLE OF CONTENTS

Page number SUMMARY AND RECOMMENDATIONS ........................................................ 1

MAJOR FINDINGS ........................................................................................... 1 WHAT PARENTS SHOULD DO .................................................................... 2 RECOMMENDATIONS TO THE FOOD INDUSTRY ................................. # RECOMMENDATIONS FOR GOVERNMENT ACTION ................................. #

INTRODUCTION ...................................................................................................... NUTRITION: FIRST-STAGE FOODS .................................................................... #

FRUITS AND VEGETABLES .................................................................... # NUTRITION: SECOND-STAGE AND THIRD-STAGE FOODS ...................... #

FRUITS AND VEGETABLES .................................................................... # Fruit with tapioca ............................................................................... #

Mixed and creamed vegetables ........................................................ # Other Findings ............................................................................... #

DINNERS ...................................................................................................... # OTHER PRODUCTS ............................................................................... #

Foods with Yogurt ............................................................................... # Desserts ........................................................................................... # Jarred and Instant Cereals .................................................................... #

Meats ...................................................................................................... # TASTE .................................................................................................................. ## COST .................................................................................................................. ##

THE COST OF DILUTION WITH WATER AND STARCHY FILLERS .......... ## THE COST OF INNOVATIVE PRODUCTS ............................................. ## COST COMPARISONS WITH REGULAR FOODS ................................. ##

Applesauce ........................................................................................... ## Fruit Juices ........................................................................................... ## Toddler Foods ............................................................................... ##

REGULATION OF BABY FOOD LABELING ........................................................ ## TABLES .................................................................................................................. ##

1. FRUIT AND VEGETABLE CONTENT OF FIRST-STAGE FOODS 2. NUTRITIONAL COMPARISON OF “BANANAS” AND “PRUNES”

WITHOUT AND WITH TAPIOCA 3. NUTRITIONAL COMPOSITION OF “CHICKEN AND NOODLES”

DINNERS 4. NUTRITIONAL COMPARISON OF SECOND-STAGE DINNERS

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CONCLUSIONS AND RECOMMENDATIONS

Parents expect baby foods to be just as nutritious as possible—to live up to Heinz’ slogan “Only the best ingredients for the best nutrition.” This report was intended to inform parents about nutritional differences among types and brands of commercial baby foods and to discourage them from paying high prices for baby food. While our study indicates that some baby foods are diluted, they do not appear to endanger the health of infants, inasmuch as most of infants’ nutrition comes from breast milk, formula, or cow’s milk. I. MAJOR FINDINGS • Gerber and Heinz replace real food with water and thickening agents in many of

their products for children over six months of age. Such adulterated products are nutritionally inferior to products made with more fruits and vegetables.

The single-ingredients foods made by all the companies differ only modestly as a result

of adding somewhat different amounts of water. However, Gerber and Heinz add substantial amounts of water and thickening agents (flours and chemically modified starches) to more than half of their twenty-five most popular fruits, mixed and creamed vegetables, desserts, and dinners for babies over six months (second- and third-stage foods). Not only are those products a monetary rip-off, they are also nutritionally inferior to similar products made without fillers. Gerber and Heinz’ bananas with tapioca, for example, contain less of than half of the levels of nutrients found in their plain first-stage bananas. Gerber and Heinz’ regular dinners, which contain at least two types of refined flour as thickeners, provide less than 50% of the nutrient levels found in comparable dinners made by Growing Healthy, which are made from whole foods and contain no starchy fillers. Many fewer products made by Beech-Nut and Earth’s Best contain starchy fillers. • Baby foods are very high priced compared to similar regular foods.

Baby foods cost far more per ounce than conventional national brands or supermarket brands. For example, parents often pay more than double for baby food fruit juices and applesauce. Gerber Graduates diced fruits and vegetables are also more than twice the price of comparable products available in the canned goods aisle. For the majority of puréed baby foods, there are no comparable regular products. However, judging from the instances in which direct

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comparisons can be made, these baby foods are also priced far higher than they would be in a competitive industry. • Makers of baby food encourage a mystique about their products. They want

parents to think that commercial baby foods have special properties that make them particularly appropriate, if not essential, for infants.

Advertising campaigns promote the myth that commercial products are especially good at

meeting the nutritional and developmental needs of infants. Gerber’s public relations and advertising machinery has cultivated an almost sacred image in people’s minds of Gerber products. Those perceptions are clearly untrue. Parents, armed with a food processor, blender, or mashing fork, can easily prepare safe, nutritious, and economical food for their infants at home. Of course, many commercial products are nutritious and do fill a need when convenience is desired. II. WHAT PARENTS SHOULD DO

To give your baby the most nutritious and economical food:

• Prepare your own baby foods whenever possible.

With a blender or food processor it is easy to make a purée of most foods. Soft foods, like bananas, can be mashed with a fork. All foods, with the exception of bananas, should be well cooked. Refrigerate any foods that are not used right away. You can make large batches of baby foods, freeze them in ice-cube trays or small containers, and thaw them as needed.

• When buying commercial baby food, compare labels carefully.

Look at ingredient lists. Avoid products that contain added sugars, modified food starches, or wheat, rice, and other flours. When buying single fruit, vegetable, or meat products (i.e., foods that contain only one ingredient and water), select the brand with the most calories—hence, the most food—per unit weight. On average, Growing Healthy, while more expensive, had a slight nutritional edge over other brands’ single-ingredient foods. When choosing dinners, buy products with little or no added thickeners, such as Beech-Nut’s

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second-stage dinners or any of Growing Healthy’s dinners. Also, Gerber and Heinz’ new meat-vegetable and meat-fruit combinations do not contain fillers and are more nutritious than their regular dinners. If you want organic food, choose Earth’s Best, though other companies claim that their products contain very low levels of pesticides (and quite possibly levels as low as Earth’s Best).

• Avoid baby food desserts. Instead, feed your baby the more nutritious plain fruit

products.

• Buy regular fruit juices, unsweetened applesauce, and other comparable prepared foods instead of baby foods when possible.

Parents may feel that there must be something especially good about baby foods that justifies high prices. There is nothing magical about baby foods. When you want convenience, prepared adult foods that are similar in consistency to baby foods are just as good, but cost much less. Regular fruit juices and unsweetened applesauce, for example, are less than half the price of baby food juices and applesauce.

III. RECOMMENDATIONS TO THE FOOD INDUSTRY

Baby food manufacturers should live up to their advertised promises. They can begin by:

• Replacing starchy fillers with real food.

