Updates to School Nutrition Program Standards

This Management Bulletin (MB) provides Child Nutrition Program (CNP) Operators information and policy guidance regarding updates to CNP meal pattern requirements resulting from the U.S. Department of Food and Agriculture (USDA) Food and Nutrition Service Child Nutrition Programs: Meal Patterns Consistent with the 2020–2025 Dietary Guidelines for Americans (DGAs) (Final Rule) released on April 24, 2024.

Effective July 1, 2024, this Final Rule provides flexibilities for CNPs to phase in over the next few school years to meet the needs of vegetarian diets and other dietary preferences, offers support for procurement of local food, makes significant updates to nutrition standards, most notably for added sugar and sodium, and aligns the National School Lunch Program (NSLP) Afterschool Snacks meal pattern requirements for student in Kindergarten (K) through grade 12 with the Child and Adult Care Food Program (CACFP) snack standards. Per EC 48000, Transitional Kindergarten is considered the first year of a two-year Kindergarten program. For information on the preschool meal pattern, which may be used when Transitional Kindergarten students are served, review SNP-02-2019 Preschool Meal Pattern Requirements in the NSLP and School Breakfast Program (SBP), accessed at https://www.cde.ca.gov/ls/nu/sn/mbsnp022019.asp.

This MB provides guidance on the areas which directly impact meal planning for the following programs: NSLP, including Afterschool Snacks, SBP, the Special Milk Program (SMP), and the Summer Food Service Program (SFSP). This MB also provides information on California state requirements that impact foods served in schools and require California program operators to also meet these state requirements.

Background

In February 2022, the USDA published the Child Nutrition Programs: Transitional Standards for Milk, Whole Grains, and Sodium. Over two school years (SY), SY 2022–23 and SY 2023–24, these transitional standards implemented gradual change as the USDA worked on developing long-term nutrition standards to align with the DGAs.

This Final Rule implements long-term school nutrition requirement standards and flexibilities categorized into three areas: nutrition requirements, menu planning flexibilities, and program operations. Implementation dates started first with program flexibilities available as of July 1, 2024, followed by school nutrition standard updates as of July 1, 2025, and beyond.

Nutrition Requirements

The federal Final Rule establishes significant updates to school nutrition standards specifically for added sugars, flavored milk, and sodium for the NSLP and SBP as follows:

Added Sugar

Added sugar limits will occur in two phases:

• Phase 1. Effective July 1, 2025, implements product-based limits for breakfast cereals, yogurt, and flavored milk.
  
  
• Breakfast cereals may contain 6 grams (g) or less of added sugar per dry ounce (oz) (7 CFR sections 210.10[c][2][iii][B] and 220.8[c][2][iii][B]).
  
  
• Yogurt may contain 12 g or less of added sugars per 6 oz (2 g per oz) (7 CFR sections 210.10[c][2][iv][C] and 220.8[c][2][iv][C]).
  
  
• Flavored milk may contain:
  • 10 g or less of added sugar per 8 fluid oz when served in the reimbursable school meal program and when sold as a competitive beverage at any grade level (7 CFR sections 210.10[d][1][iii], 220.8[d], and 210.11[l][1][ii], [2][ii], and [3][ii]).
    
    
  • 15 g per 12 fluid oz when sold as a competitive food in middle and high schools only (7 CFR sections 210.10[d][1][iii], 220.8[d], and 210.11[2][ii] and [3][ii]).
    
    
• Phase 2. Effective July 1, 2027, implements a weekly added sugar specification which limits added sugars to less than 10 percent of calories per week (7 CFR sections 210.10[f][3] and 220.8[f][3]).
  

Sodium

• Through June 30, 2027, sodium limits remain unchanged. Limits will remain at sodium Target 1A for lunch and sodium Target 1 for breakfast.
  
  
• Effective July 1, 2027, sodium levels of the meals offered in the NSLP and SBP must align with the age/grade group and the corresponding sodium limit when averaged over the school week. It does not apply daily or per meal (7 CFR sections 210.10[f][4] and 220.8[f][4]).

Refer to the California Department of Education (CDE) NSLP and SBP Meal Pattern web pages for specific information on meal pattern requirements, accessed at https://www.cde.ca.gov/ls/nu/he/smi.asp.

Additional California Meal Pattern Requirements for State Meal Reimbursement

California law places restrictions on foods served in schools, as well as those served under the NSLP and SBP for public schools, charter schools, and county offices of education (COE).

