Toddler Milk vs Infant Formula: Does Your Toddler Need a Toddler Drink?

The short answer

Most toddlers do not need toddler milk. FDA says drinks marketed as "toddler formulas" do not undergo its premarket review, are generally not necessary after 12 months, and should not be fed to babies under 12 months [1]. The American Academy of Pediatrics (AAP) says they offer no benefit over much less expensive cow's milk for most children over 12 months [2][3]. A 2026 House bill would change how they are labeled [5][6].

This is general information, not medical advice. Ask your pediatrician about your own child, especially if they have allergies, a medical condition or a prescribed formula.

What is the difference between toddler milk and infant formula?

Infant formula is a regulated food made to be a baby's main source of nutrition; toddler milk is a drink marketed for children over 12 months that is not held to the same rules. In the US, standard infant formula is reviewed by FDA under the Infant Formula Act, while toddler drinks do not undergo FDA premarket review [1][2].

	Standard infant formula	Toddler milk / "toddler formula"
Who it is for	Babies under 12 months not fed (or not only fed) human milk [2]	Marketed for older infants and young children; the AAP report covers drinks aimed at ages 6-36 months [2]
FDA premarket review	Yes, under the Infant Formula Act [2]	No [1]
US composition standard	Infant Formula Act [2]	None, per the AAP [2]
AAP view	The liquid part of the diet under 12 months, with human milk [2]	Can be used as part of a varied diet but gives no nutritional advantage for most children [2][3]
Can a baby under 12 months have it?	Yes	No [1][2]

The AAP adds that some toddler drinks are high in sugar and that they are typically more expensive than cow's milk [2]. A 2026 Public Health Nutrition study notes toddler drinks have higher sugar and lower protein than cows' milk, and that advertising spending and retail sales of these products have grown in the US [7].

Does FDA regulate toddler milk?

FDA treats toddler milks as ordinary foods, not infant formula, so they are not reviewed before sale. FDA's parent guidance says drinks for young children often marketed as "toddler formulas" do not undergo premarket review, are generally not necessary to meet the nutritional needs of children over 12 months, and that babies younger than 12 months should not be fed them [1]. The AAP's 2023 clinical report likewise found these drinks lack standardization or regulatory oversight [2][3].

Infant formula itself is covered in our guides to FDA's infant formula nutrient review and heavy metals in infant formula.

Do toddlers need toddler formula after 12 months?

No, not in most cases. The AAP's clinical report "Older Infant-Young Child 'Formulas'" (Pediatrics, November 2023) says these drinks are generally unnecessary and nutritionally incomplete, inferior to standard infant formula under 12 months, and offer no benefit over cow's milk for most children over 12 months [2][3].

A 2019 consensus statement from Healthy Eating Research, developed with national health organizations, also says toddler milk is not recommended for children aged 12 to 60 months, whose nutrient needs should be met primarily through a nutritionally adequate diet [4].

What should a 12-month-old drink instead?

From 12 months, CDC says you can begin offering plain, pasteurized whole cow's milk without added sugars, or fortified, unsweetened dairy alternatives [8]. Before 12 months, CDC lists breast milk or infant formula, plus 4 to 8 ounces of water a day from about 6 months [8].

The AAP supports continued breastfeeding for 2 years or beyond if mutually desired, and recommends whole cow's milk from 12 months for children who are not breastfed, as part of a balanced diet [2]. Fruit juice is a separate question; see our guide to lead and arsenic in fruit juice.

What would the 2026 H.R.8412 toddler drink bill change?

H.R.8412 would direct FDA to rewrite labeling rules for toddler drinks; it has not become law. Rep. Sara Jacobs introduced it on April 21, 2026, and it was referred to the House Committee on Energy and Commerce [5]. As introduced, the bill would require FDA to [6]:

stop drinks for children over 12 months being called "infant formula" or using the word "formula";
use a descriptive name such as "milk-based drink", with "sweetened" or "flavored" when added sugars, non-nutritive sweeteners or flavorings are used;
carry a warning such as "DO NOT SERVE TO INFANTS UNDER 12 MONTHS OLD" and a statement that the drinks are not recommended for children 12 to 24 months;
drop statements suggesting a recommended daily intake, such as "one cup a day";
propose rules within 1 year of enactment and finalize them within 2 years.

States are also looking at formula: New York's proposed A9026A would extend heavy metal testing and disclosure to infant formula. See our state baby food heavy metal laws tracker.

When might a toddler drink make sense?

Only after talking with your pediatrician. The AAP says some children have special nutritional needs and recommends a focused nutritional assessment, with changes to solid foods or vitamin supplements as needed [2]. Medical or therapeutic formulas prescribed for conditions such as food allergy or metabolic disorders are different products from toddler milks [2]. If your child is on a prescribed formula, do not switch without medical advice.

FAQ

Is "stage 3" formula the same as infant formula?

No. Products sold for older infants and toddlers are not standard infant formula and do not undergo FDA premarket review [1][2].

Can I give toddler milk to my 9-month-old?

No. FDA says babies younger than 12 months should not be fed toddler drinks because they are not designed to meet their nutritional needs [1].

Is toddler milk harmful?

The AAP says these drinks can safely be used as part of a varied diet but give no nutritional advantage for most children over a balanced diet with human milk or cow's milk [2]. Some are high in sugar [2].

What if my toddler will not drink cow's milk?

CDC lists fortified, unsweetened dairy alternatives as an option from 12 months [8]. Ask your pediatrician to check whether your child is getting enough nutrients [2].

Has the toddler drink labeling bill passed?

No. H.R.8412 was introduced on April 21, 2026 and referred to committee [5].

References

U.S. FDA, Infant Formula Information for Parents & Caregivers (section "Toddler Nutritive Drinks").
American Academy of Pediatrics, HealthyChildren.org, AAP: Most Toddlers Don't Need Toddler Formula (October 20, 2023).
AAP Committee on Nutrition (Fuchs GJ III, Abrams SA), Older Infant-Young Child "Formulas", Pediatrics (November 2023), PubMed.
Healthy Eating Research, Healthy Beverage Consumption in Early Childhood: Recommendations from Key National Health and Nutrition Organizations (2019, PDF).
Congress.gov, H.R.8412, 119th Congress.
Congress.gov, Text of H.R.8412 (Introduced in House).
Public Health Nutrition, Purchases of toddler formula in the USA: 17 years of household demographics and spending (February 2026).
CDC, Foods and Drinks to Encourage (April 1, 2026).