• Removing added sugars and salt and halting the production of desserts.

• Lowering prices for fruit juices and other products.

Furthermore, we urge supermarkets to consider marketing lines of their own house-

brand baby foods.

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IV. RECOMMENDATION FOR GOVERNMENT ACTION

• The U.S. Food and Drug Administration (FDA) should re-propose regulations to require disclosure of the percentage of the characterizing ingredient(s) on the front label of baby foods, as well as percentage labeling of all significant ingredients on the back label.

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INTRODUCTION

New parents want to provide their infants with the best possible start in life. They are faced with many important decisions: whether to breast feed; which soaps, lotions and diapers to buy; and, when the time for solid food comes, what foods to feed their baby. Parents want to feel secure that the foods they choose for their babies are as healthful as possible. While it is easy to make nutritious baby foods at home, commercially prepared foods are convenient for busy parents. Over the years, tens of millions of parents have entrusted food manufacturers to provide their babies with much of the solid food they will eat during their first year of life.

Four million babies are born in the United States every year.i By the time they reach twelve months of age, each of those infants has consumed, smeared around, or spit out an average of 600 jars of baby food.ii By contrast, the average baby born in western Europe will consume only about 240 jars of baby food, and in eastern European countries, like Poland, about 12 jars.iii

Baby food is a $1.25 billion a year industry in the United States.iv Just three companies—Gerber, Beech-Nut and Heinz—control over 95% of the market. Gerber, which jarred its first strained peas in 1928, is far and away the industry leader, with more than a 70% share of the market. Gerber makes 182 different food and juice items for babies and toddlers and sells over 1.2 billion units of baby food per year. Beech-Nut and Heinz trail far behind Gerber, with about 14% of the market each.v Both companies make close to 120 different baby foods and sell over 230 million units of baby food annually.5

Two companies born in the late eighties are trying to grab a share of the market from the big three. One of them, Earth’s Best, markets 47 varieties of organic jarred baby food and juices. Earth’s Best, which was founded in 1985, holds 2.5% of the market. The other newcomer is Growing Healthy. Founded in 1989, Growing Healthy is the first producer of frozen baby foods, which it claims are tastier and nutritionally superior to jarred foods. Growing Healthy is sold only in select cities and holds less than 1% of the market. However, in areas where it is available, the 33-item line accounts for up to 6.5% of baby food units sold.

Companies compete heavily for new parents’ loyalty and business. Through brochures, direct mail, and ad campaigns, each tries to convince parents that its products are the best.

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o Gerber recently launched a $30 million TV, print, and direct-mail campaign using the slogan “For learning to eat smart, right from the start.”vi The ads assure parents that Gerber foods are “specially formulated to help your baby develop a variety of tastes for healthier foods” and that “The longer you can keep your baby on these smart [Gerber] foods now, the better her chances are for eating healthy—and being healthy—for a long time to come.”

o Heinz claims that its baby foods are “Everything you could want in a baby food!”

and provide “Only the best ingredients for the best nutrition.”

o Beech-Nut’s ads focus on how its foods differ from those of Gerber and Heinz: “Gerber and Heinz add sugar and chemically modified starch to some of their fruits. But at Beech-Nut, we add more fruit instead.” Also, “Not adding refined sugar or chemically modified starch to fruits means more of the essential minerals, potassium and magnesium.”

o Growing Healthy’s ads claim that its foods taste better and are more nutritious

than jarred foods. They also play on parental guilt. One ad depicts a child with enormous eyes looking out from the page, with the caption reading “There’ll never be a more important time to give me REAL nutrition. Yet you’re gonna feed me JARRED vegetables that’ve had many of the nutrients processed out so they can sit on a shelf for three years? Does Grandma know about this?”

How well do the companies deliver on their promises to provide the most nutritious food

made of the finest ingredients? It’s hard to say from looking at the foods—almost all are puréed, strained, or blended so they look little like their whole components. And since the percentages of ingredients are not listed on the label, the ingredient statements are not always useful for making comparisons. For example, parents have no way of knowing how much chicken is in a chicken and noodles dinner, or what percentage of a mixed vegetables dish is actually vegetables. Nutrition labels provide useful information, but it often takes a nutrition degree and a calculator to compare two products. To help inform consumers, CSPI has investigated the nutritional quality and costs of commercially prepared baby food. The inquiry focused primarily on the fruits, vegetables, dinners, and juices sold for babies up to a year of age. Our findings reveal that not all baby foods are created equal. NUTRITION: FIRST-STAGE FOODS

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All the manufacturers, except Earth’s Best, market three categories of baby food: first-stage, second-stage, and third-stage foods. Food in the three stages vary in variety, portion size, and, in some cases, texture, to match the needs of growing infants. First-stage foods are single fruits, vegetables, and dry cereals intended to be the first solid foods that an infant ingests, usually sometime after four months of age. Beech-Nut’s first-stage foods also include meats. First-stage foods are sold in 2.5-ounce (Gerber, Heinz, Beech-Nut) or 4-ounce jars and packages (Beech-Nut, Growing Healthy). Earth’s Best does not use a three-stage system. Its single fruits and vegetables are sold in 4-ounce jars.

First-stage foods comprise 19% of the total units of solid baby food sold.vii Gerber sells thirteen different first-stage foods. Several first-stage foods are among the most popular baby foods—five of Gerber’s fifteen top-selling foods and Beech-Nut’s seven best-selling foods. Gerber and Beech-Nut also sell single fruit juices under the first-stage label. All juices are fortified with vitamin C. FRUITS AND VEGETABLES Major Finding: The amount of fruit or vegetable in first-stage foods varies moderately

between brands. The ingredients of first-stage fruits and vegetables vary little from company to company.

All are composed of a single fruit or vegetable, usually mixed with water, with or without the addition of vitamin C and citric acid. However, the amount of fruit or vegetable in a given amount of food varies moderately from brand to brand due to the addition of different amounts of water and perhaps the use of different varieties of ingredients.

The carbohydrate content of single fruit or vegetable products is a good indicator of the amount of fruit or vegetable that a product contains. Among the ten most popular first-stage foods, the brand with the highest carbohydrate content, and hence the most fruit or vegetable, contains 21% to 79% more carbohydrate per ounce than the brand with the least amount (Table 1).viii Growing Healthy products had, on average, the highest food content and Earth’s Best the lowest. The three major companies fell in the middle, with Heinz the best of the three. (Comparing the solids contents of the various brands of first-stage foods yielded similar results.) It is worth noting that Growing Healthy’s peaches and pears contain “natural fruit concentrate,” in addition to plain fruit and water. The use of that concentrate is partly responsible for the higher carbohydrate and solids contents of Growing Healthy’s peaches and pears compared to the plain, unconcentrated fruits of other brands.