• For public noncharter schools, charter schools, and COE:
  • Deep fried, par fried, or flash fried items, or items that contain artificial trans fats are prohibited per EC Section 49430.7 and school food authorities (SFAs) must annually certify compliance.
    
    
  • Beginning January 1, 2027, the manufacture, sale, or provision (delivering, distribution, holding, and offering) of food products in California that contain brominated vegetable oil, potassium bromate, propylparaben, and red dye number 3 is prohibited (Health and Safety Code Section 109025).
    
    
  • Beginning December 31, 2027, the definition of meals eligible for state reimbursement found in EC Section 49501.5 prohibits any of the following food dyes: Blue 1 (Chemical Abstract Service [CAS] 3844-45-9), Blue 2 (CAS 860-22-0), Green 3 (CAS 2353-45-9), Red 40 (CAS 25956-17-6), Yellow 5 (CAS 1934-21-0), and Yellow 6 (CAS 2783-94-0).
    
    
• For public, noncharter schools, effective December 31, 2027, the same food dyes listed above are prohibited in competitive foods sold in elementary, middle and high schools (EC sections 49431 and 49431.5).

Program Operators must complete an annual certification of compliance in the Child Nutrition Information and Payment System. The Certification of Compliance with Nutritional Requirements for State Meal Reimbursement form specifies in detail the nutrition standards that the law requires as a condition of receiving state meal reimbursement. The form is completed during the Annual Renewal Process for existing Program Operators. New operators complete the form during the initial application process. Public schools, charter schools, and COEs participating in the NSLP or SBP that fail to certify compliance with applicable nutrition requirements annually will be ineligible for state meal reimbursement.

Menu Planning Flexibilities

The Final Rule offers new menu planning flexibilities which support vegetarian diets and other dietary preferences. These changes do not require Program Operators to change their menus or their operations; however, operators may choose to implement these flexibilities at any time, unless otherwise noted.

Substituting Vegetables for Fruits at Breakfast

• One Day: Schools that choose to offer vegetables in place of fruits at breakfast one day per school week, may offer any vegetables, including starchy vegetables (7 CFR Section 220.8[c][2][ii]).
  
  
• Two or More Days: Schools that choose to offer vegetables in place of fruits at breakfast, two or more days during the school week, must offer vegetables from at least two different vegetable subgroups (7 CFR Section 220.8[c][2][ii]).

Note that the option to offer any vegetable, including starchy vegetables, for fruits at breakfast with no subgroup vegetable requirement ends as of June 30, 2025.

Nuts and Seeds

Allows nuts and seeds to credit for the full meats/meat alternates (M/MA) component for meals and snacks. This update impacts the NSLP, SBP, and SFSP.

Beans, Peas, and Lentils

• Subgroup name change: The name of the beans and peas (legumes) vegetable subgroup has changed to the beans, peas, and lentils (BPL) subgroup. This is consistent with subgroup names across other CNPs.
  
  
• BPLs at Lunch: Allows BPLs, when offered as a meat alternate, to also count towards the weekly BPL vegetable subgroup requirement but may not count toward the daily or weekly vegetable component (7 CFR Section 210.10[c][2][iv][E]).
  
  
• Competitive Foods - Bean Dip Total Fat Exemption: The final rule broadened the terminology used and now uses the term bean dip. This allows program operators to offer bean dips from other sources, as opposed to when the more limited term hummus was used.
  
  
  • Federal regulations: allow bean dip to be exempt from the total fat standard but still subject to the saturated fat, sugar, calorie, and sodium standards (7 CFR Section 210.11[a][7] and [f][2][ii]).
    
    
  • California regulations: do not allow a total fat exemption for bean dip (EC sections 49431[a][1] and 49431.2[a][1]). Therefore, in public noncharter schools, bean dips are not exempt from the total fat standard.

Meal Modifications

The Final Rule added Registered Dietitians (RD) to the list of State licensed healthcare professionals authorized to write medical statements requesting meal modifications due to a disability in the school meal programs. In California, this became effective April 1, 2025. As a result, RDs as well as licensed physicians, physician assistants, and nurse practitioners are authorized to complete and sign a written medical statement for a disability. The CDE does not recognize any other medical authorities as authorized to sign a written medical statement to substantiate modifications to a student’s diet (7 CFR sections 210.10[m] and 220.8[m] and 5 CCR Section 15560).

For more information, review the MB SNP-07-2025, Modifications to Accommodate Disabilities in the School Meal Programs, available on the CDE Modifications to Accommodate Disabilities web page at https://www.cde.ca.gov/ls/nu/accmmdsblts3-2025.asp.

