Skip to main content
California Department of Education Logo

Storage and Inventory Management of Donated Foods

Nutrition Services Division Management Bulletin
Purpose: Policy

To: Food Distribution Program Recipient Agencies, Commodity Supplemental Food Program Agencies

Number: USDA-FDP-02-2010

Attention: Food Service Director, School Business Official, Program Director

Date: August 2010

Subject: Storage and Inventory Management of United States Department of Agriculture (USDA) Donated Foods

Reference: USDA Policy Memo FD-107, Title 7, Code of Federal Regulations Part 250.14

This Management Bulletin (MB) clarifies the policy regarding the storage and inventory management of USDA foods: first-in first-out (FIFO), expiration dates, use-by and best-if-used-by dates, proper dispositions of spoiled or damaged foods, and single inventory management.

In accordance with Title 7, Code of Federal Regulations, Section 250.14(b), recipient agencies must ensure that foods donated by the USDA are stored in a manner to protect them from spoilage, infestation, damage, or other conditions that may jeopardize the wholesomeness or safety of the foods. Foods donated by the USDA must be maintained in sanitary conditions, at the proper temperature and humidity, and with adequate air circulation. In addition to proper storage practices, effective inventory management is necessary to ensure that USDA donated foods are distributed in a timely manner and in optimal condition.

As a general rule, recipient agencies should use a FIFO system of inventory management. To implement the FIFO system, USDA donated food cases or other containers should be marked with the date of their receipt at the storage facility. Placing incoming commodity food behind older product will ensure rotation of stock for optimal food freshness. However, be aware that many manufacturers date food products to determine how long food products should remain in optimal condition. Such product dates must be considered, along with FIFO in managing donated food inventories.

In addition, different product dates have different meanings, therefore, it is important to know which product date is used and to understand what it means. For example, except for expiration dates, product dates do not necessarily indicate when foods are no longer safe to consume. The following paragraphs describe the meaning of some product dates that may be found on USDA donated foods.

Expiration and Use-by Dates

Generally, "expiration" dates and "use-by" dates are the last dates that the manufacturer recommends a food item be consumed to ensure peak quality and nutrient retention. However, manufacturers are not required to mark their products with such dates. The one exception to these general rules is infant formula. The Food and Drug Administration (FDA) requires manufacturers to mark infant formula with a “use-by” date and prohibits the sale of infant formula after the “use-by” date.

Thus, infant formula that is past its “use-by” date must not be distributed to recipient agencies. Similarly, per manufacturer recommendations, USDA donated food that is past its expiration date or its use-by date must not be distributed to recipients agencies. Accordingly, recipient agencies must manage their inventories to ensure that program recipients have an opportunity to consume all USDA donated foods (i.e., infant formula and other foods) before their expiration dates or use-by dates.

Best-if-used-by Dates

A "best-if-used-by" date is the last date a food item will be at its peak, in terms of flavor and quality. At some point, after that date, the product undergoes changes in taste, color, texture, and/or nutrient content. However, the product may be wholesome and safe to consume, and retains most of its nutrient value long after the "best-if-used-by" date. Nevertheless, recipient agencies must consider "best-if-used-by" dates in managing their USDA donated food inventories, and distribute donated food in a manner that allows consumption by such date.

Sell-by Dates and Pack Dates

A "sell-by" date is the date by which the manufacturer recommends that a store sell the food product, and is not necessarily a reliable indicator of how long it may retain its wholesomeness or nutritional value.

A "pack date" indicates when the product was packaged or processed and may help determine the age of a product. However, it does not provide information about its wholesomeness or nutritional value.

Food Safety

USDA donated foods that show signs of spoilage, infestation, or other visible defects should not be used or distributed, regardless of product dates or when the foods were received; such food is generally considered not fit for human consumption. If there are no visible defects, but there is a question as to the wholesomeness or safety of USDA donated foods, the recipient agency should contact the Food Distribution Program as soon as possible before disposing of any USDA commodity food.

Single Inventory Management

School food authorities, other recipient agencies in child nutrition programs, and charitable institutions may use single inventory management, in which USDA donated foods are stored and inventoried together with purchased foods or other foods. Accordingly, the USDA donated foods are subject to the same safeguards and effective management practices as other foods, and must be treated as all other foods when safety is in question. Thus, such recipient agencies must comply with state, local laws, or regulations in determining the safety of all foods, including USDA donated foods.

This MB clarifies the USDA policy, “Storage and Inventory Management of USDA Donated Foods” dated June 9, 2010, located at the USDA Web page

If you have any questions regarding this MB, please contact Amy Bell, Child Nutrition Consultant, Commodity Distribution Unit, by phone at 916-322-5051, toll-free at 800-952-5609, or by e-mail at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Tuesday, March 7, 2017
Related Content
Recently Posted in Nutrition