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NUTRITION: SECOND-STAGE AND THIRD-STAGE FOODS

Second- and third-stage solid foods are cereals, fruits, vegetables, meats, dinners, and desserts for infants from six and nine months of age, respectively. Sixty percent of the leading brands of baby foods sold are second-stage foods and 21% are third-stage foods. Gerber sells sixty different second-stage and forty-six different third-stage solid jarred foods.

Most second-stage foods are sold in 4- to 4.5-ounce jars and packages. Third-stage foods are sold in a 6-ounce size. The composition and nutritional value of most second- and third-stage cereal, dessert, fruit, and vegetable products of the same name are identical. Most second- and third-stage dinners of the same name are, for the most part, similar in ingredient and nutrient composition, by weight. The principle difference is that the third-stage dinners tend to have a coarser texture and may contain chunks of food.

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I. FRUITS & VEGETABLES Major Finding: Gerber and Heinz dilute many second- and third-stage fruits and

vegetables with water and starchy fillers and sweeten them with sugars. That practice greatly reduces the nutrient density of those foods compared to the pure fruit or vegetable product.

Beech-Nut, Earth’s Best, and Growing Healthy do not add sugar or starchy fillers to any

single or mixed fruit or vegetable baby food. Gerber and Heinz also make a variety of plain second- and third-stage products, and those products have about the same nutritional value as other brands. However, Gerber and Heinz add sugars and/or starchy fillers to over half of their second- and third-stage fruits and several second-stage vegetables. Gerber adds sugar to 55% (12 of 22) and chemically modified tapioca starch to 50% (11 of 22) of its second- and third-stage fruits (products are labeled “with tapioca”). Heinz adds corn syrup or sugar to 57% (12 of 21) and chemically modified starch (corn and/or tapioca) to 48% (10/21) of its second- and third-stage fruits. Gerber and Heinz also add flour to mixed and creamed vegetables.

The addition of water, sugars, and starchy fillers greatly dilutes the nutrient content of the foods, compared with the first-stage version of the same brand, with comparable second- or third-stage products that do not contain added fillers, or with equivalent weights of fresh produce. The examples below illustrate the degree to which adulteration with water, starches, and sugars dilute the nutrient density of second-stage fruits and vegetables.ix Fruit with Tapioca

About half of Gerber and Heinz’s second- and third-stage fruits are “fruits with tapioca.” Gerber sells over 100 million jars of fruits with tapioca per year. Bananas with tapioca is Gerber’s top selling baby food—over 40 million jars were sold in 1994.x Neither Gerber nor Heinz makes jars larger than 2.5 ounces of plain versions of the fruits that are in their fruit-with-tapioca products.

All varieties of fruit with tapioca contain water, fruit, chemically modified tapioca starch, and sugar or high-fructose corn syrup. Heinz’ products also contain chemically-modified corn starch. Although these products are labeled “fruit with tapioca,” the name of the fruit(s), such as “Bananas,” is written in large letters, while “with tapioca” is written in smaller letters below.xi This labeling likely leads consumers to assume that the products are largely fruit, with all the nutritional benefits of full-fruit products.xii However, the fruit-with-tapioca products that we

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examined contain less than half as much fruit as the products made only from fruit and water. In other words, a 2.5-ounce jar of first-stage bananas or first-stage prunes actually contains more fruit than the 4-ounce jars of second-stage products that are adulterated with water and chemically modified starch.xiii

Comparison with First-stage Bananas and First-stage Prunes (Table 2) Compared to its own first-stage products, Gerber’s bananas with tapioca and prunes with tapioca provide, on average, less than half the amount of nutrients that fresh bananas and prunes are rich in—potassium, riboflavin, and vitamin B-6. Heinz’ bananas with tapioca provide an average of only 28% of the riboflavin, vitamin B-6, and potassium, per ounce, contained in Heinz’ first-stage food.

Comparison with Fresh Apricots Apricots are a good source of potassium and vitamin A. One 4-ounce serving of fresh apricots provides about 335 mg of potassium and 2860 IU of vitamin A. By contrast, a 4-ounce serving of Gerber’s apricots with tapioca contains only 139 mg of potassium and 1333 IU of vitamin A—or less than one-half as much.

Heinz’ apricots with tapioca compare even less favorably with the fresh fruit than Gerber's. A 4-ounce serving contains only 78 mg of potassium (23% of the amount in fresh apricots) and 813 IU of vitamin A (28% of the amount in fresh apricots), suggesting that Heinz’ product is less than 30% fruit by weight.

Those findings reveal that three of the most popular Gerber’s fruits with tapioca contain

less than half as much fruit as its plain products. Two of Heinz’ most popular fruits with tapioca contain less than one third as much fruit as its plain products. Other fruit products made with tapioca are probably similarly diluted, though there is no undiluted product with which to make direct comparisons. In other words, the 4-ounce jars of fruit with tapioca often actually contain less fruit than the 2.5-ounce jars. Beech-Nut’s reformulation experience strengthens this conclusion. In 1983, Beech-Nut stopped making fruit-with-tapioca products. To replace the starch and water with fruit, Beech-Nut had to increase the amount of bananas in the product from 20%-30% to 80%-90% of the product’s weight.xiv Since that time, Beech-Nut has run ads that point out the differences between the amount of fruit in its fruit products and Gerber’s fruits with tapioca. Mixed and Creamed Vegetables

Gerber and Heinz prepare several of their second- and third-stage vegetables with starch thickeners, though more than half of their their second- and third-stage vegetables are made without thickeners. The nutritional quality of a vegetable dish with added flour or starch is

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inferior to that of unadulterated dishes. Compare, for instance, mixed and garden vegetables:

“Mixed vegetables”: Gerber and Heinz’ “mixed vegetables” each contain three kinds of starch thickeners (wheat and oat flours, and potato solids or potato flour) and relatively little vegetable. The ingredients in Gerber’s “mixed vegetables,” in order by weight, are: water, carrots, wheat flour, oat flour, potato solids, tomato paste, and onion powder. Heinz’ “mixed vegetables” contain water, carrots, squash, wheat flour, oat flour, tomato paste, potato flour, and onion powder. By contrast, Beech-Nut makes a mixed vegetable product that is not adulterated with starchy filler, however nutrition information was unavailable for comparison.