Fluid Milk and Milk Substitutions

Meal Program Requirements: The Final Rule made various updates and changes related to fluid milk, fluid milk substitutes in NSLP, SBP, and SMP for individuals who have dietary needs unrelated to a disability and updated the nutrient component requirements for vitamin A and D in fluid milk substitutes in all CNPs. The Final Rule also provided regulatory updates regarding the allowability of accepting written requests for fluid milk substitutes from RDs, as previously noted above.

For more information, review the MB SNP-11-2024, Final Rule Regarding Fluid Milk Substitutions in School Nutrition Programs (SNP), available on the CDE Final Rule: Fluid Milk Substitutions web page, accessed at https://www.cde.ca.gov/ls/nu/sn/mbsnp112024.asp.

Whole Grain-Rich

Meal Program Requirements: The term whole grain-rich (WGR) is now defined in federal regulations for clarity. The term means that the whole-grain content of a product is between 50 and 100 percent and any remaining grains are enriched (7 CFR sections 220.8[c][2][iii][A] and 210.10[c][2][iii][A]).

Competitive Foods

• Federal regulations: require competitive entrées that contain a grain and that are sold by School Food Services the day of or the day after they appear on the reimbursable meal menu to be either WGR or enriched (7 CFR Section 210.11[a][3][i]). Charter and private schools may use this flexibility in their menu planning.
  
  
• California regulations: require all competitive foods that contain a grain to be WGR (EC sections 49431[a] and 49431.2[a], and 5 CCR sections 15575[c][1] and [4]). As a result, any competitive grain entrée served by public, noncharter schools must be WGR.

For more information, review the MB SNP-05-2025 Competitive Food and Beverage Entrées, Nutrient Standards, and Exemptions.

Grains or M/MA Category at Breakfast

The Final Rule creates a combined grains and M/MA meal component at breakfast, which allows schools to offer grains, M/MA, or a combination of both at breakfast. The Final Rule also removes the requirement for schools to offer 1.0 oz equivalent of grains each day at breakfast. The minimum creditable serving remains at 0.25 oz (7 CFR Section 210.10[c][2][iv]).

Synthetic Trans Fats

• Federal regulations: the Final Rule removed the dietary specification prohibiting synthetic trans fat in the in the NSLP, SBP, and competitive foods from the regulations, as synthetic trans fats are no longer allowed in the U.S. food supply.
  
  
• California regulations: as a condition of state meal reimbursement, state regulations continue to require the analysis of trans fats in food products served in school meal programs to ensure they contain less than 0.5 g of trans fat per serving; and, for public noncharter schools, state law requires the analysis of competitive foods for trans fat. (EC sections 49430.7[b][3]; 49431[a][4]; 49431.2[a][4], [b][1][C], and [b][2][D]; and 49431.7[a] and [b]).

Clarification on Potable Water Requirements

The Final Rule adds the word “plain” to the regulations requiring potable water to be offered with school meals during the lunch and breakfast meal service. “Plain” was added to prevent children with food allergies from consuming water with fruits, vegetables, or herbs (7 CFR sections 210.10[a][1][i] and 220.8[a][1]). These flavored waters may continue to be offered as long as there is a plain option available.

Substituting Vegetables for Grains in Tribal Communities

• For the NSLP and SBP, the Final Rule allows SFAs operated by the Bureau of Indian Education and that primarily serve American Indian or Alaska Native children to serve vegetables in order to meet the grains requirement (7 CFR sections 210.10[c][3] and 220.8[c][3]).
  
  
• For SFSP, the Final Rule allows sponsors, institutions, and facilities as applicable, who primarily serve American Indian or Alaska Native participants to substitute vegetables for grains or breads (7 CFR 225.16[f][3]).

Traditional Indigenous Foods

Traditional indigenous foods may credit toward the required meal components. Schools are encouraged to serve these foods as part of the breakfast, lunch, and afterschool snack service. Per 7 CFR sections 210.10[c][7] and 220.8[c][4], the term traditional foods refers to foods that have traditionally been prepared and consumed by an American Indian tribe, including wild game meat, fish, seafood, marine mammals, plants, and berries.

NSLP Afterschool Snacks Nutrition Requirements

Effective July 1, 2025, the nutrition requirements for NSLP afterschool snacks, served to K-12 children, now align with the Child and Adult Care Food Program (CACFP) snack standards as noted below (7 CFR Section 210.10[o][2][i]).

• NSLP afterschool snacks must include two of the five components.
  • The five components are: milk, M/MA, vegetables, fruits, and grains.
  • Fruits and vegetables were previously a combined component.
  • Only one of the two components served at snack may be a beverage.
    
