Updates to School Nutrition Program Standards

This Management Bulletin (MB) includes requirements and flexibilities related to meal pattern standards and menu planning flexibilities for the National School Lunch Program (NSLP), including NSLP Afterschool Snacks, the School Breakfast Program (SBP), the Special Milk Program (SMP), and the Summer Food Service Program (SFSP) enacted by or communicated in:

• USDA Child Nutrition Programs: Meal Patterns Consistent with the 2020–2025 Dietary Guidelines for Americans (DGA) Final Rule (89 FR 31962);  
  
  
• The Whole Milk for Healthy Kids Act of 2025 (P.L. 119-69), the Final Rule Expanding Fluid Milk Options in Child Nutrition Programs (91 FR 25073) and SP 08-2026 CACFP 04-2026: Expanding Fluid Milk Options in Child Nutrition Programs; and
  
  
• USDA Policy Memorandum SP 05-2026, SFSP 03-2026 2026 Appropriations Act: Effect of Child Nutrition Programs.

The final rules and policy guidance noted above also addressed competitive foods, modifications to accommodate disabilities, fluid milk substitutions, procurement, and professional standards. For more information on these topics, review the respective MBs listed on the California Department of Education’s School Nutrition Program (SNP) MBs web page accessed at https://www.cde.ca.gov/ls/nu/sn/mb.asp.

Requirements for the National School Lunch and School Breakfast Programs

Nutrition Requirements

The USDA’s Final Rule, Meal Patterns Consistent with the 2020–2025 DGA made significant updates to school nutrition standards specifically for added sugars, flavored milk, sodium, and trans fat for the NSLP and SBP. Additionally discretionary flexibilities were included in the USDA’s Final Rule Expanding Fluid Milk Options in Child Nutrition Programs. The resulting nutritional requirements are detailed below.

Added Sugar

Added sugar limits are implemented in two phases:

• Phase 1. Effective July 1, 2025, implements product-based limits for breakfast cereals, yogurt, and flavored milk.
  
  
  • Breakfast cereals must contain 6 grams (g) or less of added sugar per dry ounce (oz) (7 CFR sections 210.10[c][2][iii][B] and 220.8[c][2][iii][B]).
    
    
  • Yogurt must contain 12 g or less of added sugars per 6 oz (2 g per oz) (7 CFR sections 210.10[c][2][iv][C] and 220.8[c][2][iv][C]).
    
    
  • Flavored milk must contain:
    • 10 g or less of added sugar per 8 fluid oz when served in the reimbursable school meal program and when sold as a competitive beverage at any grade level (7 CFR sections 210.10[d][1][iii], 220.8[d], and 210.11[l][1][ii], [2][ii], and [3][ii]).
      
      
    • 15 g or less per 12 fluid oz when sold as a competitive food in middle and high schools only (7 CFR sections 210.10[d][1][iii], 220.8[d], and 210.11[2][ii] and [3][ii]).
      
      
  • Phase 2. Effective July 1, 2027, implements a weekly added sugar specification which limits added sugars to less than 10 percent of calories per week (7 CFR sections 210.10[f][3] and 220.8[f][3]).
    

Sodium

Like added sugar, the sodium limits will be phased in over time:

• Through June 30, 2027, sodium limits remain unchanged. Limits will remain at sodium Target 1A for lunch and sodium Target 1 for breakfast.
  
  
• Effective July 1, 2027, sodium levels of the meals offered in the NSLP and SBP must align with the age/grade group and the corresponding sodium limit when averaged over the school week. It does not apply daily or per meal (7 CFR sections 210.10[f][4] and 220.8[f][4]).

Saturated Fat

Saturated fat content contributed by milk and served as a part of an NSLP and SBP reimbursable meal can be excluded from the calculations for the weekly percent calories from saturated fat.

Refer to the California Department of Education (CDE) NSLP and SBP Meal Pattern web pages for specific information on meal pattern requirements, accessed at https://www.cde.ca.gov/ls/nu/he/smi.asp.

Additional California Meal Pattern Requirements for State Meal Reimbursement

California law has certain restrictions on foods served through the NSLP and SBP. For public noncharter schools, charter schools, and county offices of education (COE):

• Trans Fat and Fried Items: Deep fried, par fried, or flash fried items, or items that contain artificial trans fats artificial are prohibited, unless the manufacturer’s documentation or the label lists the trans fat content as less than 0.5 grams per serving EC Section 49430.7 and school food authoritie (SFAs) must certify compliance annually.
  