“Garden vegetables”: Growing Healthy, Beech-Nut, Gerber, and Earth's Best’s “garden vegetables” are composed solely of vegetables and water. Growing Healthy’s garden vegetables contain, in order by weight, carrots, squash, water, corn, peas, tomato paste, onions, and onion powder. Beech-Nut’s ingredient list reads: water, peas, green beans, carrots, and dehydrated potatoes. Gerber’s ingredient list reads: peas, water, carrots and spinach. Earth's Best garden vegetables contain: water, carrots, potatoes, corn, and green beans.

Thus, the garden vegetable products provide about the same number of calories as the mixed vegetables, but one-and-one-half to three times the amount of thiamin, riboflavin, niacin, and vitamin C. Gerber and Heinz’ mixed vegetables are so diluted with water and starchy fillers that we can’t help but wonder what purpose they serve other than to capture more shelf space in stores.

Gerber and Heinz adulterate four varieties of “creamed vegetables” (Gerber markets corn and spinach; Heinz markets corn, peas, and green beans) with fillers. Consider creamed corn, for example:

Creamed corn: Gerber’s product is made with water, corn, nonfat dry milk, and rice flour. Heinz’ contains water, corn, carrots, modified corn starch, sugar, and whole-milk solids. Growing Healthy’s creamed corn contains only corn and water. Compared to Gerber and Heinz, Growing Healthy’s creamed corn provides at least 73% more calories, 75% more riboflavin, two times as much niacin, three times as much thiamin, and significantly more protein per ounce.

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Other Findings

• All stages of Gerber and Beech-Nut’s unsweetened plain fruits and vegetables have similar nutritional values. Heinz’ second- and third-stage plain versions of fruits and vegetables (except for squash and sweet potatoes) contain more water and 19% to 29% less fruit or vegetable, as measured by carbohydrate or solids content, per ounce than its first-stage foods. Gerber and Heinz’ second- and third-stage peaches contain added sugar.

• Since 1994, Gerber has added modest amounts of sugar and or salt to some of its third-

stage fruits and vegetables (and other products). Two third-stage vegetables—carrots and squash—now contain added sugar. It appears that the sugar does not replace any vegetable, but is added to it, thereby increasing calories without also increasing the nutrient content. Although the American Academy of Pediatrics recommends that salt not be added to baby foodsxv, six of Gerber’s seven third-stage vegetables now contain small amounts of added salt. The sugar and salt may serve to mask off-flavors and/or enhance desired flavors in the heavily processed foods.

II. DINNERS Major Finding: Growing Healthy’s dinners consistently provide more nutrients than other

brands. Gerber and Heinz’ regular dinners provide the least nutritious dinners (though those companies have healthier new lines of dinners).

Baby food dinners are strained combination foods that typically contain meat, vegetables,

and sometimes noodles or rice. Gerber markets ten different second-stage and eleven different third-stage dinners. Heinz sells eleven second- and eleven third-stage dinners. Beech-Nut sells ten second-stage and seven third-stage dinners. Growing Healthy sells five second-stage and three third-stage dinners (each of which comes in plain and chunky). Earth’s Best sells eight second-stage dinners, five of which are vegetarian, and four third-stage dinners, one of which is vegetarian.

Growing Healthy does not add starchy thickeners, such as flour or modified starch, to any of its dinners. Gerber and Heinz, by contrast, add at least two types of flours to all their standard dinners—some meals contain 4 different flour fillers. (Both Gerber and Heinz recently began marketing a line of dinners without fillers.xvi Those products could not be compared to other companies’ products, but they are clearly more healthful than Gerber and Heinz’ regular dinners.) While Beech-Nut does not add any starchy fillers to its second-stage dinners, it does add them to six of its seven third-stage dinners. Earth’s Best adds whole grain flour to each of

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its dinners.

The use of starchy thickening agents can mask the addition of a good deal of water. As any cook knows, a little bit of flour or starch can thicken a lot of liquid. The presence in a baby food of one or more fillers, such as rice flour, wheat flour, or modified starch, is a good indicator that the food is a dilute and nutritionally inferior product. Consider, for example, chicken and noodles, the top-selling second-stage dinner.

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xvii Gerber’s chicken and noodles contains two types of flour, and Heinz’ product contains three types of flour and chemically modified corn starch. The chicken and noodles products made by Growing Healthy and Beech-Nut, by contrast, are thickened with real food. Not surprisingly, Growing Healthy and Beech-Nut’s dinners are more nutritious than either Gerber or Heinz’ (Table 3). The Growing Healthy meal is especially high in nutrients. It provides 44% more calories and at least twice as much protein, vitamin A, and B-vitamins (thiamin, riboflavin, niacin, and vitamin B-6) as Gerber and Heinz’. The differences are due both to Gerber and Heinz’ use of water and fillers and to Growing Healthy’s use of concentrated nutrient-rich broths. While the Beech-Nut product contains about the same amount of calories and protein as Gerber and Heinz’ products, it provides at least 40% more potassium (data not shown) and six times more vitamin A, indicating the use of more food and no fillers. Earth’s Best’s dinner, which is a third-stage dinner, contains at least 50% more protein than the leading brands and twice as much vitamin A as either Gerber or Heinz’ dinner.

We made similar calculations of nutrient levels in three other popular dinners:

vegetables and chicken, vegetables and beef, and vegetables and turkey. The results of those calculations are presented in Table 4. On average, Gerber and Heinz’ dinners provided less than half the nutrient content per serving as Growing Healthy’s.

Beech-Nut and Earth’s Best were not included in those calculations because complete nutrition information was not available for all four dinners. However, using the limited nutritional information available for Earth’s Best dinners, we compared Earth’s Best’s chicken and noodles, vegetables and beef, and vegetables and turkey with Gerber, Heinz, and Growing Healthy’s products (Earth’s Best does not make a vegetables and chicken dinner). The results revealed that Earth’s Best dinners provide, on average, 43% more protein, and more than two and one-half times the vitamin A as Gerber and Heinz’ dinners. Compared to Growing Healthy’s products, Earth’s Best provided an average of 85% of the calories, 64% of the protein, and 1.8 times the vitamin A. III. OTHER PRODUCTS Desserts

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The three leading manufacturers make a wide variety of dessert products. Gerber makes nine different second-stage, and eight different third-stage desserts. Heinz offers a greater variety of second-stage desserts (13) than it does second-stage vegetables (8) or fruits (12); it also makes more third-stage desserts (5) than third-stage vegetables(4). Beech-Nut makes seventeen second-stage desserts and four third-stage desserts. Every dessert sold by Gerber, Heinz, and Beech-Nut contains added sugars, and Gerber and Heinz’ desserts contain chemically-modified starch. According to a Gerber spokesperson, Gerber’s desserts contain up to 11% sugar by weight.xix That means a 6-ounce dessert item may contain up to 18 grams, or four and a half teaspoons of sugar. Some might consider such products a child's first junk foods.

