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CN Labels Copied with a Watermark

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

To: Child Nutrition Program Sponsors

Attention: Food Service and Program Directors

Number: FDP-03-2015 and CNP-08-2015

Date: May 2015

Reference: U.S. Department of Agriculture Policy Memoranda SP 11‑2015(v2), CACFP 10-2015, SFSP 13-2015: CN Labels Copied with a Watermark Acceptable Documentation; and SP 27-2015, CACFP 09-2015, SFSP 12-2015: Administrative Review Process Regarding the Child Nutrition (CN) Label, Watermarked CN Label, and Manufacturer’s Product Formulation Statement

Subject: Administrative Review Process Regarding the Child Nutrition (CN) Label, Watermarked CN Label, and Manufacturer’s Product Formulation Statement

This Management Bulletin (MB) provides California Department of Education (CDE) child nutrition program operators with clarification regarding Child Nutrition (CN) labels, watermarked CN labels, and manufacturer’s product formulation statements (PFS) as they relate to the Administrative Review (AR).

A CN label copied with a marking referred to as a “watermark” is acceptable documentation for an AR. Sponsors will see a watermarked CN label when the CN logo and contribution statement are placed on product information other than the actual product carton and provided as a separate document. Manufacturers may provide sponsors with a watermarked CN label during the bidding process. Sponsors should be aware that product information on a watermarked CN label may contain preliminary information and is subject to change. The CDE encourages sponsors to verify that the CN label with a watermark accurately reflects the purchased product. This will help maintain the integrity of the CN Labeling Program by ensuring that the CN label came from the actual product purchased by the sponsor. During an AR, sponsors may document CN-labeled products as outlined below.
Child Nutrition Labels
The CN label is the preferred documentation to verify the crediting of menu items and provides a warranty against audit claims as long as the sponsor uses the product according to the manufacturer’s instructions. Acceptable and valid documentation for the CN label includes any of the following:
  • The original CN label from the product carton
  • A legible photocopy of the CN label shown attached to the original product carton
  • A legible photograph of the CN label shown attached to the original product carton 
Watermarked Child Nutrition Labels
If the original CN label from the product carton, or the valid photograph or photocopy of the original CN label is not available, sponsors may provide the bill of lading (invoice) containing the product name and a paper or electronic copy of the watermarked CN label that displays the product name and CN number provided by the vendor.
Product Formulation Statement
The CDE will request a valid CN label and crediting statement or a PFS during the AR, as required by the USDA. A PFS is only required when reviewing a processed product that does not contain a CN label.

To support sponsors and manufacturers, the Nutrition Services Division validates PFS calculations for their contribution to the meal pattern and stores them in the Child Nutrition Information and Payment System (CNIPS). This allows sponsors to download and print a validated PFS for their files to use during ARs. Validated PFSs are listed by manufacturer and include the product name and code number in the description. Sponsors can find validated PFSs in the Download Forms section of the FDP module on the CNIPS Web site at https//

Child Nutrition Label Verification System

The U.S. Department of Agriculture (USDA) Food and Nutrition Service is currently working with the USDA Agricultural Marketing Service to develop a CN label verification system. During an AR, this system will assist the CDE to verify the CN label as well as the crediting information. The expected completion date for the verification system is fall 2015.


If you have any questions regarding this MB, please contact Sherry Tam, Child Nutrition Consultant, Food Administration Unit, by phone at 916-324-9875 or by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Thursday, August 13, 2020
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