Entrées, Nutrient Standards, and Exemptions

This Management Bulletin (MB) consolidates information from the superseded MBs and includes new information and requirements found in the U.S. Department of Agriculture’s (USDA) Final Rule - Child Nutrition Programs: Meal Patterns Consistent with the 2020-2025 Dietary Guidelines for Americans (DGAs), effective July 1, 2024, and 5 CCR. Recall that California competitive food rules in 5 CCR and EC apply only to public, noncharter schools. Refer to SNP-04-2025 for information on accessing these requirements.

Entrée Definition

The USDA Final Rule (FR) codifies that a grain-only entrée that is served as the main dish in a school breakfast can be considered a competitive entrée and must meet all competitive entrée requirements.

Therefore, 7 CFR Section 210.11(a)(3) now defines a competitive entrée as any of the following:

• A combination of a meat/meat alternate (M/MA) and a grain, or
  
  
• A combination of an M/MA and a vegetable or fruit, or


• An M/MA alone, with the exception of yogurt; low- or reduced-fat cheese; nuts, seeds and nuts or seed butters; and meat snacks (such as dried beef jerky), or


• A grain only entrée that is served as the main dish in a school breakfast

In addition, per 7 CFR Section 210.11(e), all other competitive grains included in competitive snack foods and competitive entrees sold by other groups or by the School Food Authority (SFA) not the day of or day after appearing on the menu must be whole grain-rich (WGR).

Public, noncharter schools must also consider that, although federal regulations 7 CFR Section 210.11(a)(3)(i) and (iv), state that a competitive entrée containing a grain can be WGR or enriched, per California state regulation 5 CCR Section 15575(c)–effective April 1, 2025–the grain in a competitive entrée must be WGR. As a result, any competitive grain, whether a snack or an entrée, served by public, noncharter schools must be WGR.

For additional information regarding competitive grains, refer to MB SNP-04-2025 titled Competitive Foods and Beverages Overview 2025 UPDATE.

Nutrient Standards

Beginning January 1, 2027, and December 31, 2027, EC sections 49431, 49431.2, 49431.5 and HSC Section 109025 California restricts a number of food dyes and additives from use in competitive foods and beverages. Review MB SNP-04-2025, Competitive Foods and Beverage Overview 2025 UPDATE for more details.

A competitive food must also meet specific nutrient standards for compliance. California competitive food rules include six nutrient standards, while federal competitive food rules include:

1. Calories
2. Total fat
3. Saturated fat
4. Trans fat*
5. Sugar
6. Sodium

* Because synthetic trans fats have been removed from the U.S. food supply, the trans fat requirement was removed from federal regulations for nutrient standards for competitive foods found in 7 CFR Section 210.11, per the USDA Final Rule - Child Nutrition Programs: Meal Patterns Consistent with the 2020-2025 DGAs, effective July 1, 2024. Public noncharter schools are advised that California state requirements for nutrient standards for competitive foods found in EC sections 49431(a)(4) and 49421.2(a)(4) still requires that trans fat be analyzed.

A competitive beverage must also meet specific criteria, including certain nutrient standards. These standards differ based on the type of beverage as detailed in state and federal regulations, including 7 CFR Section 210.11(l), EC Section 49431.5, and 5 CCR Section 15576. Review http://www.cde.ca.gov/ls/nu/sn/mbsnp062025.asp for more information.

The Competitive Food and Beverage Quick Reference, found at https://www.cde.ca.gov/ls/nu/he/compfoods.asp on the Resources tab provides additional details on nutrient standards that must be met for a compliant competitive food or beverage.

Nutrient Exemptions

Per federal regulations 7 CFR sections 210.11(d)(1-2), (f)(2-3), (g)(2) and state rules and regulations, EC sections 49431(a)(1-3), 49431.2(a)(1-3) and 5 CCR Section 15575(d)–effective April 1, 2025–certain foods, when sold individually and do not contain added fats or sugars, are exempt from specific nutrient standards as follows:

Foods exempt from the total fat standard^*:

• Nuts
• Seeds
• Nut or seed butters
• Reduced-fat cheese or part-skim mozzarella
• Dried fruit and nut/seed combinations
• Fruit
• Nonfried vegetables
• Eggs
• Seafood

^*While the federal competitive food rules allow bean dip to be exempt from the total fat standard, California competitive foods and beverage rules are stricter; therefore public, noncharter schools cannot exempt bean dip from the total fat standard.

Foods exempt from the saturated fat standard:

• Nuts
• Seeds
• Nut or seed butters
• Reduced-fat cheese or part-skim mozzarella
• Dried fruit and nut/seed combinations
• Nonfried vegetables
• Eggs

Foods exempt from the sugar standard:

• Fruit
• Nonfried vegetables
• Dried fruit and nut/seed combinations

No individual foods are exempt from the calorie, trans fat, or sodium standards.

The Competitive Food and Beverage Quick Reference resources found at https://www.cde.ca.gov/ls/nu/he/compfoods.asp on the Resources tab provide additional details on what foods are exempt from which nutrient standards.

Paired Exemptions

Per 7 CFR Section 210.11(a)(6) and 5 CCR Section 15578(d)–effective April 1, 2025, when food items are paired together and sold as one unit and when each individual item is exempt from one or more of the nutrient standards, the paired item is automatically exempt from the total fat and saturated fat standards. This paired exemption item, in all schools, must still meet the calorie and sodium standards; in public noncharter schools this paired exemption item must, in addition to the previously listed standards, also meet sugar and trans fat standards. Individual items that are exempt from one or more of the nutrient standards are described in the section above.

Examples of paired exemptions in public, noncharter schools include:

• Celery paired with peanut butter and unsweetened raisins – must meet nutrient standards for calories, sodium, sugar, and trans fat
  
  
• Celery is exempt from total fat, saturated fat, and sugar standards
• Peanut butter is exempt from total and saturated fat standards
• Unsweetened raisins are exempt from total fat, saturated fat, and sugar standards
  
  
• Reduced-fat cheese served with apples – must meet nutrient standards for calories, sodium, sugar, and trans fat
  
  
• Reduced fat cheese is exempt from the total fat and saturated fat standards
• Apples are exempt from the total fat and sugar standards

Additional information about paired exemptions can be found on the Resources tab of the Competitive Foods and Beverages web page located at https://www.cde.ca.gov/ls/nu/he/compfoods.asp and in the USDA Policy Memorandum SP 63-2014: Smart Snacks Standards for Exempt Foods When Paired Together, at https://www.fns.usda.gov/smart-snacks-standards-exempt-foods-when-paired-together.

Resources

The CDE Nutrition Services Division Competitive Foods and Beverages web page, at https://www.cde.ca.gov/ls/nu/he/compfoods.asp includes many tools and resources, including the Competitive Foods and Beverages Quick Reference resource.

Forward this management bulletin to all individuals and groups within your school community that are directly affected by this change or may benefit from this information.

Contact Information

If you have any questions regarding this subject, contact the Competitive Foods and Beverages team by email at CompetitiveFoods@cde.ca.gov.