Farm Service Agency

Kansas City Commodity Office

P.O. Box 419205, MS 8698

Kansas City, MO 64141-6205

USDA COMMODITY REQUIREMENTS

HEB1

HIGH ENERGY BISCUITS

FOR USE IN INTERNATIONAL FOOD ASSISTANCE PROGRAMS

Effective Date: May 12, 2015
USDA COMMODITY REQUIREMENTS 

HEB1

HIGH ENERGY BISCUITS

FOR USE IN INTERNATIONAL FOOD ASSISTANCE PROGRAMS 

Table of Contents

Part 1 COMMODITY SPECIFICATIONS............................................................................. 1

Section 1.1 Commodities ............................................................................................................1

Section 1.2 Quality Assurance.....................................................................................................7

Part 2 CONTAINER AND PACKAGING REQUIREMENTS.................................................... 9

Section 2.1 Primary Package........................................................................................................9

Section 2.2 Secondary Package ....................................................................................................9

Section 2.3 Labeling Requirements...............................................................................................9

Section 2.4 Shelf Life, Shipping, and Storage ..............................................................................10

Exhibit A - Markings.................................................................................................................10
Page 1 of 13

Part 1 COMMODITY SPECIFICATIONS

Section 1.1 Commodities

A. Product Purpose and Type

High Energy Biscuits (HEB) are designed to be high in protein and supplemented 

with a premix of vitamins and minerals. They are intended for general food 

distribution and school feeding. 

USAID High Energy Biscuits shall comply, except when specified otherwise in 

solicitations and contracts, with the following guidelines or standards:

a) US Food and Drug Administration (FDA) Food Safety Modernization Act.

b) The 21 CFR 170.3 and 21 CFR 170.30 regulations on food ingredients and 

additives in regard to being Generally Recognize as Safe (GRAS).

c) Guidelines on Formulated Supplementary Foods for Older Infants and 

Young Children, CAC/GL 08-1991 of the Codex Alimentarius.

d) Code of Hygienic Practice for Foods for Infants and Children CAC/RCP 

66 - 2008 of the Codex Alimentarius;

e) Recommended International Code of Practice: General Principles of Food 

Hygiene CAC/RCP 1-1969 Rev 4 - 2003 including Annex “Hazard 

Analysis and Critical Control Point (HACCP) System and Guidelines for 

its application”.

f) General principles for addition of essential nutrients to foods: CAC/GL 

09-1987 (amended 1989, 1991), of the Codex Alimentarius1

B. Main Ingredients

HEB must be manufactured from fresh and good quality ingredients. The product 

shall be free from foreign materials, substances hazardous to health, excessive 

moisture, insect damage and fungal contamination and must comply with all 

relevant national food laws and standards. HEB shall be prepared and packaged in 

accordance with good commercial practice (CFR - Code of Federal Regulations 

Title 21) and shall comply with the following U.S. Standards of Identity:

a. Wheat flour must conform to U.S. 21 CFR 137.105 and Codex STAN 

152-1985. OR

b. Potato flour must conform to appropriate U.S. CFR regulation as well as 

any applicable international standard.

c. Sugar must conform to U.S. 21CFR184.1854 and Codex STAN 212-

1999.

d. Shortening must be prepared from oil as defined by the Food and Drug 

Administration in 21 CFR 101.62 and in conformance with Codex STAN 

210-1999, must be free from trans fatty acids and must contain only 

antioxidants that comply with Codex and relevant regulations.

e. Skimmed milk powder must conform to FDA Regulation as established 

in 21CFR131.110 and in conformance with Codex STAN 207-1999. 

a. It must be accompanied by a ‘melamine-free’ certificate.
Page 2 of 13

b. Maximum level aflatoxin M1: < 0.5 mcg/kg milk (recommended 

methods ISO 14501/IDF 171:20070F

1

or ISO 14674/IDF 190:20051F

2

). 

Other raw materials and additives (if used) must comply with FDA Guidelines, 

Codex or relevant regulations. Raw materials must be stored under dry, ventilated 

and hygienic conditions. Only safe insecticides (i.e. phosphine) may be used for 

fumigation control. Where needed, fumigation must be performed by certified 

operators.

C. Vitamins and Minerals

Complete micronutrient premix must be purchased from an ISO 17025-approved 

supplier, as well as a GAIN-approved Premix Facility or any of the GAIN 

approved suppliers. A complete list is available at the following link: 

http://gpf.gainhealth.org/suppliers/current-suppliers

Micronutrient premix must be delivered to the processor of HEB with a complete 

Certificate of Analysis. The two documents must be presented with other 

documents to USDA for payment. Micronutrient premix must be stored in a dry, 

cool and clean place.