    
• No more than half of the weekly fruit or vegetable offerings may be in the form of juice.
  
  
• Milk must be fat-free or low-fat and may be unflavored or flavored.
  
  
• Grain-based desserts do not count toward the grains requirement.
  
  
• Foods that are deep-fat fried on-site are not reimbursable as NSLP snacks. No change is required in California (EC Section 49430.7).
  
  
• Added sugars limits:
  • Breakfast cereals may contain 6 g or less of added sugar per dry oz and
  • Yogurt may contain 12 g or less of added sugars per 6 oz (2 g per oz).
    
    
• Other requirements:
  • Fruits and Vegetables: No more than half of the of the weekly fruit or vegetable offering may be in the form of juice.
    
  • Whole-grains: At least 80 percent of grains offered weekly (by ounce equivalents) must be WGR and the remaining grains items offered must be enriched. Grain-based desserts may not be used to meet the grains requirement.
    
    

Refer to the CDE Afterschool web page Meal Patterns tab at https://www.cde.ca.gov/ls/nu/as/ for specific information on the USDA NSLP Meal Pattern for Afterschool Snacks Program.

Program Operations

This Final Rule enacted other requirements which support CNP operations, such as geographic preference, Buy American, and professional standards.

Geographic Preference

The Final Rule expands the geographic preference option by allowing the terms “locally grown,” “locally caught,” and “locally raised” as procurement specifications.

For more information, review CDE’s MB CNP-03-2024 Applying Geographic Preference in Procurement MB, available at https://www.cde.ca.gov/ls/nu/sn/cnp032024.asp.

Buy American

The Final Rule codifies and establishes new Buy American requirements which were previously included in policy guidance. Specifically, 7 CFR sections 210.21[d] and 220.16[d] requires SFA procurements to include Buy American, allows for limited exceptions to the provision, creates a phased-in cap on non-domestic products, establishes documentation and reporting requirements for exceptions, defines “substantially” for domestic agricultural products, and clarifies requirements for fish and fish products.

For more information on this subject review the MB SNP-01-2025 Buy American Provision MB available at https://www.cde.ca.gov/ls/nu/sn/snp012025.asp.

Professional Standards

The Final Rule permits the CDE the discretion to allow medium or large SFAs to hire an individual without a bachelor’s degree or associate degree as a SNP director if the individual has a high school diploma or who has passed the General Education Development (GED) exams and 10 or more years of SNP experience (7 CFR Section 210.30[b][1][iv][B]).

Resources

• USDA Updates to the School Nutrition Standards web page at https://www.fns.usda.gov/cn/school-nutrition-standards-updates.
  
  
• USDA Final Rule - Child Nutrition Programs: Meal Patterns Consistent With the 2020–2025 DGAs at https://www.fns.usda.gov/cn/fr-042524.
  
  
• USDA Crediting Tip Sheets in Child Nutrition Programs at https://www.fns.usda.gov/tn/cn/crediting-tipsheets.
  
  
• CDE NSLP and SBP Meal Patterns web page at https://www.cde.ca.gov/ls/nu/he/smi.asp.
  
  
• CDE Milk Requirements in the CNPs web page at https://www.cde.ca.gov/ls/nu/he/milkrequirementsincnps.asp.
  
  
• CDE Disability Modifications Including Food Allergies web page at https://www.cde.ca.gov/ls/nu/sn/modaccomdisinclfoodalgry.asp.
  
  
• CDE Drinking Water for Student in School web page at https://www.cde.ca.gov/ls/nu/he/water.asp.
  
  
• CDE Food Safety web page at https://www.cde.ca.gov/ls/nu/ed/foodsafety.asp.
  
  
• CDE Professional Standards web page at https://www.cde.ca.gov/ls/nu/pd-ps.asp.

Contact Information

• For SNP meal pattern questions email the SNP Unit at SNPInfo@cde.ca.gov.
  
  
• For SFSP questions email the SFSP team at SFSP@cde.ca.gov.
  
  
• For competitive foods questions email the Competitive Foods and Beverages team at COMPETITIVEFOODS@cde.ca.gov.
  
  
• For professional standards questions email the professional standards team at ProfessionalStandards@cde.ca.gov.
  
  
• For Buy American procurement questions regarding procedures, solicitations, and contract processes email the team at NSDBuyAmericanProvision@cde.ca.gov.
  
  
• For geographic preference questions email the Procurement Resources Unit at NSDProcurementReview@cde.ca.gov.