Guidance for Processed Product Documentation

This Management Bulletin (MB) provides Child Nutrition Program (CNP) Operators guidance on documenting how a food item meets meal pattern requirements of the National School Lunch Program, School Breakfast Program, and the Summer Food Service Program (SFSP), and how the California Department of Education (CDE) verifies this process through an administrative review (AR). This MB also provides updates to the Child Nutrition (CN) Label Verification System and clarification of the Valid Until date shown on the CN Label Verification Report. Finally, this MB outlines the documentation necessary for the AR, other reviews, and outside audits.

Background

CNP Operators are responsible for ensuring meal pattern requirements are met, as well as having a process for maintaining appropriate documentation for verifying meal program requirements. CNP Operators must use one of the following documentation methods to demonstrate how a processed end product or food item contributes to the meal pattern:

• Food Buying Guide (FBG) for Child Nutrition Programs
• Food manufacturer’s CN Label
• Watermarked CN Label
• Product Formulation Statement (PFS)

The documentation must be maintained on file in the event of an AR or other review or audit.

This MB provides guidance specific to the manufacturer’s CN Label, a watermarked CN Label, or a PFS.

Child Nutrition Labels

The U.S. Department of Agriculture (USDA) CN Label Program is a voluntary federal program that ensures processed end products provide the stated contribution toward the meal pattern.

Specifically, a CN label contains the CN logo and provides the:

• Contribution toward meal pattern requirements
• Product identification number assigned by the USDA
• Approval date listed as month and year
• USDA authorization statement

CN labels are only available for main dish/entrée processed end products that contribute at least 0.5-ounce equivalents to the meat/meat alternate component of the meal pattern (e.g., cheese and bean burritos, cheese and meat pizzas, breaded fish). CN labels may also include grain, fruit, and/or vegetable meal pattern contributions.

For a product to carry a CN label, the end product must first be evaluated by the USDA Food and Nutrition Service (FNS) to determine its contribution toward the meal pattern and also be produced under federal inspection by the USDA or the U.S. Department of Commerce. The CN Label Program provides a USDA-approved method to document the processed end products’ contribution to the meal pattern. The CDE will request a valid CN label and crediting statement or a PFS during the AR, as required by the USDA.

The USDA Agricultural Marketing Service (AMS) publishes a list of manufacturers that have met all the requirements of the CN Labeling Program, and a list of approved CN labeled end products with corresponding CN label numbers. The AMS updates these lists monthly. To view the lists, visit the USDA Authorized Labels and Manufacturers web page at https://www.fns.usda.gov/cn/labeling/usdausdc-authorized-labels-and-manufacturers. Note: These manufacturers lists are for informational purposes only and are not considered acceptable proof of CN labeling

Child Nutrition Label Updates and the Final Rule

On April 24, 2024, the USDA released the final rule Child Nutrition Programs: Meal Patterns Consistent with the 2020–2025 Dietary Guidelines for Americans. The final rule required only minor changes which minimally impact CN labels. CNP Operators should be aware that the vegetable subgroup, legumes, as of July 1, 2024, is now beans, peas, and lentils. Manufacturers may continue to use the term legumes vegetables on approved CN labels; however, during the application renewal or resubmission, manufacturers must update the term to beans, peas, and lentils.

Products that contain beans, peas, and lentils may be credited as a meat/meat alternate or vegetable. As referenced in Title 7 Code of Federal Regulations 210.10(c)(2)(ii)(C): “Cooked dry beans, peas, and lentils may be counted as either a vegetable or as a meat alternate but not as both in the same dish. When offered toward the protein sources component, beans, peas, and lentils may count toward the weekly beans, peas, and lentils vegetable subgroup requirement, but may not count toward the daily or weekly vegetable component requirement.” Per the USDA’s CN Labeling Manual, these products must include two crediting statements: one for the meat/meat alternate and one for the beans, peas, and lentils.

Documentation for Annual Reviews

Valid and acceptable documentation for the CN label includes one of the following:

1. the original CN label from the product carton
   
   
2. a legible photocopy of the CN label shown attached to the original product carton
   
   
3. a photograph of the CN label shown attached to the original product carton
   
   
4. a CN label copied with a watermark displaying the product name and CN number provided by the vendor and the Bill of Lading or invoice
   

Watermarked Child Nutrition Labels

Product information on the watermarked CN label can change. Therefore, CNP Operators are encouraged to verify that the watermarked CN label came from the product that was purchased and accurately reflects that product.

Dates Related to Child Nutrition Labels

Once authorized, CN labels are valid for five years under the condition that the manufacturer remains an authorized CN producer, and the product formulation does not change. The date printed on the CN label is the original date of authorization or the date of the most recent authorization for use of that CN label. The Valid Until date is the date on which authority to use the label expires.

Child Nutrition Label Verification System

The CN Label Verification System is available to assist CNP Operators and CDE reviewers in verifying the status of a CN label as well as the crediting information. During an AR, CDE reviewers may use this system to verify crediting information and the validity of the CN number on a CN label. CNP Operators may also use this system to check the Valid Until date in instances where a manufacturer has not updated the authorization date on the CN label; the CN Label Verification Report will provide the updated Valid Until date of the label.

