• None
• Product-based limits for grain-based desserts, breakfast cereals, yogurts, and flavored milks, effective in school year (SY) 2025-26.2
• Weekly added sugars limit that must average less than 10% of calories per meal, effective SY 2027-28.
Milk
• Allows flavored and unflavored for all grades K-12 (only fat-free and low-fat milks are allowed).
• Requires unflavored milk to be offered at each school meal service.
• Regulations affected: 7 CFR 210.10(d)(1)(i) and 220.8(d)
Two options, both of which would include the new added sugars limit for flavored milk and maintain the requirement that unflavored milk is offered at each meal service:
• Option 1: , Allow only unflavored milk for grades K-8 and allow flavored and unflavored for grades 9-12. OR Allow only unflavored milk for grades K-5 and allow flavored and unflavored for grades 6-12. Either proposal would be effective SY 2025-26.
• Option 2: Continue to allow flavored and unflavored milks for all grades (K-12).
Grains
• Requires at least 80% of the weekly grains offered to be whole grain-rich; remaining grain items offered must be enriched.
• Regulations affected: 7 CFR 210.10(c)(2)(iv) and 220.8(c)(2)(iv)
Two options:
• Keep the current standard.
• Require all grains to meet the whole grain-rich requirement, except enriched grains may be offered one day each school week.
• Meet Sodium Target 13 for school breakfast and lunch (and Target 1A4 for school lunch-only by school year 2023-24).
• Regulations affected: 7 CFR 210.10(c) and (f)(3); 220.8(c) and (f)(3)
• School breakfast – two reductions (10% each) in SY 2025-26 and 2027-28.5
• School lunch – three reductions (10% each) in SY 2025-26, 2027-28, and 2029-30.6
Professional Standards
• School nutrition directors must meet USDA hiring standards, including education requirements. Standards differ based on the size of the local education agency (LEA).
• Currently, school nutrition directors in medium LEAs (enrollment of 2,500-9,999) are required to have an associate’s or bachelor’s degree, and directors in large LEAs (enrollment of 10,000 or more) are required to have a bachelor’s degree.
• Regulation affected: 7 CFR 210.30(b)(1)
• State agencies could allow medium or large LEAs to hire an individual without a bachelor’s or associate’s degree as a school nutrition program director, if they have at least 10 years of school nutrition program experience.
Menu Planning Options for American Indian and Alaska Native Students
• Schools in American Samoa, Puerto Rico, and the U.S. Virgin Islands may substitute vegetables to meet the grains component.
• This option is intended to accommodate cultural food preferences, product availability, and cost concerns in these areas.
• Regulations affected: 7 CFR 225.16(f)(3), 226.20(f), 210.10(c)(3), and 220.8(c)(3)
• Allows tribally operated schools, schools operated by the Bureau of Indian Education, and schools serving primarily American Indian or Alaska Native children to serve vegetables to meet the grains requirement.
• Requests public input on additional menu planning options that would improve the child nutrition programs for American Indian and Alaska Native children.
Traditional Foods
• Traditional foods may be served in reimbursable meals in accordance with USDA guidance.
• Explicitly state in regulation that traditional foods may be served as part of a reimbursable school meal.
• Defines traditional food as “food that has traditionally been prepared and consumed by an [American] Indian Tribe,” per the Agriculture Improvement Act of 2014.
NSLP Afterschool Snacks
• NSLP afterschool snacks must contain two of the following four components: milk, meat/meat alternate, vegetable or fruit, or a serving of bread or equivalent.
• Regulations affected: 7 CFR 210.10(o)
• Aligns NSLP afterschool snack standards with the Child and Adult Care Food Program (CACFP) snack standards, which require snacks to include two of the following five components: milk, vegetables, fruits, grains, or meat/meat alternate.
• Makes fruit and vegetables two separate components, rather than being combined as one.
• Applies other CACFP snack nutrition requirements to NSLP snacks to align with statute.
Substituting Vegetables for Fruits at Breakfast
• Schools can substitute vegetables for fruits at breakfast, provided that there are at least two cups per week from the dark green, red/orange, beans and peas, or other vegetable subgroups on the menu that week. However, schools are currently allowed by law to substitute any vegetable for fruits at breakfast.
• Regulations affected: 7 CFR 220.8(c)
• Schools that substitute vegetables for fruits at breakfast more than one day per school week are required to offer different vegetable subgroups throughout the week.
Nuts and Seeds
• Nuts and seeds can be served as a meat/meat alternate, but only credit towards 50% of the component at breakfast, lunch, and supper, and must be served alongside another meat/meat alternate.
• Regulations affected: 7 CFR 210.10(c)(2)(iii)(C), 220.8(c)(2)(i)(B), 225.16(e)(5), 226.20(a)(5)(ii), and 226.20(c)(2)
• Allows nuts and seeds to credit for 100% of the meat/meat alternate component in all child nutrition programs and meals.
Competitive Foods (Smart Snacks) – Hummus Exemption
• Competitive foods must meet nutrient standards for calories, sodium, fats, and total sugars at 7 CFR 210.11(f).
• Total fat content of a competitive food must not exceed 35% and saturated fat must be less than 10% of total calories, though there are some exceptions.
• Keeps the current competitive food nutrient standards for calories, sodium, fats, and total sugars.
• Adds hummus to the list of foods exempt from the total fat standard in the regulations, allowing hummus to be sold as a Smart Snack.
Buy American
• School food authorities must purchase domestic commodities or products to the maximum extent practicable.
• Two limited exceptions, related to product availability and cost, are provided in guidance.
• Regulations affected: 7 CFR 210.21(d) and 220.16(d)
• Sets a 5% limit on non-domestic food purchases when a school food authority utilizes an exception.
• Updates federal regulations to include the exceptions related to product availability and cost that are currently only provided in guidance.
o School food authorities would need to maintain documentation showing that no more than 5% of their total annual commercial food costs are for non-domestic foods.
o School food authorities would be required to include the Buy American provision in all applicable procurement procedures, solicitations, and contracts.
• Updates regulations to clarify that over 51% of a food product must consist of agricultural commodities that were grown domestically.
• Adds language to the regulations that explain how Buy American applies to fish and fish products.
Geographic Preference Expansion
• Since 2011, child nutrition regulations allow geographic preference but do not allow “local” to be used as a bid specification (a written description of the product or service that the vendor must meet to be considered responsive and responsible).
• Currently, bidders located in a specified geographic area can be provided additional points or credit calculated during the evaluation of the proposals or bids received in response to a solicitation.
• Regulations affected: 7 CFR 210.21(g) and 220.16(f)
• Allows “locally grown, raised, or caught” to be used as procurement specifications for unprocessed or minimally processed food items, which makes it easier for program operators to purchase local foods for child nutrition programs.
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