  
• Food Additives
  
  
  • Beginning January 1, 2027, the manufacture, sale, or provision (delivering, distribution, holding, and offering) of food products in California that contain brominated vegetable oil, potassium bromate, propylparaben, and red dye number 3 is prohibited (Health and Safety Code Section 109025).
    
    
  • Beginning December 31, 2027, the definition of meals eligible for state reimbursement found in EC Section 49501.5 prohibits any of the following food dyes: Blue 1 (Chemical Abstract Service [CAS] 3844-45-9), Blue 2 (CAS 860-22-0), Green 3 (CAS 2353-45-9), Red 40 (CAS 25956-17-6), Yellow 5 (CAS 1934-21-0), and Yellow 6 (CAS 2783-94-0).

California law requires that School Nutrition Program Operators complete an annual certification of compliance with these requirements. The Certification of Compliance with Nutritional Requirements for State Meal Reimbursement form, completed in the Child Nutrition Information and Payment System, specifies the nutrition standards required by state law as a condition of receiving state meal reimbursement, including certifying that meals comply with the trans fat and food additives restrictions listed above as well as the current federal meal pattern requirements. The form is completed during the initial application process as well as during the Annual Renewal Process. Program Operators that fail to certify compliance with applicable nutrition requirements annually will be ineligible for state meal reimbursement.

Meal Pattern

Serving Preschool Students

In California, per EC 48000, Transitional Kindergarten (TK) is considered the first year of a two-year Kindergarten (K) program. The preschool meal pattern may be used when TK students are served in the NSLP, including Afterschool Snacks, and the SBP. If preschoolers are comingled, or served at the same time, as older children, USDA Policy Memo SP 37-2017 allows School Food Authorities, or SFAs, the flexibility to use one meal pattern–kindergarten through grade five (K–5)–to serve all comingled students.

For more information on comingling review the SNP-09-2026 Preschool Meal Pattern Requirements in the NSLP accessed at https://www.cde.ca.gov/ls/nu/sn/mbsnp092026.asp.

Definition of Whole Grain-Rich

The term whole grain-rich (WGR) is now defined in federal regulations for the SBP and NSLP. The term means that the whole-grain content of a product is between 50 and 100 percent and any remaining grains are enriched (7 CFR sections 220.8[c][2][iii][A] and 210.10[c][2][iii][A]).

Nuts and Seeds

Recent federal SNP guidance allows nuts and seeds to credit for the full meats/meat alternates (M/MA) component for meals and snacks. This update impacts the NSLP, SBP, and SFSP.

Use of NSLP and SBP Meal Patterns in the Summer Food Service Program

SFAs that operate the NSLP and SBP, and are approved to operate the SFSP when school is not in session, may use the NSLP or SBP meal pattern requirements (7 CFR Parts 210.10 and 220.8) instead of the SFSP meal pattern requirements, as permitted under 7 CFR 225.16(f)(1)(i).

Additionally, for summer school instructional days, California EC sections 49501.5(k)(1)(A), (k)(2)(A), and (3) further requires that participating school districts, county superintendents of schools and charter schools, operating the SFSP during a summer school day meet NSLP and SBP meal pattern requirements to be eligible for state meal reimbursement. 

Other Requirements

Potable Water Requirements

Federal regulations were clarified by adding the word plain to describe the requirement for the water that must be accessible during the NSLP and SBP meal service. Plain was added to preserve access to water during mealtime for children and students that may not tolerate water with added fruits, vegetables, or herbs (7 CFR sections 210.10[a][1][i] and 220.8[a][1]). Flavored waters may continue to be offered as long as there is also a plain water option available at no cost. For more information, refer to the MB Availability of Potable Water to Children and Allowable Costs guidance available at https://www.cde.ca.gov/ls/nu/sn/mb.asp.

Buy American

The Buy American provision is a procurement standard that SFAs must comply with when purchasing food products served in SNPs. SFAs are required to purchase domestic food commodities or products to the maximum extent practicable. Federal regulations allow for SFAs to use exceptions to purchase nondomestic food items but have established percentage caps and documentation requirements for exceptions. In addition, regulations define “substantially” to mean that food products must consist of over 51 percent of agricultural commodities that were grown domestically. For more information on procurement requirements for SNPs, review MB SNP-01-2025 Buy American Provision accessed at https://www.cde.ca.gov/ls/nu/sn/snp012025.asp and visit the CDE’s Procurement in School Nutrition Programs web page, tab Buy American at https://www.cde.ca.gov/ls/nu/sn/fsmcproc.asp.

