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Classifying Smoothies-Revised

Nutrition Services Division Management Bulletin

Purpose: Policy

To: National School Lunch Program and School Breakfast Program Sponsors

Attention: County and District Superintendent, Chief Business Official, Food Service Director, Parent–Teacher Association President, Associated Student Body Director, and Other Parent and Student Group Leaders

Number: SNP-20-2015

Date: April 2015

Reference: California Education Code, sections 49430, 49431, 49431.2, and 49431.5; Title 5, California Code of Regulations, sections 15575–15578; Title 7, Code of Federal Regulations, sections 210.11 and 220.12; U.S. Department of Agriculture Policy Memorandum SP 23-2014(v.3): Revised Questions and Answers Related to the Smart Snacks in School Interim Final Rule

Supersedes: SNP-37-2014—Competitive Foods and Beverages: Classifying Smoothies

Subject: Competitive Foods and Beverages: Classifying Smoothies—Revised

This Management Bulletin (MB) provides additions and changes to MB SNP-37-2014 from the California Department of Education (CDE) Nutrition Services Division about classifying and determining compliance for smoothies. The updates include:

  • Juice is considered a food group when considering a smoothie as a food
  • Examples of a smoothie as a food when juice is the first ingredient

Prior to the U.S. Department of Agriculture (USDA) issuing Policy Memorandum
SP 23-2014 (v.3): Revised Questions and Answers Related to the Smart Snacks in School (SSIS) Interim Final Rule (, California presumed that a smoothie of any type or composition was considered a beverage under the competitive food and beverage rules. The Policy Memo provides written guidance that a smoothie can be considered a food or beverage, based on the composition of ingredients. California will follow the guidance provided in the USDA Policy Memo when classifying a smoothie sold as a competitive item.

It is important to note that this MB refers to requirements for a smoothie as a competitive item (i.e., an item sold to a student, on school campus, during the school day, outside of the National School Lunch Program [NSLP] or School Breakfast Program [SBP]) and not requirements for smoothies served within the NSLP or SBP. For smoothie requirements served in the NSLP or SBP, please reference the U.S. Department of Agriculture Policy Memo SP 40-2019 available at

Determining Compliance for a Smoothie
A smoothie, when sold as a competitive item, is categorized as either a food or a beverage.
  • A smoothie is a food if the first ingredient is a main food group category (e.g., fruit, vegetable, dairy, etc.). Under this definition, a fruit and/or vegetable juice is considered a main food group. If the first ingredient is water (or ice), then the second ingredient is used to determine if the smoothie is considered a food group. A smoothie deemed a food is further categorized as either a snack or an entrée based on additional ingredients. If the smoothie is a food and contains a meat alternate such as yogurt (Note: frozen yogurt is not considered a meat alternate) or peanut butter, it is considered an entrée and measured against the entrée requirements. A smoothie deemed a food that does not contain a meat alternate is considered a snack and must meet the competitive snack requirements. For example, a smoothie with the following ingredients is considered a snack food: apple juice, ice, frozen bananas, frozen strawberries, milk. If a meat alternate is also added, it is considered a competitive entrée. The apple juice is deemed a food group, which meets the definition of a smoothie as a food.

  • A smoothie is considered a beverage if it is comprised entirely of allowable competitive beverages. In this instance, the rules for compliant competitive beverages apply. For example, a smoothie with the following ingredients is considered a beverage: ice, apple juice, pear juice, nonfat milk.

For more information, please review MB SNP-08-2019 on the CDE Competitive Foods And Beverages—Determining Compliant Beverages web page at [Note: MB SNP-08-2019 supersedes MB SNP-27-2014].


For additional information, including trainings, updated Quick Reference Cards, MBs, and other competitive food and beverage resources, please visit the CDE Competitive Foods Web page at

Contact Information

If you have any questions regarding this MB, please contact the Competitive Foods and Beverages team by email at

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Wednesday, February 23, 2022
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