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Infant formula guide · US

Infant formula CGMP: nothing leaves quarantine until it meets every specification

Part 106 is strict by design: every production aggregate stays in quarantine until it meets every specification, and its code traces every stage.

3 min readFor QA, regulatory affairs and plant management at FDA-registered infant formula manufacturers
Production colleague in hood, mask, glasses, coat and gloves reviewing a batch record on a screen beside a processing line

In Short

  1. 1Powdered formula: Cronobacter and Salmonella, none detected.
  2. 2Quarantine until all specifications are met.
  3. 3One sequential code traces every stage of manufacture.
Free guide22 pages · Online & printable · 2 worksheets · 10 primary sources · opens online

The Infant Formula Manufacturing Guide

Every nutrient checked. Every can traceable.

What's inside
  • What counts, which rules
  • Nutrients and micro, tested before release
  • Release, records and notification
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The Infant Formula Manufacturing Guide

Every nutrient checked. Every can traceable.

QualityTraceabilityPerformance
Contents
  1. Production and in-Process Control
  2. Microbiological Testing
  3. Quarantine until release
  4. Coding and Traceability
  5. Audits and Records
  6. Questions
Contents
  1. Production and in-Process Control
  2. Microbiological Testing
  3. Quarantine until release
  4. Coding and Traceability
  5. Audits and Records
  6. Questions

21 CFR Part 106 is FDA's binding CGMP and quality control rule for infant formula. It sits on top of the general food CGMP rules and the infant formula requirements in section 412 of the FD&C Act. This guide covers the sections production and quality teams ask about most. Every section cited was checked on the eCFR on 2 Oct 2026.

01

Production and in-Process Control

106.6 requires a production and in-process control system covering every stage, with specifications at points where control is needed, and the manufacturer reviews and evaluates the results. Separately, 106.50 has an individual qualified by education, training, or experience review deviations from the master manufacturing order and document the outcome.

02

Microbiological Testing

106.55 requires controls to prevent contamination by microorganisms. For powdered formula, each production aggregate is tested for Cronobacter spp.

Powdered formula microbiological standards (106.55)

OrganismSamplesSample sizeLimit
Cronobacter spp.3010 gNone detected
Salmonella spp.6025 gNone detected
  • Cronobacter spp.
    Samples
    30
    Sample size
    10 g
    Limit
    None detected
  • Salmonella spp.
    Samples
    60
    Sample size
    25 g
    Limit
    None detected
Per production aggregate, from the eCFR.
More on microbiological Testing

(30 samples of 10 g) and Salmonella spp. (60 samples of 25 g), with none detected.

03

Quarantine until release

106.70 requires each production aggregate to be held under a quarantine system until it meets all of the manufacturer's specifications, or until a documented review finds that a failure does not result in, and could not lead to, adulteration. Product that fails is quarantined until a qualified individual decides.

Can this aggregate leave quarantine?

May be released
  • Who released and against which results is recorded.
Stays quarantined
  • Under 106.70, an individual qualified by education, training, or experience reviews whether the failure could lead to adulteration and documents the disposition.
Not Released
  • Fails the 106.55 standard.
04

Coding and Traceability

106.80 requires each production aggregate to be coded with a sequential number that identifies the product and establishment and lets you trace all stages of manufacture, including the packing period and the receipt and handling of raw materials.

05

Audits and Records

106.90 to 106.94 require regular audits of CGMP and quality control procedures. 106.100 lists the records, including test results, calibration and deviation reviews.

More on audits and Records

V5 records batch steps, lab results, holds and lot trace. Qualified people decide release.

How V5 supports this

V5 records batch steps, laboratory results, holds and lot trace with electronic signatures. An authorised qualified individual makes and documents disposition and release; V5 only records the evidence.

  • Quality ManagementDeviations, CAPA, documents, training and change control in one quality system.
  • Document controlControlled revisions with approvals, and training linked to the current version.
  • CAPA & ComplaintsAudit findings and events raised as CAPA, hold or training actions for people to decide.
  • Lot TraceabilityTrace a lot back to its inputs and forward to customers.

Questions

Which microorganisms must powdered infant formula be tested for?

Under 106.55, each production aggregate of powdered formula is tested for Cronobacter spp. (30 samples of 10 g) and Salmonella spp. (60 samples of 25 g), with none detected.

When can a production aggregate be released?

Under 106.70, only when it meets all of the manufacturer's specifications, or when a documented review finds that a failure does not result in and could not lead to adulteration.

What must the production code show?

Under 106.80, a sequential number identifying the product and establishment that lets you trace all stages of manufacture, including the packing period and raw material receipt and handling.

Does V5 release infant formula?

No. V5 records batch steps, laboratory results, holds and lot trace with electronic signatures. An authorised qualified individual makes and documents disposition and release; V5 only records the evidence.

Terms
  • cGMP
Industry
  • Infant Formula
  • Ingredients & Dry Mixes
  • Food & Beverage

Practical orientation, not legal advice. Rules differ by jurisdiction; your quality and compliance team decides what applies.

Keep reading

  • Food CGMP Readiness: Daily Checks and Evidence
  • EU Acrylamide Regulation 2017/2158: Mitigation, Sampling and Benchmark Levels
  • BRCGS Food Safety Issue 9 Guide: Culture, HACCP, Traceability and Audits
  • Cronobacter in Powdered Infant Formula: Part 106 Testing and FDA's Prevention Actions
  • Food Allergen Control: US Labeling and Bakery Readiness
  • Food Fraud and Food Defence: Running VACCP and TACCP Vulnerability Assessments
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Page version 1.3· Last revised 2 Oct 2026