D. Process Description

a. Formula. Formulation shall be based on supplier experience and must include

dry skimmed milk (Minimum of 4.0 g/100g of HEB) and Sugar (10.0-19.0 

g/100g of HEB). 

b. Homogeneity of micronutrients. Theoretical calculations indicate that a 

mixing system with a Coefficient of Variation of 10% using iron as the 

indicator element, will enable product to meet the above variation target on 

95%, provided that all conditions of mixing are rigorously applied. To 

conduct these calculations, see WFP handbook: Fortified Blended Food- Good 

Manufacturing Practice and HACCP Principles and fortification guide on 

http://foodqualityandsafety.wfp.org/coefficient-of-variation-calculator. 

c. Food safety and risk assessment at manufacturing premises. For 

compliance with FDA Guidelines and Codex standards, the processor must be 

able to demonstrate by principle and practice the adoption, implementation 

and recording of Good Manufacturing Practice (GMP), Hazard Analysis 

Critical Control Point program (HACCP), Pathogen and Environmental 

Monitoring (PEM), zoning demarcation and a complete quality and food 

system program. Accordingly, USDA, USAID and/or WFP Inspector / 

Quality Surveyor are entitled to visit the factory without prior notice during 

 

1 Milk and milk powder: determination of aflatoxin M1 content, clean up by immunoaffinity chromatography and determination 

by HPLC.

2 Milk and milk powder: determination of aflatoxin M1 content, clean up by immunoaffinity chromatography and determination 

by Thin Layer Chromatography.
Page 3 of 13

any period when product is being manufactured to check that the above food 

safety and quality are in place, validated and being implemented.

d. First Production Approval and subsequent audits. HEB suppliers are 

expected to go through a preparatory or first production run during which 

baseline data on composition, microbiology, operator training, and grading 

table (sensory analysis) are developed, as well as all calibrations necessary 

before running at full capacity. During start-up run, the supplier must run all 

the required analyticals in this document and ensure that the facility is capable 

of producing the product with the highest quality. During this phase, the 

contracting agency (any or multiple representatives of USDA/FGIS, USAID, 

and/or WFP) may choose to be present.

E. Analytical Requirements

a. Table 1 General Requirements (Based on 100g of Finished Product)2F

3

No. Component Target

1 Moisture content 4.5% max

2 Energy 462 kcal (Min)

3 Protein 10 g min

4 Total Fat

 Saturated

 Trans fat

12 g min

5.7g max

1.34 max

5 Added Sugar 10-19 g

6 Crude Fiber 2.3 g max

7 Total Ash 3.5 g max

8 Peroxide Value 10 meq/ kg fat, max 

b. Finished Product Characteristics

Organoleptic: HEB must have a typical color, pleasant smell and 

palatable taste which consumers will like and enjoy. 

Broken: percentage of broken HEB must not be more than 5.0% (by 

weight).

Weight: one piece of HEB should weigh between 5 g and 10g.

c. Micronutrients.

HEB must be fortified to provide the following target micronutrients supplement 

per 100g of finished product (Table 2)

 

3

These values shall be used for labeling purpose. Suppliers are encouraged to do accelerated shelf life studies to 

ensure these levels of micronutrients are achieved at consumption time
Page 4 of 13

Table 2. Recommended micronutrient rates and chemical forms per 100g finished product3F

4

 

4

This table shall be used for labeling purpose. Suppliers are encouraged to do accelerated shelf life studies to ensure these levels 

of micronutrients are achieved at consumption time.

5

In order to make appropriate formulations, suppliers are encouraged to understand intrinsic contributions of raw material to 

micronutrients as it is will influence the amount of micronutrients in finished product.