Sugar-added desserts dilute the nutrient density of babies’ diets and serve no purpose in the diet of an infant. Plain fruit provides the sweetness children like, as well as higher levels of essential nutrients. By contrast, the fruit in baby food desserts is diluted out with water and starch. The added sugars provide calories, but no other nutrients. Consider the following products: • Gerber’s peach cobbler provides only 78% of the vitamin A and 54% of the potassium

that is present in Gerber’s plain peaches. • Gerber’s banana-apple dessert contains only 47% of the potassium and 26% of the

dietary fiber that is present in Gerber’s plain apple-banana product. • Gerber’s fruit dessert has 57% of the potassium and 59% of the fiber that is present in

Gerber’s plain fruit salad. • Heinz’ peach cobbler has only 40% as much vitamin A and 32% as much fiber as its

plain peaches. • Beech-Nut’s banana-yogurt dessert contains more calories than its plain bananas, but

only half the potassium (according to label data).

Furthermore, children’s dietary preferences and habits are shaped early in life. Gerber’s current advertising states that “The first 24 months are the most important months in developing tastes for a variety of healthy foods.” Consumption of sugary desserts early in infancy may encourage a life-long preference for highly sugared foods. The wide variety of desserts offered by the leading brands appears to be more a strategy to capture as much shelf space as possible than to provide babies with the most nutritious foods. Foods with Yogurt

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Gerber, Heinz, Beech-Nut, and Earth’s Best manufacture several yogurt-containing

products. Gerber sells second-stage “juices with lowfat yogurt” and fruit-yogurt desserts. Heinz and Beech-Nut sell yogurt desserts, and Earth’s Best makes yogurt breakfast products. Yogurt-containing products have obvious appeal to health-conscious parents who perceive yogurt as a healthful food. The yogurt products do add a little calcium to the diet. However, because all jarred baby foods are held at high temperatures for up to an hour, the live bacteria that give yogurt its special beneficial properties are killed. Jarred and Instant Cereals

All five companies make jarred second-stage “cereals with fruit.” Third-stage cereals include Gerber and Earth’s Best jarred cereals with fruit and Gerber’s “yogurt cereals.” Gerber, Beech-Nut, and Heinz also sell instant plain cereals and cereals with fruit. All brands of jarred and instant cereals, except Earth’s Best, are fortified with vitamins and iron.

Gerber and Heinz’ cereals with fruit all contain added sugar or high-fructose corn syrup. Heinz’ mixed cereal with apples and bananas and Gerber’s cereals (rice, oatmeal, ad mixed cereal) with applesauce and bananas contain more added sugar by weight than banana. The addition of refined sugars to cereals is unnecessary. The fruits in these cereals should provide sufficient sweetness to make them pleasant to babies. Furthermore, the added sugars may encourage a preference for heavily sweetened foods. Meats

Gerber, Heinz, Beech-Nut, and Growing Healthy all manufacture at least 3 strained meat products that are made of a single type of meat and water or broth. All four companies offer beef, turkey, and chicken products, which do not differ significantly in nutritional value (data not shown). Gerber, Beech-Nut, and Heinz also sell lamb, turkey and veal; Gerber offers ham; and Heinz offers beef liver. TASTE

We are not aware of studies that compare the taste of different brands of baby food. Independent studies should be done to determine if babies prefer certain products over others and if that makes any difference in their taste preferences when they begin eating regular solid foods. (Fifteen adults at CSPI’s offices participated in an informal taste tests of Gerber, Growing Healthy, and Heinz’ first-stage peas, first-stage bananas, and second-stage vegetables-and-chicken dinners. People generally preferred Growing Healthy products. However, adult taste

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preferences may have nothing to do with the preferences of infants.)

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COST

New parents spend an average of $300 on baby food during their infant’s first year of life.xx Many parents spend much more, while a few never buy prepared baby foods.

Among the leading brands, Beech-Nut and Heinz are often priced a few cents less per jar than Gerber. However, the price of baby foods varies considerably more from store-to store. Some stores appear to price baby foods (and other baby products) near their cost (or perhaps even below cost) to get parents into the store. In a sample of supermarkets and grocery stores in the Baltimore-Washington area, for example, 4-ounce jars of Gerber and Heinz baby foods ranged in price from $0.33 to $0.66 per jar. Most area suburban supermarkets, however, charged $0.45 to $0.50 for the 4-ounce second-stage foods, and 0.63 to $0.67 for 6-ounce third-stage foods.

Earth's Best suggested retail prices are $0.63 per 4-ounce jar, and $0.83 per 6-ounce jar. The suggested retail prices of Growing Healthy’s products are $0.79 per 4-ounce package of fruit(s) or vegetable(s), $0.89 per 4-ounce second-stage dinner, and $1.19 per 6-ounce third-stage dinner. According to the company, actual in-store prices for 4-ounce fruits and vegetables range from $0.63 in Minneapolis to $0.89 in stores in Los Angeles. I. THE COST OF DILUTION WITH WATER AND STARCHY FILLERS

Foods made with starchy fillers cheat babies and consumers while increasing company profits. As discussed above, Gerber and Heinz replace up to 70% of their second- and third-stage fruits with water and then thicken them with chemically modified tapioca starch. They also add starchy fillers to all their regular second- and third-stage dinners.