Menu Planning Flexibilities

Federal guidance established menu planning flexibilities in six areas outlined below; these are voluntary options that SFAs may choose to consider when planning their menus. Program Operators have the discretion whether or not they choose to incorporate them as a part of their SNP operations.  

Substituting Vegetables for Fruits in the School Breakfast Program

• One Day: Schools that choose to offer vegetables in place of fruits at breakfast one day per school week, may offer any vegetables, including starchy vegetables (7 CFR Section 220.8[c][2][ii]).
  
  
• Two or More Days: Schools that choose to offer vegetables in place of fruits at breakfast, two or more days during the school week, must offer vegetables from at least two different vegetable subgroups (7 CFR Section 220.8[c][2][ii]).

Note that the option to offer any vegetable, including starchy vegetables, for fruits in the SBP with no subgroup vegetable requirement ends as of June 30, 2027. Vegetables may be offered as part or all of the fruits requirement in the SBP. SFAs are not required to make any breakfast menu changes.

Additional meal pattern flexibilities for traditional indigenous foods and for tribally operated schools are detailed below.

Combined Grains and Meats/Meat Alternate Meal Components in the School Breakfast Program

The USDA Child Nutrition Programs: Meal Patterns Consistent with the 2020–2025 DGA Final Rule created a combined Grains and Meats/Meat Alternate (M/MA) meal component in the SBP, which allows schools the flexibility to offer grains, M/MA, or a combination of both at breakfast.

Additionally, the requirement for schools to offer 1.0 oz equivalent of grains each day at breakfast was discontinued. The minimum creditable serving remains at 0.25 oz (7 CFR Section 210.10[c][2][iv]).

Beans, Peas, and Lentils

The name of the beans and peas (legumes) vegetable subgroup has changed to the beans, peas, and lentils subgroup. This update is consistent with subgroup names across other Child Nutrition Programs (CNP) and applies to the NSLP, SBP, and SFSP.

Beans, Peas and Lentils Flexibility at Lunch: Allows beans, peas, and lentils, when offered as a meat alternate, to also count towards the weekly beans, peas, and lentils vegetable subgroup requirement but may not count toward the daily or weekly vegetable component (7 CFR Section 210.10[c][2][iv][E]).

Fluid Milk

In addition to the existing fluid milk options of non-fat and low-fat (1 percent) milk, the Whole Milk for Healthy Kids Act and the Final Rule Expanding Fluid Milk Options in Child Nutrition Programs provide Program Operators the discretion to serve reduced-fat (2 percent) and whole milk in the NSLP, SBP, and SMP to children as follows:

• One (1) years of age- unflavored whole milk only
  
  
• Two to 5 years old- whole, reduced-fat (2 percent), low-fat (1 percent), or fat-free milk; unflavored only
  
  
• Six (6) years and older and adults- whole, reduced-fat (2 percent), low-fat (1 percent), or fat-free milk; milk may be unflavored or flavored

As previously noted above:

• The saturated fat content of fluid milk may be excluded from the weekly average calculations for NSLP and SBP when determining compliance with the federal meal pattern requirements.
  
  
• The federally mandated added sugar product limits apply to flavored milk served as a part of the CNPs (7 CFR sections 210.10[d][1][i], 215.7a[a], and 220.8[d])

The SFSP meal pattern requirements already allow for whole and reduced-fat milk options (7 CFR 225.16[d]).

Crediting Traditional Indigenous Foods

Traditional indigenous foods may credit toward the required meal components in the SBP and NSLP. Schools are encouraged to serve these foods as part of the breakfast, lunch, and afterschool snack service. Per 7 CFR sections 210.10(c)(7) and 220.8(c)(4), the term traditional foods refers to foods that have traditionally been prepared and consumed by an American Indian tribe, including wild game meat, fish, seafood, marine mammals, plants, and berries.