No. Vitamin/Mineral Unit Target4F

5

Levels

Chemical Forms

1 Vitamin A (Retinol) μg 250 Palmitate 250 CWS

2 Vitamin B1 mg 0.5 Thiamine mononitrate

3 Vitamin B2 mg 0.7 Riboflavin

4 Niacin mg 6 Nicotinamide

5 Panthothenic Acid mg 3 Calcium d-pantothenate

6 Vitamin B6 mg 1 Pyridoxine hydrochloride

7 Folic Acid μg 80 Folic acid

8 Vitamin B12 μg 2 Vitamin B12 – 1% in manitol

9 Vitamin C mg 20 Ascorbic acid coated

10 Vitamin D μg 1.9 Vit D3 100 CWS

11 Vitamin E mg 5 Vit E 50 CWS

12 Calcium mg 250 Calcium carbonate

13 Magnesium mg 150 Magnesium oxide

14 Iron mg 11 Ferrous fumarate

15 Iodine μg 75 Potassium iodate

16 Sodium mg 0.24 Sodium Chloride, Sodium 

Phosphate
Page 5 of 13

d. Contaminants

Table 3. Most common contaminants and thresholds

Heavy Metals Permissible 

Thresholds5F

6

(mg/kg body)

Per 1000 

Kcal6F

7

(mg)

Analytical Method

Cadmium 0.050 0.12 AOAC 982.23;945.58;973.34

Arsenic 0.107 0.25 AOAC 986.15 AOAC 942.17

Lead 0.179 0.43 AOAC 972.25; 982.23

Mercury 0.036 0.09 AOAC 971.21;952.14

Tin 100.0 238 AOAC 980.19; EN 15764

Other Contaminants

Contaminants Requirements Reference method (or equivalent)

Melamine/Cyanuric 

acid (ppb) Max. 2.5mg/kg

http://www.who.int/foodsafety/

fs_management/Melamine_method

s.pdf 

Aflatoxin B1, B2, 

G1 and G2. (ppb)

< 0.5 ppb AACC 45-16

 

6

Limits are calculated from the protocols and tolerable weekly intake (PTWI) in mg/kg body as defined in the CODEX STAN 

193-1995: Codex General Standard for Contaminants and Toxins in Food and Feed. Calculations were done assuming as 

reference a 5-kg child. Equivalent and validated methods are allowed.

7 Calculation based on PTWI, assuming a lower-end weight of 5kg average child and a 2100 calories daily requirement, using the 

formula: ((mg/kg-body x 5kg)/2100 kcal) x1000 kcal
Page 6 of 13

e. Compulsory Testing and Methods

Table 4: List of compulsory tests and reference methods

No Tests Requirements Reference method (or equivalent)

1 Moisture content Max. 4.5 % AOAC 925.10, 2002

2

Organoleptic

characteristic (color,

smell and taste)

Typical color, Pleasant

smell and palatable

taste.

Sensorial inspection

3 Broken biscuits Max. 5.0 % broken (by

weight) Visual inspection

4 Protein Min. 10 g/100g AOAC 981.10

5 Fat Min. 12.0 g/100g AOAC 963.15, 2000

6 Sugar (total) 10.0-19.0 g/100g AOAC 920.189

7 Crude fiber Max. 2.3 g/100g AOAC 962.09

8 Ash (total) Max. 3.5 g/100g AOAC 942.05, ISO 2171.2000

9 Aflatoxin M1 < 0.5 ppb AACC 45-16

10 Peroxide value Max. 10 meq/kg fat AOAC 965.33

11 Vitamin A-Retinol Min. 250 mcg/100g AOAC 960.45

12 Iron Min. 11 mg/100g AOAC 945.40

13 Mesophillic aerobic 

bacteria

< 10,000 cfu/g ICC No 125

AACC 42-11

14 Coliforms < 10 cfu/g AOAC 2005.03

15 Escherichia coli Absent in 1g AOAC 991.14

16 Salmonella Absent in 25g AACC 42-25B

17 Staphylococcus aureus < 10 cfu/g AACC 42-30B

18 Bacillus cereus < 10 cfu/g AOAC 980.31

19 Yeasts and molds < 100 cfu/g ICC No 146

20 GMO (only if required) Negative (< 0.9% of 

GMO material)
Page 7 of 13

Section 1.2 Quality Assurance

Table 5. General guidelines for food safety and quality control

No. Activity Annotations

1 Qualification audit/ 

preliminary Survey

1. A preliminary USG audit, before granting contract to 

potential suppliers

1. Audit must be HACCP-based 

2. Written manifestation from the suppliers indicating 

commitment to comply with highest levels quality, 

proving all their written quality programs

3. Third party audits to be requested from potential suppliers, 

if sharable 

2 Start-up process 1. Process capability validation

2. Generation of baseline data (production, environmental, 

finished product compliance)

3. Validation of sampling plans for continuous monitoring by 

USG

3 Ongoing monitoring through 

indicative parameters

1. Suppliers need to provide COAs

2. USG will continue to test indicative parameters both for 

microbiology, and composition.

