Skip to main content
California Department of Education Logo

USDA Foods Inventory Protection Requirements


Nutrition Services Division Management Bulletin

Purpose: Policy, Action Required, Beneficial Information

To: U.S. Department of Agriculture Foods Processors

Attention: U.S. Department of Agriculture Foods Processors

Number: FDP-02-2014

Date: June 2014

Reference: U.S. Department of Agriculture Policy Memorandum FD-134
http://www.fns.usda.gov/minimum-inventory-protection-requirements-processors-participating-national-processing-program (Please note, the previous link is no longer valid, please use https://www.fns.usda.gov/usda-fis/minimum-inventory-protection-requirements-processors-participating-national-processing-program.)

Subject: Minimum Inventory Protection Requirements for Processors Participating in the National and/or State Processing Program


This Management Bulletin (MB) provides U.S. Department of Agriculture (USDA) Foods Processors updated information on the process for calculating minimum inventory protection levels. This MB is effective beginning July 1, 2014.

Title 7, Code of Federal Regulations, Section 250.32(a), requires inventory protection for the contract value of USDA Foods diverted to processors either on hand or on order. This protection ensures that school food authorities receive the full benefit of USDA Foods entitled to them in the event the USDA Foods Processor is unable to provide them with finished end products. In addition, inventory protection also ensures that processors will account for, return, and/or pay for all USDA Foods inventory (physical or book) that has been carried over from previous years. Inventory protection can be provided in one of the following three forms:
  • Performance bond
  • Irrevocable letter of credit
  • Escrow Account [No longer accepted as a form of inventory protection]
Minimum Inventory Protection for National Processors

Processors who have a National Processing Agreement (NPA) with the USDA and have participated for one or more school years will need to maintain minimum inventory protection. The following steps outline the process for calculating the amount of minimum inventory protection needed:

  • Determine the highest monthly ending inventory as reported on the Monthly Performance Reports during the 12 months beginning in December of the previous school year and ending in November of the current school year.

  • Obtain the dollar value of the highest monthly inventory using the USDA estimated cost-per-pound data provided in the November 15 Commodity File Report. The November 15 Commodity File Report is available on the USDA’s Food Distribution Processor Pricing Reports Web page at https://www.fns.usda.gov/usda-fis/processor-material-prices

  • Obtain the minimum inventory protection level required by multiplying the dollar value of the highest monthly inventory by 75 percent.

Example: Processor A is calculating its minimum inventory protection requirement for School Year (SY) 2014–15 for chicken (USDA Foods code 100103–Chix Chill Large). It has determined that:

  • The highest monthly ending inventory level was 65,000 pounds

  • According to the November 15 Commodity File Report (for SY 2014–15), the price per pound of this chicken is $0.8542

To calculate the minimum inventory protection requirement, Processor A will:

  • Determine the dollar value of the highest monthly inventory level by multiplying 65,000 pounds by $0.8542, which equals $55,523.00

  • Multiply this dollar value by 75 percent ($55,523.00 x 0.75), which equals $41,642.25

Therefore, Processor A’s minimum inventory protection requirement for SY 2014–15 would be $41,642.25.   

Minimum Inventory Protection for New Processors

If a processor is entering into an NPA for the first time, inventory protection must be secured prior to receiving USDA Foods deliveries. The minimum inventory protection levels required for new processors must equal 100 percent of the value of the USDA Foods the processor will receive in their first year of processing.  

Minimum Inventory Protection for California-Only Processors

The California Department of Education’s Food Distribution Program (FDP) will follow the same guidelines, outlined above, for calculating minimum inventory protection levels for California-only processors, whether new or returning. The FDP’s Processing Consultants review inventory protection levels annually for all processors approved under the State Master Processing Agreement and will contact those that need to obtain increased inventory protection levels.

Contact Information

If you have any questions regarding this MB, please contact the Food Distribution Program Office by phone at 916-323-0865 or by e-mail at FoodDistribution@cde.ca.gov.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Friday, August 22, 2025
Related Content
Recently Posted in Nutrition
  • Input Request on CA Universal Meals Implementation (added 16-Mar-2026)
    The California Department of Education, in partnership with the Nutrition Policy Institute, is conducting a voluntary statewide survey to continue to assess the implementation of California Universal Meals; this survey is in follow up to the survey c
  • Updated Sample FSMC RFP and Contract in CNIPS (added 13-Mar-2026)
    An updated Sample Food Service Management Company Request for Proposals and Model Fixed-price Contract document is now available. Updates include revised Buy American and California Agricultural Preference requirements and clarified responsibilities.
  • 2026 SUN Bucks Data Submission (added 13-Mar-2026)
    Information on 2026 SUN Bucks data submission.
  • CEP Application Information (added 12-Mar-2026)
    This listserv provides information on applying for the CEP.
  • Interagency Agreements in School Food Service (added 12-Mar-2026)
    This management bulletin provides guidance on interagency agreement requirements when administering the School Nutrition Programs (SNP) at unaffiliated schools.

  • Tuesdays @ 2 School Nutrition Town Hall (added 12-Mar-2026)
    School Nutrition Town Hall webinar for School Nutrition Program Operators and Food Service Directors.
  • Summer Food Service Program Annual Updates (added 12-Mar-2026)
    The California Department of Education (CDE) Nutrition Services Division (NSD) is pleased to announce that the SFSP 2026 Program Year is now open.
  • Reimbursement for Off-Site Meal Consumption (added 02-Mar-2026)
    SNP-06-2026 provides guidance on serving NSLP and SBP meals for off-site consumption.
  • Honoring Cultural Preferences in School Nutrition (added 02-Mar-2026)
    This webinar highlights best practices for incorporating student cultural food preferences honoring Black voice and other cultures, in menu offerings, strengthen student trust and engagement, and support equity in school meal participation.
  • State Meal Mandate (added 02-Mar-2026)
    SNP-05-2026 addresses the requirements for LEAs to serve and claim NSLP and SBP meals for both state and federal reimbursement.