While the price per pound of chemically modified tapioca starch is slightly more than that of bulk mashed bananas (tapioca starch: $0.60 to $0.80; bananas: $0.49 to $0.55 per pound),

xxiii

xxi much less of the starch is needed to achieve a given consistency. Baby foods thickened with tapioca contain no more than 5% to 7% modified food starch by weight.xxii, Thus, the maximum amount of chemically modified starch required to thicken a 4-ounce jar of food would be 0.3 ounces, which would cost about about 1 cent per jar. The sucrose added to sweeten the diluted fruit would cost less than 1/4 cent cent per jar.xxiv By contrast, to replace the water and starch in a 4-ounce jar of bananas with tapioca with bananas would require an additional two ounces of bananas, at a cost of 7 to 10 cents.xxv Thus Gerber and Heinz probably save about 6 cents or more per 4-ounce jar of fruit-with-tapioca product by substituting starch, sugar, and water for fruit. Gerber's overall savings from replacing fruit with water and starch is staggering. With bananas-with-tapioca products alone, Gerber probably reaps at least $2.3 million in savings

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annually.xxvi

Beech-Nut, Growing Healthy, and Earth's Best do not dilute any fruit product with chemically modified starch or other fillers. Each makes plain bananas in 4-ounce and larger jars or packages. Beech-Nut’s first- and third-stage bananas in 4- and 6-ounce jars are the lowest priced, and thus offer best value. Growing Healthy and Earth's Best also sell plain bananas, apricots, and prunes, which generally still offer more fruit per dollar than the fruits with tapioca made by Gerber and Heinz. II. THE COST OF INNOVATIVE PRODUCTS

The products made by the two new companies, Growing Healthy and Earth’s Best, are considerably more expensive per container, but offer benefits that may, for many consumers, justify the additional expense. Growing Healthy’s fruits and vegetables cost about 60% more per ounce than Gerber, its dinners almost 80% more. Growing Healthy’s foods, however, are likely to appeal to many parents who want minimally processed, better-tasting (at least to adult palates) foods. Many of its fruits, vegetables, and dinners are more nutritious than other brands. Growing Healthy’s fruits and vegetables, on average, contain slightly more food value per ounce than Gerber and Heinz’ plain products, and considerably more than Gerber and Heinz’ products that are diluted with water and tapioca. Growing Healthy’s dinners are roughly twice as nutritious as comparable dinners made by Gerber and Heinz.

Earth’s Best 4-ounce jars of baby food cost about 25% more than its competitors’ products. Earth’s Best’s dinners provide more protein and vitamin A than the comparable products made by Gerber and Heinz. Earth's Best uses no modified starches and minimal amounts of other thickening agents. In addition, all of Earth’s Best’s foods are made with organically grown ingredients, which is a definite plus for the environment. III. COST COMPARISONS WITH REGULAR FOODS

Baby foods are greatly overpriced compared to similar regular foods. Examples include applesauce and fruit juices, as well as diced fruits and vegetables for toddlers. The nutrient content and physical characteristics of those baby foods do not differ significantly from those for adults. However, the baby foods cost up to several times as much per unit weight. Baby foods for which there is no direct comparison in other grocery aisles are also priced very high. Gerber meats in 2.5-ounce jars, for example, cost $4.48 per pound in one Baltimore supermarket (Giant).

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Applesauce Regular unsweetened applesauce costs much less than baby-food applesauce. In a survey of four supermarket chains in the Baltimore-Washington area, baby food applesauce was up to 2.4 times as expensive as regular applesauce. The table below shows prices in one supermarket.

Brand

Size

Cost per pound

Gerber

4-ounce jar

$1.86

Mott’s

4 ounce-cup (6-pack)

$1.33

Gerber

6-ounce jar

$1.68

White House

48-ounce jar

$0.69

Besides cost, texture is the only difference between applesauce for babies and adults.

Applesauce for babies is slightly denser and more finely puréed, and thus has a smoother consistency.xxvii However, most babies like regular applesauce just as much. If a baby rejects the less expensive regular applesauce, a parent could then try a baby food applesauce. Fruit Juice

Gerber, Beech-Nut, and Heinz market fruit juices in 2.5-, 4-, and 32-ounce jars. These juices provide at least 100% of the Daily Value (DV) for infants of vitamin C per serving. Except for the addition of vitamin C, however, they are nutritionally identical to regular fruit juices, but cost much more: • At a Baltimore supermarket (Super Fresh), Mott’s brand apple juice in 4 packs of 4.23-oz

boxes cost $1.68 per quart, whereas Gerber juices in 4-ounce jars cost $3.56 per quart, or over twice as much.

• At a major Washington, D.C., supermarket (Safeway), one-quart jars of the store brand

juice cost $1.29 and Mott’s brand apple juice cost $1.49. By contrast, Gerber’s apple, pear, and other juices cost $2.29 per quart jar, or 78% more than Safeway’s brand and 54% more than Mott’s.

The cost of the added vitamin C does not account for or justify the difference in the price

of baby and regular fruit juices. Companies pay less than ½ cent per quart for enough vitamin C to ensure that each 4-ounce serving provides 100% of the DV.xxviii Furthermore, the added

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vitamin C is hardly essential to a child’s diet, because juices should never comprise a substantial amount of a baby's calorie intake, and a child's other foods and vitamin drops should provide all the needed vitamin C. (In fact, babies should consume minimal amounts of, if any, fruit juice, because it replaces more nutritious milk or formula.) Toddler Foods

Baby food companies continually seek ways to maintain or expand their sales base. Gerber and Beech-Nut have extended their product lines to include foods for toddlers. While some of those foods may provide busy parents a better alternative than other canned foods (Spaghetti-O’s and the like), which tend to be loaded with sodium, toddler foods are unnecessary. Toddlers can easily chew and swallow small portions of most adult foods. Furthermore, many similar foods are already available in stores at much lower prices. For example, Gerber’s line of toddler foods, Gerber Graduates, includes 4.5-ounce jars of vegetables and fruits, such as peas and diced carrots, green beans, apples, and peaches. In one Baltimore supermarket (Super Fresh) Gerber Graduate diced fruits and vegetables cost roughly two to three times as much as similar non-baby food products:

Brand/product

Size

Price per

pound Gerber Graduate diced vegetables (e.g., carrots, green beans, peas)

4.5-ounce jar

$1.78

America’s Choice no-salt-added sliced carrots

14.5-ounce can

$0.55

Del Monte no-salt-added cut green beans

8-ounce can

$0.89

Del Monte no-salt added peas

17-ounce can

$0.60

Gerber Graduate diced fruits (apples, peaches, pears)

4.5-ounce jar

$2.24

America’s Choice fruit “Lite Fruit Cocktail”

16-ounce can

$0.93

Del Monte peaches in pear juice

16-ounce can

$0.99

Furthermore, fresh fruits and vegetables are sometimes cheaper and certainly taste better and are more nutritious than processed products. REGULATION OF BABY FOOD LABELING

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The labels on baby foods are generally subject to the same regulations as regular foods. However, unlike regular foods, it is impossible for the consumer to estimate amounts of important ingredients by the foods’ appearance, because baby foods are strained, puréed, and blended foods and food combinations. Thus, consumers must thus rely on the name of the food to make their purchasing decisions. They may assume that the ingredients emphasized on the label, for example, vegetables and chicken, are present in larger amounts than they actually are. While labels list ingredients in order of predominance, they provide only a rough guide as to the actual amounts of the ingredients. Consumers are certainly not told that chemically modified starch, rice flour, wheat flour, and similar substances replace the valuable and characterizing ingredient(s).

