Skip to main content
California Department of Education Logo

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//www.cnips.ca.gov.

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.

Questions

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 stam@cde.ca.gov.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Thursday, August 13, 2020
Related Content
  • Food Distribution Management Bulletins
    Links to the Food Distribution Program management bulletins.
  • Nutrition
    Resources and information related to child nutrition, nutrition education, food distribution programs, and the Child Nutrition and Physical Activity Advisory Council.
Recently Posted in Nutrition
  • Feeding Adults, Children, and Infants in the CACFP (added 21-Oct-2020)
    The California Department of Education is pleased to share the following new Child and Adult Care Food Program (CACFP) resources from the U.S. Department of Agriculture (USDA) Team Nutrition (TN).
  • Federal Approval of Major Disaster Declaration (added 21-Oct-2020)
    On October 16, 2020, Governor Gavin Newsom announced that the President has approved California’s request for a Major Disaster Declaration to bolster the state’s emergency response to wildfires across the state and support impacted residents.
  • 2020–21 Seamless Summer Site Application Updates (added 19-Oct-2020)
    On Friday, October 9, 2020, the U.S. Department of Agriculture announced the extension of twelve Nationwide COVID-19 waivers. The CDE NSD recognizes that these extensions will require SFAs to once again update SNP site applications in CNIPS.
  • USDA Q&As Relating to the Nationwide Waiver (added 19-Oct-2020)
    On October 14, 2020, the USDA issued Policy Memorandum SP 01-2021, CACFP 01-2021, SFSP 01-2021: Q&As Relating to the Nationwide Waiver to Allow SFSP and SSO Operations through School Year 2020–2021 – EXTENSION – Q&As #2.
  • Legislative Update – Assembly Bill 827 (added 14-Oct-2020)
    Assembly Bill 827 updates mandatory commercial recycling (AB 341) and mandatory organics recycling (AB 1826) requirements regarding student and staff access to recycling bins and organics recycling bins.

  • Public Safety Power Shutoff Event October 14, 2020 (added 14-Oct-2020)
    On October 13, 2020 PG&E announced that public safety power shutoffs are under consideration due to extreme weather and fire danger. If these conditions persist, PG&E may need to turn off power to local customers for safety.
  • Extension of COVID-19 Meal Service Waivers (added 09-Oct-2020)
    The CDE NSD is pleased to announce that the USDA has extended twelve nationwide COVID-19 waivers. These waivers extend existing flexibilities through June 30, 2021.
  • Providing Safe Physical Activity During COVID-19 (added 06-Oct-2020)
    CDE NSD is pleased to share two resources that child care providers can use to learn more about providing a safe environment for physical activity for young children during the Novel Coronavirus (COVID-19) pandemic.
  • 2021 Census Bureau Data for Area Eligibility (added 06-Oct-2020)
    U.S. Department of Agriculture Food and Nutrition Service has announced that the 2021 Child and Adult Care Food Program, Seamless Summer Option, and Summer Food Service Program participant Area Eligibility data are now available.
  • Discover MyPlate (added 06-Oct-2020)
    Six interactive nutrition lessons for kindergarteners including mini books, food cards, recipes, student workbooks, parent handouts, and a poster to help develop healthy food choices and to promote a physically active lifestyle.