Product Formulation Statements

If a processed end product does not possess a CN label, CNP Operators should obtain a complete and signed PFS to document meal pattern contributions for a processed food product. A PFS demonstrates how the processed end product contributes toward meal pattern requirements and should include the contribution to all components. All manufacturers must use the yields found in the USDA FBG to calculate meal pattern contributions. To avoid additional burdens on food industry partners, reviewers and CNP Operators must not request a PFS or additional crediting information when a valid CN label or watermarked CN label is provided.

The USDA developed PFS samples and templates for use as a guide for CNP Operators. These resources, as well as specific policies for Alternative Protein Products and a reviewer’s checklist, can be found on the USDA CN Labeling and PFS Guidance for Food Manufacturers/Industry web page at https://www.fns.usda.gov/cn/labeling/food-manufacturersindustry under the Manufacturer’s Product Formulation Statement subheading.

The USDA templates serve as guidance only and are not required. An acceptable PFS must be completed on the manufacturer’s letterhead and include all of the following:

• Product name, code number, and serving size
• Type and weight of the creditable ingredient
  
• Date signed
  
• Printed name, electronic or font signature, and title of the company representative certifying that the information on the PFS is true and correct
  
• Documentation of the manufacturer calculation

Product Formulation Statement Validation

A PFS must prove how the claimed credit was obtained in the finished product. It is never acceptable for a manufacturer to simply state that the product provides a certain amount of credit.

In the unusual event that a PFS for a specific end product claim to provide higher credit than that listed in the FBG, the PFS must demonstrate how the product provides that credit according to FNS regulations, guidance, or policy. Manufacturers must also verify that the credit a product contributes to the meal pattern is not greater than the serving size of the product and assure that the creditable components are visible in the finished product.

Any crediting information received from a manufacturer other than a valid CN label must be verified by the CNP Operator for accuracy. CNP Operators are responsible for ensuring that a menu fulfills all meal pattern requirements; therefore, all PFS must be validated.

To support CNP Operators and manufacturers and expedite the AR process, the Nutrition Services Division (NSD) staff are available to validate calculations for contribution to the meal pattern. CNP Operators can email the NSD directly at productformulation@cde.ca.gov. Manufacturers requiring technical assistance completing a PFS should first contact the USDA at cnpntab@usda.gov; if additional assistance is needed, the NSD can be reached by email at productformulation@cde.ca.gov.

This process does not provide an official approval for an end product.

Record Retention

Title 7, Code of Federal Regulations, sections 210.23(c), 220.8(a)(3), 225.15(c), and 250.19(b), require all CNP Operators to retain meal pattern contribution documentation for three years from the close of the fiscal year to which they pertain.

Other Considerations

Current CN labels and PFS are important to ensure products are appropriate for students with special dietary needs. Ensure your internal process includes a system to regularly monitor CN labels and PFS for product formulation changes.

For more information on accommodating disabilities, visit the following CDE web pages:

• Modifications to Accommodate Disabilities MB SNP-07-2025 at https://www.cde.ca.gov/ls/nu/sn/mbsnp072025.asp
  
• Disability Modifications Including Food Allergies at https://www.cde.ca.gov/ls/nu/sn/modaccomdisinclfoodalgry.asp

Resources

• The USDA FBG can be accessed at https://foodbuyingguide.fns.usda.gov/.
  
• Visit the USDA CN Labeling and PFS Guidance for Food Manufacturers/Industry web page at https://www.fns.usda.gov/cn/labeling/food-manufacturersindustry.
• The USDA CN Label Verification System is available on the CN Authorized Labels and Manufacturers web page at https://www.fns.usda.gov/cn/labeling/authorized-labels-manufacturers.
  
• The USDA’s CN Labeling Manual can be accessed at https://www.fns.usda.gov/cn/labeling/manual
  
• Access the USDA Manufacturer Documentation: CN and PFS web page at https://www.fns.usda.gov/cn/manufacturer-documentation.
  
• Review the USDA PFS Evaluation Tip Sheet on the USDA Tips for Evaluating a Manufacturer’s PFS web page at https://www.fns.usda.gov/cn/labeling/tips-evaluating-pfs.

Contact Information

CN Label Questions:

• School Nutrition Program (SNP) Operators with questions regarding CN labels can contact the School Nutrition Programs Unit at SNPInfo@cde.ca.gov.
  
• SFSP Operators with questions regarding CN labels can contact the Summer Nutrition Programs and Grants Unit at SFSP@cde.ca.gov.

PFS Questions:

• SNP Operators requiring PFS assistance can email NSD at productformulation@cde.ca.gov.
  
• Manufacturers requiring technical assistance completing a PFS should first contact USDA at cnpntab@usda.gov; if additional assistance is needed, contact NSD by email at productformulation@cde.ca.gov.

AR Questions:

SNP Operators requiring assistance about how CN labels and PFS are used in the AR process can email questions to FSU@cde.ca.gov.