Nutrition Services Division Management Bulletin
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
Date: April 2015
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 (https://www.fns.usda.gov/q-and-related-smart-snacks-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
MB CNP-06-2015 [Note: this bulletin is superseded by MB CNP-11-2015 available at http://www.cde.ca.gov/ls/nu/sn/mbcnp112015.asp].
Determining Compliance for a SmoothieA 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-27-2014 on the CDE Competitive Foods And Beverages—Determining Compliant Beverages Web page at http://www.cde.ca.gov/ls/nu/sn/mbsnp272014.asp.
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 http://www.cde.ca.gov/ls/nu/he/compfoods.asp.
If you have any questions regarding this MB, please contact the competitive foods and beverages team by e-mail at COMPETITIVEFOODS@cde.ca.gov.