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Nutrition Requirements for Fluid Milk in the CACFP

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: Child and Adult Care Food Program
All Child Care Agencies

Attention: Food Program Director

Number: CACFP-09-2017

Date: September 2017

Reference: U.S. Department of Agriculture Policy Memorandum CACFP 17-2016

Supersedes: Management Bulletin USDA-CACFP-20-2011 Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP

Subject: Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP

This management bulletin (MB) notifies Child Nutrition Program operators that the U.S. Department of Agriculture (USDA) has updated MB USDA-CACFP-20-2011, dated December 2011, by providing Child and Adult Care Food Program (CACFP) agencies with nutrition requirements for fluid milk and fluid milk substitutions.

A policy memo detailing this information from the USDA is available at the USDA Nutrition Requirements for Fluild Milk and Fluid Milk Substitutions in the CACFP, Q&As web page at


The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296, amended section 17 of the Richard B. Russell National School Lunch Act (NSLA) to require the USDA to update the CACFP meal pattern requirements to make them consistent with the most recent version of the Dietary Guidelines for Americans, the most recent relevant nutrition science, and appropriate authoritative scientific agency and organization recommendations. On April 25, 2016, USDA published the final rule Child and Adult Care Food Program: Meal Pattern Revisions Related to the Healthy, Hunger-Free Kids Act. This final rule added the fluid milk requirements and allowance of nondairy beverages outlined in memorandum CACFP 21-2011 Revised Child Nutrition Reauthorization 2010: Nutrition Requirements for Fluid Milk and Fluid Milk Substitutions in the CACFP, Questions and Answers to the CACFP regulations under Title 7, Code of Federal Regulations (7 CFR), 226.20(a)(1) and 226.20(g)(3), respectively. The final rule also established additional nutrition requirements and flexibilities for fluid milk served in the CACFP.

One Year Old Children

Beginning October 1, 2017, one year old children must be served unflavored whole milk. This is consistent with recommendations from the National Academy of Medicine. Additionally, breastmilk is considered an allowable fluid milk substitute for children of any age if a mother chooses to breastfeed her child past one year of age.

Children Two Years Old and Older and Adults

Milk served to children two years old and older and adults must be low-fat or fat-free. Whole milk and reduced-fat (2 percent) milk may not be served to participants two years of age and older or to adults. This has been in effect since September 15, 2011.

Switching immediately from whole milk to low-fat or fat-free milk when a child turns two years old may be challenging. Therefore, the USDA is allowing a one-month transition period. During this one-month period, meals served to children 24 to 25 months old that contain whole milk or reduced-fat milk (2 percent) may be claimed for reimbursement.

Flavored Milk

Flavored milk contains added sugars and the Dietary Guidelines recommends that all Americans reduce their consumption of added sugars. To better align with the Dietary Guidelines’ recommendation and help children develop healthy eating practices early, the USDA established new requirements for flavored milk:

  • Children one through five years old: Flavored milk or flavored nondairy beverages served to children one through five years old cannot be claimed for reimbursement.

  • Children six years old and to older adults: If flavored milk is served to children six years old and older or adults it must be fat-free. This is consistent with the National School Lunch and School Breakfast Programs.

CACFP centers and day care homes must comply with these flavored milk requirements by October 1, 2017.

Nondairy Beverages as Fluid Milk Substitutes

In the case of children who cannot consume fluid milk due to special dietary needs, personal preference, or religious reasons (in instances where it is not a disability), the caregiver may serve nondairy beverages in lieu of fluid milk. Nondairy beverages must be nutritionally equivalent to milk and meet the nutritional standards for fortification of calcium, protein, vitamin A, vitamin D, and other nutrients to levels found in cow’s milk, as outlined in the CACFP regulations 7 CFR, Section 226.20(g)(3). As mentioned above, nondairy beverages served to children one through five years old must be unflavored.

Parents, guardians, adult participants, or a person on-behalf of the adult participant, must provide a written request for the nondairy milk substitution that is nutritionally equivalent to fluid milk. As an example, if a parent has a child who follows a vegan diet, the parent can submit a written request to the child’s caregiver asking that soy beverage be served in lieu of cow’s milk. Such substitutions are at the option and the expense of the center or day care home. A sample form that agencies can use to document the parent’s request for a milk substitute was developed by the California Department of Education Nutrition Services Division.

A medical statement is required for nondairy substitutions due to a disability that do not meet the nutritional standards of cow’s milk. The medical statement must be completed and signed by a licensed physician, nurse practitioner or physician’s assistant.

The Parental Request for Fluid Milk Substitutions form and the Medical Statement to Request Special Meals and/or Accommodations form are in the download forms section on the Child Nutrition Information and Payment System (CNIPS) Web page at They are also available on the CACFP Forms Web page at

Yogurt (Adults Only)

Beginning October 1, 2017, yogurt (six ounces by weight or ¾ cup by volume) may be served to meet the fluid milk requirement once per day for adults only.

Allowing yogurt to substitute fluid milk once per day for adults offers greater flexibility to the menu planner and will help encourage consumption of a calcium rich food among adult participants. Yogurt may not be substituted for fluid milk for children of any age.


To ensure compliance with the milk requirements, centers and day care homes must document the type of milk served on their menu. This includes listing the fat content and if the milk is flavored.

Additional Information

To assist you with implementation, we have provided the following guidance about the nutrition requirements for fluid milk and fluid milk substitutions:

Contact Information

If you have any questions regarding this subject, you can contact Nancy Charpentier, CACFP Office Technician (OT), by phone at 916-327-2991 or by e-mail at, or Lee Foland, Community Nutrition Programs Administration OT, by phone at 916-324-6153 or by e-mail at You can also contact the CACFP team by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Wednesday, November 20, 2019
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