In 1975, to facilitate informed choices, CSPI petitioned the FDA to require the disclosure of the percentage of all characterizing ingredients on the front labels of baby foods and to disclose the percentage of each ingredient on the ingredient label. In 1976, the FDA responded favorably to CSPI’s petition and proposed to institute such requirements. The agency stated:

The Commissioner agrees that most labels currently used on infant and junior foods do not inform the consumer about the amount of characterizing ingredients(s). The Commissioner also agrees that the proportion of characterizing ingredient in infant and junior foods, i.e., those ingredients listed in the name of the food or otherwise featured on the label, may have a material bearing on price and consumer acceptance. . . . The Commissioner also agrees that there is a potential for deception because the ingredient(s) listed in the name of infant and junior foods may appear to be present in greater amounts than is actually the case.xxix

In 1991, after two decades of inaction, the FDA withdrew that proposal as part of a larger

effort to clear its dockets of proposed regulations that had never been finalized.

It is clear that parents still need help in choosing the most healthful foods for their babies. Disclosure of the characterizing ingredients(s) on the front of the label and percentage-ingredient labeling on the side or back of the label would give parents the tools. Thus, one product might indicate on the front label “85 percent bananas,” while another might state “50 percent bananas.” Some companies would probably say that such labeling would reveal trade secrets, but the fact is that the only secret today is from parents—competitors know roughly what each other makes. It is also possible that certain companies, such as Beech-Nut and Growing Healthy, would favor percentage labeling, beacuse it would give them a competitive tool. In any case, percentage labeling would encourage companies to compete on the basis of quality.

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Table 1

FRUIT AND VEGETABLE CONTENT OF FIRST-STAGE FOODS

Fruit of Vegetable Content as a Percentage

of the Brand with the Highest Content* Food, Ranked by Popularity†

Highest Food

Content Per Ounce

Gerber

(% of highest)

Heinz

(% of highest)

Beech-Nut

(% of highest)

Earth’s

Best

(% of highest)

Growing Healthy

(% of highest)

#1 Bananas

Heinz

99

100

81

64

87

#2 Applesauce

Growing Healthy

72

92

65

70

100

#3 Pears

Growing Healthy

70

91

77

76

100

#4 Sweet Potatoes

Heinz

98

100

87

83

90

#5 Carrots

Growing Healthy

76

64

88

75

100

#6 Peaches

Heinz

56

100

78

—

98

#7 Squash

Growing Healthy

69

71

93

84

100

#8 Peas

Growing Healthy

68

81

71

—

100

#9 Green Beans

Gerber

100

93

80

—

97

#10 Prunes

Gerber

100

—

—

—

79

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Average

81%

(n=10)

88%

(n=9)

80%

(n=9)

75%

(n=6)

95%

(n=10)

* Fruit or vegetable contents are based on the amount of carbohydrate reported in manufacturers’ nutritional analyses. † Ten most popular first-stage foods; Nielsen Marketing Research, 1995.

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Table 2

NUTRITIONAL COMPARISON OF “BANANAS” AND “PRUNES” WITHOUT AND WITH TAPIOCA Calories and Nutrients Per 4-Ounce Serving†

Gerber Bananas

Heinz Bananas

Gerber Prunes

plain

w/tapioca*

plain

w/tapioca

plain

w/tapioca

Calories

114

80

115

81

115

85

Potassium (mg)

393

172

366

107

350

225

Riboflavin % of DV

15 %

7%

23%

5%

60%

17% Vitamin B-6 % of DV

107%

48%

73%

25%

35%

23% Percent Fruit as Compared to Plain Products‡

——

44%

——

28%

——

48%

* According to data collected by Nielsen, bananas with tapioca is Gerber’s best-selling baby food. It accounts for over 75% of all the banana products that Gerber sells, on a weight basis.

† Nutrients selected for comparison were potassium and those occurring in amounts greater than 10% of the Daily Value per 4-ounce serving of any brand.

‡ Based on the average percent reduction in levels of potassium, riboflavin, and vitamin B-6, as compared to the plain fruit of the same brand.

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Table 3 NUTRITIONAL COMPARISON OF “CHICKEN AND NOODLES” DINNERS

Calories and Nutrients Per 4-Ounce Serving§

Growing Healthy

Gerber

Heinz

Beech-Nut

Earth’s Best

Calories

88

61

59

66

68

Protein (%DV)*

57%

19%

16%

16%

29%

Vitamin A (%DV)

171%

58%

63%

390%

142%

Thiamin/B-1 (%DV)

18%

6%

6%

4%

na

Riboflavin/B-2 (%DV)

32%

7%

7%

12%

na

Niacin (%DV)

75%

10%

11%

12%

na

Vitamin B-6 (%DV)

25%

15%

10%

na

na

Average % of GH‡

100%

38%

34%

68%

70%

Ingredients (in order by weight)

chicken broth

carrots chicken

corn enriched egg

noodles rice

onions

water

carrots chicken

rice flour enriched egg

noodles wheat flour

nonfat dry milk potato solids onion powder

chicken broth

carrots potato flour rice flour chicken

modified corn starch

wheat flour egg noodles soybean oil

carrots water

chicken green beans enriched egg

noodles

water carrots chicken

whole wheat flour whole wheat pasta

onions canola oil

garlic powder

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onion powder celery extract

All dinners except Earth’s Best are second -stage dinners. Earth’s Best is a “junior” dinner, which is equivalent to a third-stage dinner of other brands. * Percent of Daily Value (DV) for infants. na= nutrient information unavailable. § Nutrients selected for comparison were those occurring in amounts greater than 10% of the Daily Value per 4-ounce serving of any brand. ‡ Average of percentage of nutrients as compared to Growing Healthy. For Earth’s Best, the average is based on only three nutrients.