Substituting Vegetables for Grains in Tribal Communities

For the NSLP and SBP, SFAs operated by the Bureau of Indian Education and that primarily serve American Indian or Alaska Native children may serve vegetables in order to meet the grains requirement (7 CFR sections 210.10[c][3] and 220.8[c][3]).

For SFSP, the SFAs, institutions, and facilities as applicable, who primarily serve American Indian or Alaska Native participants may substitute vegetables for grains or breads (7 CFR 225.16[f][3]).

Nutrition Requirements for NSLP Afterschool Snacks Program

Additional information may also be found on the CDE’s Serving Afterschool Snacks web page Meal Patterns tab accessed at https://www.cde.ca.gov/ls/nu/as/.

Meal Components

Effective July 1, 2025, the nutrition requirements for NSLP Afterschool Snack Program, served to K-12 children, which includes Transitional Kindergarten students, aligns with the CACFP snack standards as noted below (7 CFR Section 210.10[o][2][i]).

• NSLP afterschool snacks must include two of the five components.
  
  
  • The five components are: milk, M/MA, vegetables, fruits, and grains.
    
    
    • Fruits and vegetables were previously a combined component.
      
      
  • Only one of the two components served at snack may be a beverage.

Milk and Juice

• No more than half of the weekly fruit or vegetable offerings may be in the form of juice.
  
  
• If fluid milk is served, it must meet the following requirements by age group:
  
  
  • For one year olds: fluid milk must be unflavored whole milk only
    
    
  • Two to 5 years olds: fluid milk may be whole, reduced-fat (2 percent), low-fat (1 percent), or fat-free milk and must be unflavored
    
    
  • Six and older and adults: fluid milk may be unflavored and flavored whole, reduced-fat (2 percent), low-fat (1 percent), or fat-free milk;
    
    
• The product limit for added sugar in milk served as a part of the NSLP and SBP do not apply to NSLP Afterschool Snacks.

Added Sugar

• Breakfast cereals must contain 6 g or less of added sugar per dry oz and
  
  
• Yogurt must contain 12 g or less of added sugars per 6 oz (2 g per oz).

Grains

• Grain-based desserts do not count toward the grains requirement.
  
  
  • Whole-grains: At least 80 percent of grains offered weekly (by ounce equivalents) must be WGR and the remaining grains items offered must be enriched. Grain-based desserts may not be used to meet the grains requirement.

Fried Foods

• Foods that are deep-fat fried on-site are not reimbursable as NSLP afterschool snacks. (7 CFR 226.20[d]).
  
  
• California EC Section 49430.7 requires that food items served by a school district, charter school, or COE must:
  
  
  • Not be deep fried, par fried, or flash fried.
    
    
  • Not contain oils or fats such as palm, coconut, palm kernel, or lard at any stage of the manufacturing or preparation process.

Resources

• CDE School Nutrition Programs Management Bulletins web page at https://www.cde.ca.gov/ls/nu/sn/mb.asp
  
  
• USDA Updates to the School Nutrition Standards web page at https://www.fna.usda.gov/cn/school-nutrition-standards-updates.
  
  
• USDA Crediting Tip Sheets in Child Nutrition Programs at https://www.fna.usda.gov/tn/cn/crediting-tipsheets.
  
  
• CDE NSLP and SBP Meal Patterns web page at https://www.cde.ca.gov/ls/nu/he/smi.asp.
  
  
• CDE Milk Requirements in the CNPs web page at https://www.cde.ca.gov/ls/nu/he/milkrequirementsincnps.asp.
  
  
• CDE Disability Modifications Including Food Allergies web page at https://www.cde.ca.gov/ls/nu/sn/modaccomdisinclfoodalgry.asp.
  
  
• CDE Drinking Water for Student in Schools web page at https://www.cde.ca.gov/ls/nu/he/water.asp.
  
  
• CDE Competitive Foods and Beverage web page at https://www.cde.ca.gov/ls/nu/he/compfoods.asp.

Contact Information

• For SNP meal pattern questions and questions regarding serving comingled students email the SNP Unit at SNPInfo@cde.ca.gov.
  
  
• For SFSP questions email the SFSP team at SFSP@cde.ca.gov.
  
  
• For competitive foods questions email the Competitive Foods and Beverages team at COMPETITIVEFOODS@cde.ca.gov.
  
  
• For Buy American procurement questions regarding procedures, solicitations, and contract processes email the team at NSDBuyAmericanProvision@cde.ca.gov.