4 Spot, unannounced audits 1. According to supplier production capability, hopefully 

measured as a function of cPk (process variability), at least 

annual audits will take place 

2. If it is a new contract, presence will be compulsory at least 

for one production cycle 

A. The contractor shall perform the product testing and quality analysis to ensure that the 

product meets the commodity specifications. The results shall be evidenced by a 

Certificate of Analysis (COA). Copies of the original COA must be submitted as part of 

the invoice package. The COA shall provide results of all tests specified. 

B. Contractors shall notify the Government immediately of lots that fail to meet contract 

requirements. 
Page 8 of 13

C. Quality Discounts

If the product to be delivered by the contractor does not meet the quality specifications 

required herein, but falls within the discounts listed, the product may be delivered to the 

Government, but the purchase price will be reduced in accordance with the following 

schedule of discounts for each 100 pounds of commodity delivered. A commodity that 

deviates from the specifications may be rejected. 

High Energy Biscuit Discounts

Excess Moisture Excess Sugar

4.51% - 5.00% $0.10 19.10 - 20.00 g/100g $0.10 

5.01% - 5.50% $0.20 20.10 - 21.00 g/100g $0.20 

5.51% - 6.00% $0.35 21.10 - 22.00 g/100g $0.35 

Deficient Protein Excess Crude Fiber

9.99 - 9.50 g/100g $0.10 2.31 - 2.50 g/100g $0.10 

9.49 - 9.00 g/100g $0.20 2.51 - 2.70 g/100g $0.20 

8.99 - 8.50 g/100g $0.35 2.71 - 2.90 g/100g $0.35 

Deficient Fat Excess Ash

11.99 - 11.50 g/100g $0.10 3.51 - 3.75 g/100g $0.10 

11.49 - 11.00 g/100g $0.20 3.76 - 4.00 g/100g $0.20 

10.99 - 10.5 g/100g $0.35 4.01 - 4.25 g/100g $0.35 

Deficient Iron

10.99 - 10.50 mg/100g $0.10 

10.49 - 10.00 mg/100g $0.20 

9.99 - 9.50 mg/100g $0.35 
Page 9 of 13

Part 2 CONTAINER AND PACKAGING REQUIREMENTS

Section 2.1 Primary Package

It is under supplier responsibility to select a packaging material that will protect biscuits from 

moisture as well as vitamins and fat degradation during shelf life.

 It must be based on supplier experience and comply with relevant regulations. 

 It must be food grade, have good sealing properties and be printed as per requirement. 

 It must include a metalized layer to reduce permeability to oxygen and vapor. 

 It must be stored under dry, ventilated and hygienic conditions. 

Typically a laminated composed of BOPP + VMCPP (20 and 25 microns respectively) or 

equivalent or stronger can be used. Each package must contain 100 grams biscuits. 

Section 2.2 Secondary Package

Individual packages must be stuffed in strong cardboard cartons suitable for multiple 

handling and must contain 10kg net biscuits. About 15-20 bags of silica gel of at least 1g 

each should be placed in each container in order to absorb moisture. In addition, craft paper 

should be laid to all sides of the container.

If the contractor purchases packaging and container ingredients from a foreign country and/or 

the package and container is manufactured in a foreign country, the package and container 

SHALL NOT display country of origin labeling. Phrases similar, but not limited to “Made in 

[Name of Foreign Country.]” or “Product of [Name of Foreign Country.]” are strictly 

prohibited. 

Section 2.3 Labeling Requirements

Primary Packaging

 Name of the product 

 USAID’s Logo: USAID Gift of the American People

 Ingredient list

 Net weight

 Table 1 and Table 2

 Contract Number

 Date of manufacture

 Best used by date

 Storage instructions 

 Additional markings as per contractual agreement.

Secondary Packaging 

 Name of the product

 Logo: USAID Gift of the American People

 Contract Number

 Additional markings as per contractual agreement. 
Page 10 of 13

Section 2.4 Shelf Life, Shipping, and Storage

The product shall have a shelf life of 24 months at 30°C, and it shall retain all commodity 

specification qualities included in this specification document for at least 18 months from 

date of manufacture when stored dry at ambient temperatures prevalent in the country of 

destination. HEB must be stored under dry, ventilated and hygienic conditions. 

Exhibit A – Markings

A. Primary Markings
Page 11 of 13

 B. Secondary Markings
Page 12 of 13
Page 13 of 13