Table 4 NUTRITIONAL COMPARISON OF SECOND-STAGE DINNERS†

Amount Per 4-Ounce Serving§

Growing Healthy

Gerber

Heinz

Calories

81

62

57

Protein (%DV*)

37%

16%

14%

Vitamin A (%DV)

159%

93%

106%

Thiamin/B-1 (%DV)

14%

4%

6%

Riboflavin/B-2 (%DV)

20%

5%

7%

Niacin (%DV)

43%

9%

10%

Vitamin B-6 (%DV)

27%

15%

10%

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Average Percent of Growing Healthy‡

100%

48%

49%

* Percentage of Daily Value (DV)for infants. † Figures represent the combined average of four of the five most popular dinners: chicken and noodles (#1), vegetables and chicken (#2), vegetables

and beef (#3), and vegetables and turkey (#5). Growing Healthy does not make the fourth most popular dinner, turkey, rice and vegetables. Beech-Nut and Earth’s Best did not provide sufficient data for this comparison.

§ Nutrients selected for comparison were calories and those occurring in amounts greater than 10% of the Daily Value per 4-ounce serving of any brand.

‡ Average percent of listed nutrients as compared to Growing Healthy. For each dinner type, Gerber and Heinz’ dinner was compared to Growing Healthy’s. The percentage differences for the four dinners of each brand were then averaged. Some of the nutrients in Growing Healthy come from the use of nutrient-rich concentrated broth.

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ENDNOTES

i. Bureau of the Census. Statistical Abstract of the United States, 1994 (114th edition), Washington, D.C., 1994.

ii. Brandweek, October 10, 1994.

iii. Tim Croadsdale, vice president of investor relations at Gerber, as quoted in Investor's Business Daily, February 20, 1992.

iv. Supermarket Business, September 1994, p.66.

v. Nielsen Marketing Research, 1995.

vii. First foods comprised 11.6 % of Gerber, 34.7% of Beech-Nut, and 11.1% of Heinz baby foods sold for the 52-week period ending February 18, 1995. Nielsen Marketing Research, 1995.

viii. All nutritional data cited in this report were provided by the manufacturers. All calculations were done with the actual analytical data, which are much more accurate than the rounded-off information on food labels. We appreciate the cooperation of all the companies. Some data from Beech-Nut was not received in time to be included.

ix. We use the term “adulterated” in both its dictionary and legal definitions. According to Webster’s New World Dictionary (second edition), adulterate means “to make inferior, impure, not genuine, etc. by adding a harmful, less valuable, or prohibited substance.” According to the U.S. Food, Drug and Cosmetic Act, a food is adulterated:

(b)(1) If any valuable constituent has been in whole or in part omitted or abstracted therefrom; or (2) if any substance has been substituted wholly or in part thereof, or (3) if any substance has been added thereto or mixed or packed therewith so as to increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater value than it is.

21 U.S.C. 342(b)(1). It is clear that many baby foods, including several discussed in our report, are adulterated under this standard.

x. Source: Nielsen Marketing Research. Data are for the 52-week period ending February 18, 1995.

xi. Stating “tapioca” on the front label is inaccurate inasmuch as the actual ingredient is chemically modified tapioca starch, a substance that is physically, chemically, and physiologically different from native tapioca.

xii. Also, some people probably think that the tapioca is an added bonus rather than an adulterant.

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xiii. A Gerber spokeswoman on the company’s 1-800 consumer-information service (April 17, 1995) said that the bananas used in the bananas with tapioca are not as ripe as the first-stage bananas and have to be diluted with water, thickened, and then sweetened to be palatable.

xiv. Richard Theuer, Beech-Nut Nutrition Corporation, personal communications, 1985 and 1995.

xv. Caring for Your Baby and Young Child: Birth to Age 5, American Academy of Pediatrics, 1993, in a discussion of baby-food preparation, advises against adding salt; p. 205-206.

xvi. Gerber and Heinz recently introduced new meat-and-fruit/vegetable products called Simple Recipe and Simple & Delicious, respectively. These products contain only three ingredients: a single type of meat, a fruit or vegetable, and water. Unlike Gerber and Heinz’ standard dinners, these products contain no added fillers. According to Gerber’s data, the Simple Recipe products contain up to twice as much protein, slightly more iron, and generally more riboflavin and niacin than the same-meat regular dinners. As of February 1995, the new dinners were not among the 100 best-selling foods of either Gerber or Heinz, according to Nielsen data.

xvii. Nielsen Marketing Research. Data are for the 52-week period ending February 18, 1995.

xviii. Earth’s Best nutritional analyses include only the nutrients required on the food label (calories, fat, protein, carbohydrate, sodium, fiber, vitamin A, vitamin C, iron and calcium).

xix. Gerber’s 1-800 consumer line; April 17, 1995.

xx. In 1993, Americans spent $1.25 billion on baby food for the four million infants born that year. On average, then, each baby consumed about $312 worth of commercial baby food.

xxi. The price of bananas is based on the wholesale price of peeled, frozen bananas supplied by Smuckers to food manufacturers. The price of modified tapioca starch is based on the price quoted by A.E. Staley Co.

xxii. According to Dr. Jim Bemiller, professor and director of the Whistler Center for Carbohydrate Research at Purdue University, about 5% of the weight of a jar of baby food with tapioca would be tapioca starch. Personal communication, March 22, 1995.

xxiii. Richard Theuer, Beech-Nut Nutrition, personal communication, July 16, 1985.

xxiv. The cost of sugar added to bananas-with-tapioca products is based on the average wholesale price of refined beet sugar during August-September, 1994 ($0.25 per pound). According to information provided by Gerber, a minimum of 1.4 grams and a maximum of 4 grams of sugar are added to each 4-ounce jar of bananas with tapioca. The price of wholesale refined sugar was obtained from the U.S. Department of Agriculture’s Sugar and Sweetener Situation and Outlook Report, #SSSV19N3, 1994.

xxv. When Beech-Nut eliminated tapioca from its fruit products, the amount of bananas in their 4-ounce jars of bananas had to be increased from 27 to 60 grams to maintain a desirable consistency.

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xxvi. According to Neilsen Marketing Reearch, in the 52 weeks ending February 18, 1995, Gerber sold 40,921,414 jars (4- and 6-ounce) of bananas with tapioca. Using the conservative estimate of 6 cents savings per jar (neglecting jar size), Gerber saved over $2.5 million by substituting starch, sugar, and water for bananas.

xxvii. Baby food applesauce contains up to 20% more fruit per unit weight than regular applesauce, to which more water is added.

xxviii. The wholesale cost of vitamin C manufactured by Hoffman-La Roche is $17.90 per kilogram, personal communication, April, 1995.

xxix. 41 Fed. Reg. 37,594 (1976).