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Fluid Milk Substitution Questions and Answers

Fluid milk and fluid milk substitution questions and answers from the U.S. Department of Agriculture (USDA).

Fluid Milk and Fluid Milk Substitution Questions and Answers from the United States Department of Agriculture (USDA)

A. Flavored Milk

  1. Can a center or day care home add chocolate or strawberry syrup to unflavored milk and serve it to children 1 through 5 years old?

    No, adding syrup to unflavored milk adds sugar to the unflavored milk and turns the beverage into flavored milk. Flavored milk is not allowed as part of a reimbursable meal for children 1 through 5 years old starting October 1, 2017. Added sugars are currently consumed in excessive amounts and contribute a substantial portion of calories consumed by Americans without contributing importantly to the overall nutritional adequacy of the diet.

    Additionally, zero calorie and sugar-free syrups are not allowed to be added to unflavored milk served to children 1 through 5 years old. Research indicates that flavor and food preferences are shaped early in life and that the more sweet foods children consume, the more they prefer sweet foods. It is important to establish in young children the habit of drinking unflavored milk as taste preferences are developed at a young age.

    Similarly, syrup (including zero calorie and sugar-free syrups) may not be added to low-fat (1%) milk for children ages 6 years old and older and adults. This is because when flavored milk is served to children 6 years old and older and adults, it must be fat-free starting October 1, 2017.

  2. Can a center or day care home start implementing the flavored milk provisions prior to October 1, 2017?

    Yes, centers and day care homes may stop serving flavored milk to children 1 through 5 years old and start serving only fat-free flavored milk to children 6 years old and older and adults at any time. This is because the flavored milk provisions in the updated meal patterns are consistent with the current meal pattern requirements. FNS strongly encourages implementing these flavored milk provisions, and other provisions under the updated meal patterns that are consistent with the current meal patterns (e.g. serving whole grains, limiting juice and sugar, prohibiting grain-based desserts, etc.), as soon as is feasible for the center or home.

    Please note, State agencies cannot disallow meals that are not compliant with the updated meal patterns until the updated meal patterns are implemented on October 1, 2017. See the memorandum SP 42-2016, CACFP 14-2016 Early Implementation of the Child and Adult Care Food Program Meal Patterns External link opens in new window or tab. (PDF) for more information on implementing the updated meal patterns prior to October 1, 2017.

B.  Non-Dairy Milk Substitutions

  1. Is a center or day care home required to provide a non-dairy milk substitute if it is not related to a disability?

    No. It is at the center’s or day care home’s discretion to provide a non-dairy milk substitute if it is not related to a disability. However, FNS strongly encourages centers and day care homes to make meal modifications to accommodate participants’ non-disability special dietary needs.

  2. Must non-dairy beverages served to children 1 through 5 be unflavored?

    Yes, fluid milk and non-dairy beverages that are served to children 1 through 5 years of age must be unflavored starting October 1, 2017.

  3. Must non-dairy beverages meet the fat content requirements of fluid milk?

    No. Non-dairy beverages are not required to be low-fat or fat-free when served to children 2 years old and older and adults. In order for a non-dairy beverage to meet the nutrient requirements for milk substitutes, they must be fortified and some fat is needed to help mask the flavor of the nutrient packet added. Therefore, setting a fat standard for non-dairy beverages would severely restrict the number of available non-dairy beverage options that are nutritionally equivalent to cow’s milk. This would consequently limit centers’ and day care homes’ ability to meet the special dietary needs of children or adults requesting a substitute.

  4. Will centers and day care homes receive additional meal reimbursements if they provide a non-dairy milk substitution?

    No. Modified meals that are due to a disability or non-disability, including meals with non-dairy milk substitutions, are reimbursed at the same rate as regular meals. Centers and day care homes cannot require a parent or guardian to pay the difference between the fluid milk and the non-dairy milk substitute if the non-dairy milk substitute costs more than the fluid milk.

  5. If a parent provides a creditable non-dairy milk beverage, can the center or day care home serve it and still receive reimbursement?

    Yes. If a parent provides a non-dairy milk beverage that meets the nutritional standards outlined in 7 CFR 226.20(g)(3), the center or day care home may serve the non-dairy milk substitute and claim reimbursement for the meal.

  6. If a parent or adult participant can request a non-dairy milk substitute that is equivalent to cow’s milk, can the parent or adult participant also request that their child or themselves be served whole or reduced-fat (2%)milk?

    No. Milk served to children two years old and older and adult must be low-fat or fat-free in order to be reimbursable (7 CFR 226.20(a)(1)). Therefore, any request for higher fat milk must be made through a medical statement, related to a disability, and prescribed by a licensed physician or a licensed health care professional in order to be reimbursable.

C. Compliance

  1. When submitting menus for review, do centers and day care homes need to document the type of milk that they serve?

    Yes. Starting October 1, 2017, centers and day care homes must document the type of milk served on their menus. The menu must indicate the fat content of the milk and if it is flavored. In addition, it is the responsibility of the State or sponsor, as applicable, to further ensure that the correct type of milk is being served when conducting reviews.

  2. If one year old and two year old children sit together for the same meal, must they be served different types of milk?

    Yes, starting October 1, 2017 children two years old and older must be served unflavored
    low-fat or unflavored fat-free milk and children one year of age must be served unflavored whole milk. The fluid milk requirements are based on age to ensure that children are receiving the nutrients they need for growth and development. Centers and day care homes must ensure that children of various ages seated together receive the appropriate type of milk.

  3. What if the parent agrees to provide the non-dairy substitute, but brings in one that does not meet the USDA’s nutritional standards; can the center or day care home serve it and still receive reimbursement?

    Centers and day care homes should inform parents, guardians, and adult participants about the types of creditable non-dairy milk substitutes. If a non-dairy milk substitute is served that does not meet the nutritional standards outlined in 7 CFR 226.20(g)(3), then the meal is not reimbursable.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Friday, October 13, 2017
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